School Discipline

In my youth, I attended parochial school, ruled by nuns with a penchant for school discipline. Whether control was achieved by such actions as the ‘Board’ of Education, community service (pounding erasers) or – Eek! Gasp! – a letter home to my parents, nuns maintained total rule over their immature, life-inexperienced, dependent charges. We did survive … and succeeded because of that ‘cruel’ discipline.

This isn’t about that type of school discipline.

The aircraft maintenance (ACMX) community has always gotten the short straw. ACMX circulars use pilots (not mechanics) to interpret regulations for airframe and powerplant (A&P) mechanics, where they tell A&Ps how pilots want them to be. The National Transportation Safety Board (NTSB) uses engineers to lecture A&Ps about what engineers think maybe, might’ve, could’ve, probably(?) happened in accidents. The Federal Aviation Administration (FAA) shelved ACMX safety from 2019 – (?) when Acting Mismanagement pushed Progressive quack theory: diversity, equity, inclusion (DEI) – not safety.

What made United States’ A&Ps the best in the world? It was (key word ‘was’) largely due to A&P trade schools teaching ACMX fundamental and discipline. But now Title 14 code of federal regulations (CFR) Part147 Aviation Maintenance Technician Schools (AMTS) have been erroneously rewritten, altered in ways that ruined future FAA-certificated A&Ps’ basic understandings of ACMX techniques while leaving the FAA Airworthiness aviation safety inspector (ASI) powerless to conduct proper AMTS oversight. Was ACMX probity diminished because: A&P numbers are dwindling; government blundered through CØVID; and/or has DEI destroyed A&P rectitude? AMTSs are graduating A&Ps who won’t possess the basic skills and discipline to be effective. Did FAA upper management play a role in crippling the future of the ACMX success?

The FAA took part in amending how AMTSs train up-and-coming A&Ps through a 2015 amendment introduced during the CØVID crises. Conspiracy theory, right? Or is it? Question: What does it take to change a regulation? Answer: Five years and $5,000,000 dollars just to change one regulation. From 2015 to 2020, the FAA rewrote fifteen Part 147 regulations and removed eight … and cut four Appendices. That’s twenty-seven Part 147 regulations changed or removed at $5,000,000 dollars each.

According to Advisory Circular (AC) 147-3C, paragraph 1.7.2.1: “On October 2, 2015, the FAA published an NPRM [Notices of Proposed Rulemaking] … the FAA proposed to amend the regulations governing the curriculum and operation of FAA-certificated AMTSs. The FAA proposed to modernize and reorganize the required curriculum subjects found in the appendices of the current regulations, remove the course content items from the appendices and relocate them to each school’s operations specifications (OpSpecs), and revise the curriculum requirements to include an option for schools to use a credit hour curriculum as an alternative to an instructional hour curriculum.” Wait, what?!!

Although an AC isn’t regulatory, it is FAA guidance for industry on how to write manuals, train employees, create programs, etc. When new or existing AMTSs follow AC 147-3C, they follow the new standards because the FAA accepts AC 147-3C’s procedures. AC 147-3C states, “… if you choose to follow this AC as the means to meet the provisions of 14 CFR 147, then you must follow the AC in its entirety.” So, following the AC verbatim makes the AMTS’s resulting processes regulatory. This is important. Was Part 147 radically changed, resulting in unsafe ACMX instruction?

We must understand, AC 147-3C paragraph 1.7.2.2 states: The FAA proposed on April 16, 2019, “… (1) to allow curriculums using competency-based training programs as a curriculum delivery; (2) to allow the establishment of satellite training locations: and (3) to remove the national passing norm requirements in §147.37 and replace them with standard pass rate.” Why? Is “competency-based” a real term or just buzz words? What does “standard pass rate” even mean? Congress told the FAA to replace Title 14 CFR Part 147 (to be in effect on Section 135’s enactment date) with new regulations that conform to the statutory requirements. To be clear, the US Congress – bureaucrats who know nothing about AMTSs – pushed the FAA to change how AMTSs train soon-to-be FAA-certificated A&P students. This went through the NPRM process, but let’s be honest, nobody reads NPRMs for AMTSs – nobody.

Congress has been playing FAA budget misdirection for years. As a result, FAA upper management puppets what Congress imposes. Was this pushed by lobbyists? The function of the FAA Airworthiness ASI has become a little less relevant, ironically making FAA management … even more irrelevant.

AC 147-3B (AC 147-3C’s predecessor) was published on June 5, 2015, four months before the NPRMs were circulated; it’s still in the archives to compare against -3C. Comparing the two, one can see what changes were made to FAA guidance. So, what were these changes?

NOTE: When FAA guidance is changed, new wording is highlighted with Revision Bars: dark bars that run down the page’s side.

**FAA Order 8900.1 Volume 6 Chapter 10 Section 5**

When reviewing FAA Order 8900.1 Volume 06 Surveillance, Chapter 10 Part 147 Inspections, Sections 01 through 07, revision bars are everywhere: almost everything was revised. That’s not good. Who can tell what’s new? Whole sections are nothing but revised material. For instance, why is Accreditation mentioned twice in AC 147-3B (in only one sentence), but Accreditation shows up 41 times in AC 147-3C? AC 147-3C points to the US Department of Education (DOE) accrediting AMTSs. Why? What does the DOE know about aviation training? AMTSs are trade schools; they may have accredited electives, like Math. Why is the DOE now deciding what goes in an A&P-certificate curriculum?

Answer: Because AMTSs are being nationalized. Can local FAA ASIs conduct effective oversight and onsite surveillance when the AMTS itself is nationalized? And AMTSs adopted alternate methods of instruction, such as virtual classrooms, computer-based instruction (CBI) and virtual simulations for practical training. Can local FAA ASIs oversee virtual class effectiveness? Nationalizing sacrifices lesson quality and personal safety since the AMTS sets the curriculum while simultaneously eliminating the FAA. Wait, why isn’t the FAA determining curriculum? Isn’t that in the regulations?

Regulation Changes: Another AC 147-3B to 3C point of interest – Before the regulation changes, Part 147 was separated into three Subparts, A: General, B: Certification Requirements, and C: Operating Rules; followed by Appendices A: Curriculum Requirements, B: General Curriculum Requirements, C: Airframe Curriculum, and D: Powerplant Curriculum. Revised Subparts were reduced to two A: General and B: Certification and Operating Requirements. What about the four curriculum Appendices? Presto! THEY’RE GONE! Moved to the operations specifications. What are operations specifications?

**Pre-2015 Title 14 CFR 147 Appendix D Powerplant Curriculum**

OpSpecs: Operation specifications (OpSpecs) are a contract – an agreement – between the FAA and the certificate holder, such as an AMTS. When they moved curriculum from the regulations to the OpSpecs, the curriculum isn’t regulatory anymore. Is curriculum FAA-enforceable anymore?

Curriculum Basis: Then there’s the question – Why did Part 147 change the time requirements from 18 months per certificate (30 months for two) to a choice between Hours-based or Credit Hour based? The Credit Hour based is not clearly defined, but AC 147-3C makes clear that Part 147 no longer prescribes (regulates) minimum credit hours. Will determining credit hours be the DOE’s responsibility?

But let’s look at Hours-based. As an example, 1,150 hours are required for each certificate if pursued separately. Doing the math, the Airframe certificate requires 16 class hours per week. That’s only three class hours per day for completion. That’s equal to one class per day, which doesn’t even qualify as a part-time student’s class load. The hours match those required before Part 147’s revision. However, the Title 14 Subpart 147.21 specified two differences. One, per paragraph (b), “The curriculum must offer - at least - [dashes added] the following number of hours of instruction for the rating shown and the instruction unit hour shall not be less than 50 minutes in length.” Instruction time does not include time for practical exercises. Two, “The curriculum must cover the subjects and items prescribed in appendices B, C, or D as applicable. Each item must be taught to at least the indicated level of proficiency as defined in Appendix A.” The appendices have been deleted, so the curriculum that is now being determined does not have to maintain the same level of proficiency - by regulation. But Appendix A further defines ‘levels of proficiency’ as, for example, “‘Inspect’ means to examine by sight AND touch.” “‘Repair’ means to correct a defective condition. Repair of an airframe or powerplant system includes component replacement and adjustment, but not component repair.” How does one simulate a repair’s replacement and adjustment? How does one touch in a simulated inspection?

The new and improved curriculum also allows instruction to be delivered out of order, meaning no being held to prerequisites. The instruction can be delivered with no regard to understanding the material as it was designed to be presented.

In addition, a major difference due to the Part 147 rewrite is what is considered the “authenticated document” in Title 14 CFR Subpart 65.77. Per revised Subpart 147.21, authenticated document is, “…indicating the student’s date of graduation and curriculum completed.” Is revised Subpart 147.21 allowing a certificate of completion to be a future date, to be completed after certification? “… an appropriate graduation certificate or certificate of completion …” satisfied Subpart 65.77 pre-2015; a date of completion was in the past tense – certificate in hand. Is this an unethical game with unclear wording, questionable details that are a smoke-and-mirrors distraction? How will designated maintenance examiners, who give the certification tests, to interpret authenticated document?

Curriculum Delivery Methods: The guidance describes the possible methods for curriculum to be delivered. A) In person; B) Distance Learning; and C) Virtual Simulation:

· The Virtual Simulation method is described as, “Many AMTSs are incorporating virtual simulation for conducting practical application for certain skills. For example, virtual welding and virtual paint booths use simulated equipment and technology to provide near-real environments …” They excuse the unproven method as, “… minimizing the hazards associated with those environments.” This is false! Virtual simulations in practical environments are the very definition of hazardous; they are video game techniques, not based in reality. How do A&P students understand the risks of oxy-acetylene, proper aircraft jacking, hands-on use of torque wrenches, or effective Non-destructive Testing training? Who can teach students virtual study? University professors? Other unqualified persons?

· The Distance Learning method is supposed to be a combination of CBI and virtual classroom instruction. CBI guarantees the students (those who don’t fall asleep in an instructor-free class) cannot ask questions. For decades, A&P classes combined in-person instruction with practical instruction. Practical courses cannot be taught, they must be experienced. The FAA, itself has failed to implement these same distance learning/CBI methods in its FAA Academy. No proof exists these methods even work in practical applications. Lessons in troubleshooting fuel metering systems or installing a variable speed propeller cannot be simulated. CBI only works if coupled with practical, hands-on training, such as on-the-job training, that supports the CBI. Distance learning only works as textbook instruction – not where the students rely heavily on practical class participation.

Look in 8900.1 V06 C10 S05 6-10-5-5 General Discussion: (B) Curriculum description (3) Curriculum Delivery Method, where it says the FAA doesn’t approve a school’s curriculum delivery method. To be clear, the same DOE that crippled the public school system, that sent our children and grandchildren three years backwards during CØVID, is now in control of A&P curriculum. The DOE is out of its element.

It is why the FAA should’ve never been sidelined, why continuing resolution was – and still is – a farce, political games. Politicians play to win votes while the public safety suffers. Why would industry respect the FAA’s authority when it’s suspended at the whim of Congressional incompetence? Kicking FAA budgets down the road has irreparably damaged its effectiveness. FAA temporary upper management assignments are even worse; it’s where bureaucrats check boxes for a private sector job or warm a chair while promoting social agenda items that don’t work, instead of promoting aviation safety.

What are the consequences of the Part 147 rewrite?

1 – The FAA no longer directs the curriculum for aviation technicians. Who is to act as the experienced authority on curriculum? University professors? Deans of the Liberal Arts departments? There’s no reason to doubt professors with tenure will replace experienced aviation instructors. Clearly, the aviation industry was crippled – safety-wise – by the CØVID shutdowns. We now understand the damage from what should’ve remained as FAA ‘business-as-usual’ – not hiding from on-site oversight. These changes make aviation safety even further out of reach.

2 – Under the DOE, the same curriculums taught by universities will be forced – not suggested – on trade schools, such as AMTSs. With DOE making the class selections, they will require Progressive studies, such as Diversity, Equity, and Inclusion; white privilege; and other socialist studies forced on future A&Ps to pay for and sit through. These future candidates will be obliged to suffer these courses or face dismissal or refused graduation. Will indoctrination be on the curriculum?

3 – The unrealistic use of virtual practical exercises and CBI eventually will eventually become the norm. Repetition will dull the senses of those in charge of A&P certification. The lie of ineffective teaching processes in A&P instruction will become the reality because the lie is repeated often enough.

Think people! What has the aviation industry given up? Title 14 CFR Subpart 121.367 (b) and Subpart 135.425 (b), both require, by regulation, “Competent personnel”, not only for these certificated air carriers, but for the repair stations and maintenance providers who support them. That covers just about every A&P coming out of AMTSs. We’ll end up with A&Ps who can’t even safety wire a bolt because the internet didn’t work the day they taught that lesson. We’ve sacrificed education quality and safety because nobody wanted to leave their house. Discipline in any field begins with what was learned in training or in school. The revised Part 147 is the antithesis of discipline.

Hours

Experienced

… Professional

… … Safety-Focused

AMSP