April 18, 2018
Brenda Robeson
Office of Rulemaking
Federal Aviation Administration
800 Independence Avenue SW
Washington, DC 20591– 0001
RE: Petition for Exemption; Southern Utah University
Docket No. FAA–2018–0215
Federal Aviation Administration
Dear Ms. Robeson,
On behalf of the Transport Workers Union of America, AFL-CIO (TWU), I submit these comments to the Federal Aviation Administration’s notice regarding a petition for exemption filed by Southern Utah University (SUU). The TWU represents 145,000 transportation workers employed in the rail, transit, and aviation sectors. This includes 10,000 members employed in the aviation maintenance industry, many of whom have completed training at Aviation Maintenance Technician schools (AMTS) and maintain Airframe and Powerplant (A&P) mechanic certificates. We therefore have a direct and vested interest in the docket.
In its petition, SUU requests an exemption to use a credit hour system for A&P courses as opposed to the current clock hours system. The TWU understands the importance of attracting qualified workers to the aircraft maintenance industry and appreciates SUU’s interest in doing so. But as the agency considers SUU’s petition to modify its curriculum structure, we encourage the FAA to consider the following to ensure that students pursuing the A&P certificate at SUU receive training comparable to that required in the current regulations.
While we understand that there are existing programs which operate under the credit hour system as opposed to clock hours, the FAA must require that SUU’s program does not reduce the total training its students receive. In most college settings, courses calculated by credit hours have policies in place that permit student absences without penalty. However, current maintenance policies and standards require that students pursuing A&P certificates at AMTS make-up any hours missed. This ensures AMTS students receive all the training and education they are intended to receive. The FAA must ensure that SUU’s program has similar requirements in place to require students to make-up any missed classes, as this will help prevent SUU from graduating A&P mechanics with dangerous gaps in their knowledge.
The TWU supports strong training programs which graduate qualified, skilled maintenance workers who will help maintain the safety of the aviation industry. We appreciate the opportunity to comment on this petition and encourage the agency to give these concerns due consideration.
Sincerely,
John Samuelsen
International President