Reforming Annex III (PART-66) and Annex IV (PART-147) of Regulation (EU) No 1321/2014 to meet new and future Aviation maintenance challenges
European Association of Aviation Training and Educational Organisations (EATEO)
1. Introduction / Background
It is evident that according to the forecasts of major aircraft manufacturers as Boeing  and Airbus  as a well as the forecasts of ICAO , the world commercial fleet is expected to more than double over the next 20 years.
According to Boeing Current Markets Outlook 2017-2020 , “Demand in the commercial market is forecast to more than double over the next two decades. To meet this demand, we forecast the number of jet airplanes will nearly double to 47,000 airplanes, at an average annual growth rate of 3.3 percent. To support this fleet growth, Boeing forecasts a need for more than 41,000 new deliveries, valued at over US$6 trillion, for growth and replacement over the next 20 years.”
According to Airbus Global Market Forecast, Growing Horizon 2017/2036 , a demand for 34900 aircrafts is expected by 2036 for replacement of ageing fleet and 60% growth.
At the same time both Boeing  and Airbus  project that more 600 000 technicians will be needed to be trained at the highest levels to be able to serve these aircrafts.
On the other hand, according to studies like , ,  and  is getting obvious that labor shortage in the maintenance technician field is expected. A main reason for this labor shortage is the fact that there is a lack of interest in aviation from younger talent pools . Also, another major issue that arises is the fact that besides labor shortage there is also problem with skill shortage of the new technicians that enter the industry .
The problem becomes more worrisome if we count the fact that according to studies there is also “aviation talent gap problem” . According to this survey “The aviation industry has immediate and long-term needs for employees with a wider scope of knowledge and sophisticated skills and the current complaints made by the industry is that new graduates are not learning or acquiring the important skills required to thrive and survive in the business. The aviation industry is experiencing a fundamental shift due to advancing technology and productivity changes resulting in new needs for relevant and practical skills that were previously non-existent. It is also stated that “Industry needs talent and a resource must be created to offer accelerated learning and qualifications as soon as possible. The traditional ways of supplying talent to the industry are no longer viable.”
In this work, we propose the introduction of an upgraded training and licencing model, based on “Commission Regulation (EU) No 1321/2014 of 26 November 2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks” and especially Annex III (PART-66) and ANNEX IV (PART-147) to Regulation (EU) No 1321/2014, to meet the new aviation challenges.
2. Problem Statement
According to 66.A.25 (a) an applicant for an aircraft maintenance engineer licence, or the addition of a category or subcategory to such a licence, shall demonstrate by examination a level of knowledge in the appropriate subject modules in accordance with the Appendix I to Annex III (Part-66). The examination shall be conducted either by a training organisation appropriately approved in accordance with Annex IV (Part-147) or by the competent authority.
Also, according to 66.A.25 (a), an applicant for an aircraft maintenance licence for category B2 and subcategories B1.1 and B1.3 shall have acquired:
- 5 years of practical maintenance experience on operating aircraft if the applicant has no previous relevant technical training; or
- 3 years of practical maintenance experience on operating aircraft and completion of training considered relevant by the competent authority as a skilled worker, in a technical trade; or
- 2 years of practical maintenance experience on operating aircraft and completion of a basic training course approved in accordance with Annex IV (Part-147)
It is obvious that based on the above, a candidate that wants to become Licensed Aviation Maintenance Engineer (LAME), will need 4-5 years of training to become able to apply for his/her license. Four years will need only in the case that he/she decides to complete the basic training course approved with Annex IV (Part-147) and at least 5 years for all the other cases.
In this paper we challenge the duration and the effectiveness of theoretical and practical training, providing specific solution to update and modernize the existing training system and to become more efficient and attractive to new candidates. Questions that arise are the following:
- Does the theoretical training and the exams system provide to the candidates up to date knowledge that renders them capable to enter the soonest the industry?
- Is the academic background of these modular lessons adequate for this purpose?
- Does the practical training provide to the candidates the necessary skills to enter the industry the soonest?
According to the legislation “engineer licence, or the addition of a category or subcategory to such a licence, shall demonstrate by examination a level of knowledge in the appropriate subject modules in accordance with the Appendix I to Annex III (Part-66). The examination shall be conducted either by a training organisation appropriately approved in accordance with Annex IV (Part-147) or by the competent authority”.
Initially, we consider the cases of paragraphs 2(i) and 2 (ii). In such cases, a candidate with no other education and degree, besides his/her high school degree, can apply for maintenance license for category B2 and subcategories B1.1 and B1.3, by just passing the module exams. In such cases it can be safely claimed that such candidates focus on just studying for passing the exams and not for gaining any knowledge. It is definite that the way that module exams are structured (multiple choice questions and just 4 short essays) are in favor of such tactics. The result of this option is to have mechanics signing “Certificated Release to Service” (CRS), after their Type Rating courses, only with practical experience. According to our opinion, this cannot be an option anymore especially considering the complexity of new aircrafts. There are specific cases that need to be considered and referring to graduates with Academic Degrees in Electrical/ Mechanical Engineering or Aerospace Engineering and other related engineering degrees that would like to receive an EASA Part-66 license. In those cases, due to the inefficiency of DCAs to evaluate the degrees, the graduates need to pass all module exams and prove 5 years of practical training to receive the EASA Part-66 license. This tactic discourages this pool of prominent level graduates to become LAME. For these specific cases, we suggest EASA to assign to an independent committee the evaluation of the Academic Degrees and the decision for exceptions from module exams. This, in comparison with the option that we suggest below for the Practical Maintenance Training, can attract this pool of graduates.
The third option is stated in Paragraph 2 (iii). In this case a candidate attends a full course in an EASA Part-147 approved training school for 2-2.5 years and then with another two years practical experience in an EASA Part-145 Maintenance Training Organization is eligible to apply for its EASA Part-66 license. This route, guarantees that the candidate receives adequate theoretical training and with 2 years of practical training can apply for his/her license.
The question that is normally derived after this discussion is why after almost five years of training, the industry complains that the new engineers are not ready for the industry and that they have to train them again leading to massive resources drain from the companies [6 Survey reveals skills shortage in airline engineering]
According to our opinion, the reason lies on the fact that both theoretical and practical training as they are now structured, are not addressing the new requirements and cannot cope with the demands in numbers and quality of new aviation engineers.
3. Specific Problems and Proposed Solution(s)
a. Basic Knowledge
Concerning the basic knowledge, we suggest a revision of the EASA Part-147 system in a way that will become more effective and will improve the quality of training in a way that the new graduates will be ready for the industry.
The first step is the revision of training material of the subject modules. We suggest the following system:
(1)Removal of subject Module 1 (Mathematics) and subject Module 2 (Physics). These two modules along with the Technical English should be a prerequisite for anyone that wants to join Part-147 training schools. Teaching of basic mathematics and basic physics should not be a task for an aviation training school. It is necessary that everyone that eventually wants to become aviation engineer to already possess this very basic knowledge, along with the technical English. The proper knowledge of basic Mathematics and Physics should be verified through a dedicated exam (admission exam). For the knowledge of the English language we suggest that is necessary to establish a minimum level for technical English (for example as it is established for pilots - ICAO level 4).
(2)Revision of the training material of subject Module 6 (Material and Hardware) and Module 7A (maintenance practices) to meet the demands of the modern aircrafts and their technology improvements. For example, in Module 6 there are sub-modules that refer to wooden structures (6.3.2) and fabric covering (6.3.3), while in Module 7 the training material briefly covers the computer-based techniques (uploading- downloading software from/to the aircraft).
(3)Revision and extension of the training material covered in Subject Module 9 (Human Factors). We consider Human Factors as one of the most critical aspects in aviation maintenance. The training material and the teaching hours in the current system are inadequate and they must be enhanced to also include lessons learned from aviation accidents that has as major cause the human performance.
(4)Significant reduction in training material of Modules 11A and 13. We suggest these modules to focus only the basic principles of operation of the various aircraft systems and not in details. An approach like this will reduce the teaching hours and simultaneously will improve the knowledge on the operation/functions of the aircraft systems.
Next, we suggest the following measures that will render all the EASA Part-147 training schools, capable to provide the same level of knowledge and eliminate any fraud cases.
(1)Common/Central Curriculum (training material): We suggest the development of a center that will be responsible to deliver to all EASA Part-147 Training Schools the basic training material. All Part-147 organization will be obliged to teach at least this material and if they want the can add anything else in excess.
(2)Common online question bank: A mandatory measure that will eliminate the fraud cases. The question bank should be kept somewhere centrally by EASA and continually updated with the removal and addition of new questions. The candidates will be examined only on questions from the common training material and those questions will be selected randomly for each candidate in any exam. The development of dedicated software that is able to generate a different, unique paper for each candidate is a measure that will enhance the reliability of the exams. Paper based exams should be allowed only for the essays.
The combination of these two measures will force the candidates to choose the training center that provides the best education and not the training center that has the highest passing rate. .
Also, a measure like this, will allow EASA to easily update the training materials, in a global way and adapt rabidly to any new requirements due to technology or any other improvements. We are confident that a measure like this will immediately rise-up the standards of EASA Part-147 organizations. We also consider the involvement of Academic Institutions as very important. This step besides the obvious benefits it can be proven as crucial in bridging the gap between academia and industry because and bring these two worlds together.
Furthermore, to attract higher level students, we suggest the incorporation of the European Credit Transfer and Accumulation System (ECTS) to the EASA Part-147 organizations. The incorporation of this system, will allow the candidates to continue their studies in European Academic Institutions and receive Bachelor of Science (BSc) in fields related to the aerospace and aviation maintenance with a limited number of extra classes. This option also gives the students that started the EASA Part-147 basic training and decided for any reason to aboard it, to continue their studies in other related field without wasting the time and money they invested in the Part-147 schools.
b. Practical maintenance experience
Practical maintenance experience is according to our opinion the biggest obstacle in attracting new candidates and the biggest obstacle to attract technicians from the other industries into the aviation industry.
The problem lies mostly on the fact the new technicians need to seek for Part-145 organizations to allow them to perform their training and fill their practical training log-books with signatures to become ready for applying in DCAs for the licence. Since Part-145 organizations perform maintenance in functional aeroplanes, they are almost always under the pressure to deliver the aircrafts “released to flight” and they trend to ignore the new candidates especially when they are not employees of their companies. Generally, in several cases candidates are assigned minor tasks, as cleaning of parts, panel removal installation and very basic jobs that do not improve the technical skills of the new candidates. As a result, when the new candidates receive their licence, they do not have the necessary skills to enter the industry and companies need to invest resources to bring them to an acceptable level. We believe that the major issue with this tactic arises from the fact that Part-145 maintenance organizations are not training organizations and as it is expected they do not have structured method to educate the new candidates.
It is also obvious that the uncertainty of finding a suitable Part-145, as an individual, to perform the practical maintenance training is a major obstacle in attracting new graduates and especially the high-level students.
The proposed solution is to perform the practical maintenance experience in EASA Part-147 organization. The idea is to create a “training Part-145 organization”, inside the EASA Part-147 organization. In such system, each Part-147 organization that performs full basic course should have a functional aircraft of any type (e.g. CESSNA 150, 172, Diamond etc.). In combination with the practical experience required in modules the students should acquire the following knowledge:
-Proper use of basic tools like torque wrenches, multimeters, bonding testers, compressed air tools, drilling, riveting tools etc. on the aircraft using the technical publication of the manufacturer and the standard practice manuals. Proper and efficient use of these tools is some of the basic skills that a new engineer should have and needs substantial practice before acquiring these skills. It is obvious that during this practice mistakes may happen, and equipment can be damaged, which is acceptable in a demo aircraft in comparison with a functional aircraft in Part-145 organization. Also, in trainings of this style, the instructor can focus on the absolute safety measures that should be taken, both for the personnel and the equipment, fact which is not always the case in real maintenance environment.
-Dedicated training in novel skills like software updates, computer bases fault finding etc
-Understanding and use of Maintenance Manuals of all kind. This is one of the major problems that new engineers face when they join Part-145 organizations. In the proposed system, the practical use of maintenance manuals on a functional demo airplane as a part of their training can render the students capable to fully understand the procedure without time pressure. Also, fault solving procedures can enhance this process
-Understanding and implementation of Airworthiness Directives, Service bulletins, Service letters etc. The students can go through all the procedure and perform these tasks on the airplane
-Practical understanding of legislation. Understanding of how storage works, the procedure of receiving functional parts and delivering the unserviceable parts to the storage, issuing of Certificate Release to Service (CRS), etc.
-Focus in human factors in practice, assessing attitude, cooperation with other team members, shift handling etc.
-Training related to effective jobs/task on the aircraft (for example: changing a propeller, weight and balance, NDT procedures, etc) to be done in the following two ways :
- a part using special simulators (simulating real actions as it is done for the pilots)
- and the other part (which cannot be done in simulators) to be done on a functional aircraft, in partnership with an approved Part- 145 Maintenance Organization.
-Assessment of each student in practice by an external assessor.
4. Future Direction / Long-Term Focus/ Conclusions
As we discuss, above a new system in Aviation Maintenance Training is required to cope with the new developments and demand of well trained and well-educated Aviation Engineers in the forthcoming years. The suggestion of EATEO is the evolvement of the existing system that served the Aviation Industry in a very efficient way during the previous years. The suggested system addresses both the Basic Knowledge as well as the Practical Maintenance Training.
The aim is to reduce the average time for a student to receive a basic license (B1 or B2) in three years.
The two years will be devoted to basic knowledge training, which needs to be restructured with academic support and allocation of ECTS to the modules, and third year will be devoted to practical training. The idea of implementing a “training Part-145” inside the Part-147 organization will allow the students to finish the practical training within one year and learn correctly how the system should work and not receiving knowledge just based on the experience of any individual engineer. An established partnership between the Part-147 Organization and an approved EASA Part-145 Maintenance Organization will train the candidates on the tasks in functional aircrafts, but in a structured and effective way. The fact that according to 66.A.45(c) “the endorsement of the first aircraft type rating within a given category/sub-category requires satisfactory completion of the corresponding On the Job Training, as described in Appendix III to Annex III (Part-66)” and since the decision of whether an engineer can sign a CRS is according to the policy of the Part-145 organization, safeguards the system and allows only to engineers with real knowledge to sign a CRS.
We strongly believe that this system can contribute in the short-term and long- term recruitment of well-educated engineers capable to work on modern aircrafts, fact that will significantly improve flight safety.
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