Submits Comments To BLS Saying The Designation Should Be Retained

The AEA has submitted comments to the Bureau of Labor & Statistics, Standard Occupational Classification Policy Committee Members, asking for the committee to retain the detailed occupation "49-2091 Avionics Technician." The AEA's comments were in response to a recent proposal by a small group of aviation special interests led by the Aviation Technician Education Council (ATEC), which among a list of changes, proposed to eliminate the definition, data and career paths of the Avionics Technician.

The AEA's comments opposed the recent proposal on June 4, 2015, by a group of aviation special interests led by the Aviation Technician Education Council (ATEC), which proposed changes to the Standard Occupational Classifications for the aviation industry. The AEA stated in its comments that while there is some logic to the proposal to reinstate some of the changes made during the 1998 SOC Revision regarding the aviation maintenance occupations, the proposed elimination of the detailed occupation "49-2091 Avionics Technicians" is illogical and unsupported.

The Standard Occupational Classification (SOC) system is used by federal statistical agencies to classify workers into occupational categories for the purpose of collecting, calculating or disseminating data. All workers are classified into one of 840 detailed occupations according to their occupational definition. For decades, the occupational information provided by the SOC has provided critical information for the aviation occupations that is widely used for career recruiting throughout the industry.
 
The Aircraft Electronics Association, which represents tens of thousands of avionics technicians working under the certification of an FAA Part 145 repair station, opposes the elimination of this valuable and critical occupational data and requested that the current information regarding 49-2091 Avionics Technicians be retained.
 
Revising the SOC is a multi-year process, during which the interagency SOC Policy Committee (SOCPC) will formulate recommendations for revisions that are submitted to OMB for consideration.

For the 2018 revision, the SOCPC began planning in early 2012. On May 22, 2014, OMB published a Federal Register notice announcing review of the 2010 SOC manual for revision in 2018, and soliciting public comment on the proposed revision of the 2010 SOC Classification Principles; the intention to retain the 2010 SOC Coding Guidelines; the intention to retain the 2010 SOC Major Group Structure; the correction, change, or combination of selected 2010 SOC detailed occupations, and inclusion of new detailed occupations.

AEA said in its comments that while the interested party, led by the Aviation Technical Education Council (ATEC), submitted their recommendation a full 12 months following the closing of the comment period, which closed on July 21, 2014, and should therefore be rejected by both the Bureau of Labor Statistics (BLS) as well as the Office of Management and Budget (OMB), the association is taking an aggressive defense position by also submitting our unsolicited comments in protest to the ATEC recommendation.

The association concurs with the submitters that capturing certification data, as an element of the occupational data, would provide a valuable enhancement to data already collected. However, it is simply unacceptable that ATEC does not recognize the difference between a certificate and an occupation.

FMI: Full Comments