ATEC Illustrates Difficult Path to Education Reform

By Kathryn B. Creedy

The opening of applications for two $5 million workforce aviation/aerospace workforce grant programs is a positive move, coming more than two years after the 2018 Reauthorization package calling for their creation.

However, it is only the tip of the iceberg on the towering task to promote aviation careers and reform aviation/aerospace education and training that includes new curricula on emerging technology, advanced manufacturing and engineering.

The grants are only a part of federal efforts to promote aviation/aerospace careers and improve the diversity of the industry. The FAA is now overseeing the Youth Access to American Aviation Jobs Task Force and the Women in Aviation Advisory Board, which are working diligently to create road maps for future workforce development. This, ironically, comes at a time when the General Accountability Office concluded FAA needs its own workforce development program.

Industry Workforce Development, Education Programs Abound

Meanwhile, industry has been working diligently on such programs, leveraging high schools, career & technical education and community colleges to train to the meet immediate needs. (See related story on the progress of aviation/aerospace career promotion and education.)

An example of the task ahead on education and training reform, is the recent passage of The Promoting Aviation Regulations for Technical Training (PARTT) 147 Act instructing the FAA to replace the current too-prescriptive language of Part 147 with community-drafted language that leverages competency-based instruction and focuses on outcomes based on new airmen certification standards (ACS) developed by FAA and industry.

A decades long effort, the new curriculum significantly streamlines education, enabling institutions to tailor coursework to the student and open satellite locations to increase the number of students in the pipeline.

Academia Now Echoing Tech School Concerns

Significantly, ATEC and the maintenance industry’s concerns about education and training are now being echoed in the halls of aviation universities about aeronautical engineering. This will be the subject of a panel discussion later this week at the Vertical Flight Society’s eVTOL2021 conference.

The problem is, industry and educators cannot afford decades long efforts at reform, not with how rapidly technology changes. Ultimately, the maintenance schools had to do an end run around the FAA in order to get what it needed.

The measure was spearheaded by the Aviation Technical Education Council (ATEC) and is the culmination of calls for the changes dating back to a General Accountability Office report in 2003. Unfortunately, numerous efforts for change by working with the FAA did not yield what industry, educators and labor were looking for, according to Justin Madden, executive director of Government Affairs, Aircraft Mechanics Fraternal Association (AMFA).

“Industry was telling educators they don’t want to retrain new hires but want them trained as part of the education process,” he said

The failure of both the Notice of Proposed Rulemaking and the Supplemental NPRM to meet industry education needs forced supporters to seek legislation through Congress when they felt they were not being heard by regulators. But ATEC expressed caution about this approach.

“The Administrative Procedures Act sets forth the rules for promulgating regulation, including the requirement that the agency put out proposals and ask for (and consider) feedback, as well as economic impacts,” said ATEC Executive Director Crystal Maguire. “That is good for industry and we certainly don’t want to make a habit out of bypassing that very important process. It’s just that, in this case, we’d waited so long and were so frustrated by the FAA proposals, we thought it was warranted.”

The move to competency-based training might have implications for other higher-education institutions seeking changes to their own curriculum to accommodate new technology.

Little Association That Could

Not a lobbying organization, ATEC managed to wrangle a significant coalition of supporters among aviation groups in Washington, member schools, businesses and sponsors on Capitol Hill. To put ATEC’s accomplishement into perspective, Madden, who worked with ATEC on the effort, noted 14,000 pieces of legislation are introduced in a given Congress but only 300, just 2%, become law.

A true grass-roots effort, members did numerous “fly-ins” to discuss the disconnect between what industry needs and the ability for educators to deliver given antiquated regulations. The legislative process brought FAA in, enabling tweaking of the language to address FAA concerns.

“Often the FAA’s concerns were valid, and it gave the community, labor and industry a good opportunity to make changes,” said Joel English, executive vice president, Aviation Institute of Maintenance (AIM). “Even though we think the FAA certification process was arduous, it did give the entire sector a level of professionalism based on doing it right and that has allowed us to relax some things with the new Part 147. Serving two masters – education accreditors and the FAA – it was difficult to get it right, but we’ll hold on to those things we think are right in the interest of safety.”

The new rule streamlines oversight, eliminating the duplication – and conflict – between the accreditation and quality control requirements under the Department of Education and FAA. Non-accredited schools, including high schools, will still need to provide a quality system for FAA approval. In addition, separate approvals for distance learning are no longer required because the rule is based on performance and student test results.

In fact, an important part of the new rule means increased reliance on distance learning. Fred Dyen, professor, Blue Ridge Community College reported that many of his courses and projects can be taught online. “As long as you can impart knowledge, skills and risk mitigation virtually and can demonstrate that it results in competency you can go online,” he said.

“The FAA still looks at student performance as they do now,” English noted. “But now, if a school does not achieve a 70% passage rate over a three-year cycle, it would prompt FAA to take a closer look at the school.”

Indeed, one of the greatest contributions of the new Part 147 is the ability to streamline education and deliver a workforce with the knowledge and skills needed for companies to get them on the job from day one, without expensive training programs.

FAA Grants

Spearheaded by the Aeronautical Repair Station Association (ARSA), the grants fund between $25,000 and $500,000 for any single grant per fiscal year with applications due March 22. ARSA recently advised, FAA “strongly recommended” prospective candidates for grants submit a non-binding notice of intent by Jan. 29. 

The Aircraft Pilots Workforce Development Grants are designed to expand the pilot workforce and educate students to become pilots, aerospace engineers or unmanned aircraft systems operators.  Meanwhile, the Aviation Maintenance Technical Workers Workforce Development Grants will help prepare a more inclusive talent pool of aviation maintenance technicians, according to the FAA release.

This is the first opening of applications despite the fact Congress appropriated full funding for the two grants for FY2020. The programs were also fully funded by the year-end omnibus bill for FY21, said ARSA Executive Vice President Christian Klein in a recent brief. ARSA continues work on pushing full funding for FY22 and FY23.

“The launch of the grant programs is another important step towards solving the maintenance industry’s long-standing workforce challenges,” said Klein. “Unfortunately, we find ourselves in very different circumstances than when the program was conceived more than three years ago. Today, in addition to fostering collaboration between schools, businesses, unions and government to recruit and prepare the next generation for successful aviation careers as maintenance technicians, these grants will also help rebuild our workforce in the wake of unprecedented economic disruption.”

Indeed, retraining and reskilling programs are a critical part of retaining the aviation/aerospace workforce as technology changes. It is also an important evolution long past due since the 40 years after digitalization displaced millions of high-value, well-paying factory jobs. As workers were replace by robots or jobs were outsourced, other developed countries implemented robust reskilling, upskilling and retraining programs to help transition affected workers into new jobs. Much could have been accomplished if the US had embraced new technology with retraining, for instance, coal miners and oil workers to clean energy, thus eliminating the hardship their redundancies have created in the interim.

While this is important, we still need to increase the number of aviation maintenance technicians to prepare for recovery and the tightened labor market created by accelerated retirements brough on by Covid-19.

ATEC Provides Path to the Future

Industry efforts were eloquently recounted in a recent ATEC webinar that impressively told aviation schools exactly what changes were wrought and what specifically they need to do accommodate those changes. Indeed, ATEC has been at the forefront of providing blow-by-blow guidance and instruction, including templates, to members on everything from this new rule to transitioning to digital instruction in the wake of Covid-19. The PowerPoint presentation from the webinar is here while resources are here since operational specifications for schools will need revision.

The legislation directs FAA to replace Part 147 with the new language within 90 days of the December 27, 2020 enactment which puts it in late March, although such deadlines often slip.

ATEC said the new rule requires:

• Schools to align curriculum with Airman Certification Standards (ACS), free from FAA micromanagement which means there are no FAA curriculum approvals necessary.
• FAA to assess program quality based on student test performance.
• FAA to defer to the Department of Education for oversight of all educational elements for schools that are nationally accredited institutions.
• FAA will assess the quality of A&P programs, facilities, materials, equipment, additional fixed locations, instructor qualifications, student-to-instructor ratio for shop class, for non-federally accredited organizations.

“ACS is the glue that pulls together the curriculum and the test,” said Jared Britt, director of Global Aviation Maintenance Training, Southern Utah University. “It aligns everything, is more conducive to education and helps students. It also allows us to work more closely with our industry partners to gain valuable feedback on which parts of the curriculum need work based on their experience of hiring our students.”

Another important provision is the ability for technician schools to create satellite locations at local high schools providing certificate programs and allowing students to receive both high school and college credit. Such dual certification programs are already available in non-aviation disciplines in high schools across the US. Technical schools, however, must have those satellite locations on their operations specifications, mirroring the same requirement for Part 145 repair stations.

“The ability to open satellite locations is going to open up the flood gates for aviation maintenance technician schools and provide training for more students,” said Dyen. “We have high school teachers teaching this curriculum for 20 years, but students received no credit. With the new Part 147, schools can make instructors adjuncts to get both high school and college credit.”

Linking curriculum to the new airmen certification standards means students must demonstrate competency in knowledge, skills and risk mitigation. FAA, in coordination with industry representatives, developed a draft ACS last year. It hasn’t been published yet although it is available from ATEC, so schools could work on curriculum changes. It is continuously updated as changes are made.

The plan is to revise ACS periodically – perhaps on a two-year cycle – as new technology emerges. This means curriculum will be continuously updated as well. FAA already does this for pilots, resulting from new pilot certification standards enacted previously. Britt said it gives schools more freedom and flexibility to go about educating students within the framework of the ACS.

There is also no “seat-time,” or credit-hour requirement, leaving schools free to structure the program in whatever manner best conveys the elements outlined in the ACS. This also eliminates the need for experienced workers – veterans for instance – to repeat curriculum they already know, as long as they can demonstrate they have mastered it. It means students can work at their own pace and skip areas they are already competent in for faster certification. And students who need extra help proving competency will get that help rather than the one-size-fits-all approach of the old regulation.

“Time based learning is an antiquated concept, and this helps us rebuild the time requirements,” said James Hall, Dean of Aviation and Manufacturing National Center for Aviation Training, WSU Tech, “We are newly focused around what it takes to teach the novice to become worthy of certification. Now we have the flexibility to ignore time in favor of ensuring competencies. We can also streamline curriculum that are repetitive and cover the same material in different classes or when they have done these courses in high school or college.”

“We have a lot of students who are in manufacturing hubs who have a lot of experience in sheet metal,” Lewis University’s Todd Shuneman said. “They can now demonstrate their competency and move on. Students can also take entry-level exams so schools can develop a program tailored to them, rather than repeat training they’ve already had.”

Flexibility

Schools were struggling to incorporate new curriculum needed to prepare workers for emerging technology within the requisite hours of the old regulation. So, the flexibility of the new Part 147 is a boon to creating a dynamic, ever-changing curriculum that meets industry needs.

“This now gives schools the freedom to innovate,” said Maguire. “Schools are already brainstorming ways to innovate with their programs.”

For now, schools need to do a Gap analysis between the proposed ACS and their curriculum and more closely align that curriculum with it.

After doing the gap analysis, Shuneman, reported the curriculum was 90% aligned with the new Part 147. A gap analysis template is available on ATEC’s website.

The pressure is on to accommodate emerging technologies as reported by FA/AW News in November. While academia and industry struggle with how to change curriculum, the regulatory barrier looms large and requires new thinking. ATEC’s example provides one example but others will surely follow.