FAA Draft of new "Enhanced" Certification Standards

I just received my copy of the new draft of the Airman Certification Standards (ACS). After spending the day mulling it over let me give you some observations.

New Format
First of all its long, over 75 pages of charts containing a new numbering system. This is because the new standard is now a combination of the three old standards for Generals, Airframe, and Powerplant. Probably to allow the FAA to revise a single document in the future instead of three. Also included in each section is a new type of questions already included in the pilot standards.,

These new questions have a special emphasis on the mitigation of risks AKA Risk management and SMS. The current standard for the oral and practical the applicant would be asked a question to evaluate knowledge then perform a physical task. When the risk management test standard is in place, an applicant will be required to identify risks associatedwith the task and then describe to the DME  how to assess and mitigate these risks. This will require applicants to have a greater in-depth knowledge of the subject than in the past.

New Content
The devil is in the details. As I review the new subject areas I compare the current FAR 147 curriculum subject, the biggest change that jumps out is the number of new subject areas. although the main subject titles are the somewhat the same, individual items are greater in number. For example; Basic Electricity is now called Fundamentals of Electricity and Electrons. FAR 147 only has 6 subject areas while the knowledge test standards now have 43 individual questions that can be asked. So you don't have to I counted all of the possible areas in all three question types.

General Subject Total             350
Airframe Subject Total           458
Powerplant Subject Items       346
Total Possible                        1154

Source Material
When you look at each subject areas what jumps out is the sources used to create the questions. For most subject areas in the original standard the FAA-H-8083-XX are referenced. However, these new questions now include the relevant FAR, Advisory Circular and other FAA Handbooks. A  summary of the references are;

FAA-H-8083-30
FAA-H-8083-1
FAA-H-8083-31
FAA-H-8083-32
14 CFR 21,23,25,43, 65, 91
AC43.13-1
AC43.13-2
AC 150/520-20

In addition to these reference documents, the applicant will need to be familiar with the associated maintenance and test documents that would be required for all of the practical test apparatus that would be required.

Conclusion
I applaud the FAA for a great start, and I will have some opinions of my own on the AFS 630 comments section: AFS 630 Comments. Again the FAA still has not felt the need to have an additional rating for Avionics Technician but rather created a standard where someone holding an Airframe rating would be required to learn more Instrument and Com/Nav subjects.  However, it's unclear how in-depth the applicant will need to know about added avionics subjects.


The real question for the FAR 147 schools is how are they going to prepare students for the new Airman Certification Standards. Each school will need to look at all 1154 subjects and determine if there are sufficient course classroom and practical materials to prepare the applicants.

Another observation I have is; can all of the subjects be taught in the 1900 minimum hour now required by the current FAR 147 rule?  I suspect that the new FAR 147 rewrite that has been promised that would be similar to these ACS.  Are the instructors prepared to teach the new material, will be enough equipment on hand to administer the tests and how well will the students retain the information.

The FAR 147 curriculum rewrite would need to include an increase in the minimum class hour requirements. At a minimum, the test standard is really going to be challenging and will require better preparation by future mechanics.

Take a look at the standard and tell me what you think.
Bruce Bessette




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