SUPPORTING STATEMENT
OMB -2120-XXXX
Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers
Justification
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
Title 49 U.S.C., Section 44702 empowers and requires the Secretary of Transportation to issue operating certificates and to establish minimum safety standards for the operation of air carriers and those to whom such certificates are issued. Also, Title 49 U.S.C., Section 44701 empowers and requires the Administrator of the Federal Aviation Administration (FAA) to prescribe standards applicable to the accomplishment of the mission of the FAA.
This project is in direct support of the Department of Transportation’s Strategic Plan – Strategic Goal – SAFETY; i.e., to promote the public health and safety by working toward the elimination of transportation-related deaths and injuries.
This project also directly supports the following initiatives under the FAA’s Corporate Project, Safer Skies:
a. AFS Strategic Plan – Goal 1: Evolve to a Systems Approach for Safety Oversight.
b. AFS Business Plan Initiative 2.9: Improve the Requirements Process.
c. AFS Strategic Plan – Goal 4: Promote Positive, Responsive, and Focused Customer Relations.
d. AFS Business Plan Initiative 2.13: Continue Efforts Associated with Safer Skies – Commercial Aviation.
2. Indicate how, by whom, and for what purpose the information is to be used.
This request for clearance reflects requirements necessary under Title 14 CFR parts 61, 63, 65, 91, 119, 121, 135, and 142, to ensure safety-of-flight by making certain that complete and adequate training, testing, checking, and experience is obtained and maintained by those who operate under these parts of the regulation and that the use of flight simulation is utilized to its maximum practical extent in achieving these goals. The FAA will use the information it collects and reviews to ensure compliance and adherence to regulations and, where necessary, to take enforcement action on violators of the regulations.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.
In accordance with the Government Paperwork Elimination Act (GPEA), the FAA will not only allow and accept, but encourages the use of automation and electronic media for the gathering, storage, presentation, review, and transmission of all requests, records, reports, tests, or statements required by this proposed rule with the provision that such automation or electronic media has adequate provision for security (i.e., that such submissions may not be altered after review and acceptance by the FAA) and that the systems or applications are compatible with the systems or applications used by the FAA. One Hundred (100) % of the proposed rule is available electronically and includes hyper-linking of table-of-content entries directly to the appropriate section of the proposed rule and to associated preamble language for further explanation. The FAA is working to insure that the process maintains this 100% availability to respondents throughout the world.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in 2 above.
We have reviewed other FAA public-use reports and find no duplication. Also, the FAA knows of no other agency collecting the same information. The information sought is peculiar to the training and qualification requirements for certificate holders operating under the provisions of 14CFR, part 121. The information necessary is available from that certificate holder only, and is not available from any other source.
5. If the collection of information has a significant impact on a substantial number of small businesses or other small entities (item 5 of OMB Form 83-I), describe the methods used to minimize burden.
The FAA believes that this rule will not impact a substantial number of small businesses or other small entities; however, the material published in conjunction with this rule is informative and explanatory with regards to the requirements, and an applicant for a certificate will be guided through the administrative requirements by the local principal operations inspector or training center program manager and, if necessary, by a representatives of the Washington headquarters staff regarding training, testing, checking, or experience requirements for crew members or dispatchers.
6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
The reason for information collection is for original certification and review and approval of initial and continuing qualification of dispatcher and crew member training, evaluation, and flight experience requirements. If the certificate applicant does not apply initially, evaluation and approval of the applicable training programs and subsequent qualification will not occur. If the certificate holder does not continue to provide this information, the FAA will not be able to determine if the certificate holder continues to administer the program according to the approval and will not be able to determine if the training program continues to produce dispatchers and crew members who meet the required standards for serving in operations conducted under 14 CFR part 121.
7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with 5 CFR 1320.5(d)(2)(i)-(viii).
This collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2)(i)-(viii).
8. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any) and on the data elements to be recorded, disclosed, or reported.
This proposal represents, in major part, a continuation of the requirements currently levied by the FAA and an inclusion of sound training and evaluation practices developed over the preceding 20 years regarding the way and the frequency with which this training and evaluation should be conducted. This proposal was published in the Federal Register on January 12, 2009, vol. 74, no. 7, pages 1280-1328, and encouraged public comment to be made. All comments received will be reviewed and evaluated as potential reasoning to modify the proposal prior to publication of a final rule.
9. Explain any decision to provide any payment of gift to respondents, other than remuneration of contractors or grantees.
There are no monetary considerations for this collection of information.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The respondents have been given no assurance of confidentiality.
11. Provide additional justification for any questions of a sensitive nature such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
There are no questions of a sensitive nature.
12. Provide estimates of the hour burden for the collection of information.
a. Proposed subparts BB and CC set out prerequisites and levies requirements that must be met by certificate holders operating in accordance with part 121 and by those individuals who serve in given capacities for those certificate holders. The estimates for hours and costs are broken down by sections of the proposed rule, below, including a section-by-section calculation. For a cumulative estimate of the hours and cost burden see the chart at the end of this section. Computations involving salaries, including fringe benefits estimated at 23.45%,1 are based on the following:
Flight Attendant Instructor $38.21 per hour.
Check Flight Attendant $38.21 per hour.
Flight crewmember manager $89.03 per hour.
Flight Attendant Manager $43.33 per hour.
Instructor Pilot $98.05 per hour.
Flight Engineer Instructor $37.06 per hour.
Dispatch Manager $41.55 per hour.
Dispatch Instructor $37.39 per hour.
Clerk/Secretary $16.93 per hour.
Programmer $37.19 per hour.
Technical Writer $29.95 per hour.
b. Proposed changes, dealing with manuals for operations in accordance with part 121 (§ 121.133 Preparation, and § 121.135 Contents) will require revisions to the manual requirements in § 121.133. The manual must include the instructions and information necessary to allow the crewmember or aircraft dispatcher to perform their required safety related duties and responsibilities. The manual, and any changes, must be approved by the Administrator and contain the following sections:
(1) A Flight Attendant Operating Manual (FAOM) for all of the aircraft types operated by the certificate holder in operations under this part.
(2) A Flight Crewmember Operating Manual (FCOM) for each aircraft type operated by the certificate holder in operations under this part.
(3) An Aircraft Dispatcher Procedures Manual (ADPM) for all types of operations and aircraft types, if required.
The FAA estimates that, for a certificate holder operating under part 121 with 1 aircraft type, on average, 35% of the content of these manuals (including the FAOM/FCOM/ADPM) will require revision. For the FCOM, this constitutes, on average, 75 pages for each aircraft type and, as a result, on average, 3 modules of instruction will be newly generated or revised for each aircraft type. For the FAOM and the ADPM, on average, 11 pages for each manual for each aircraft type will be revised and, as a result, on average, 3 modules of instruction will be newly generated or revised for each aircraft type. The FAA estimates that a part 119 certificate holder, operating in accordance with part 121, operates an average of 3 aircraft types; and there are 118 air carriers.
Calculations:
■ For FCOM:
Air Carriers |
118 |
Technical Writers |
3 |
Time cost for tech. writer |
$29.95 |
Hours per tech. writer |
40 |
Aircraft Types |
3 |
First Year Cost
Dollars |
$1,272,212 |
Hours |
42,480.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$1,272,212 |
Hours |
42,480.0 |
Average per year
Dollars |
$127,221 |
Hours |
4248.0 |
■ For FAOM and ADPM:
Air Carriers |
118 |
Technical Writers |
2 |
Time cost for tech. writer |
$29.95 |
Hours per tech. writer |
20 |
Aircraft Types |
3 |
First Year Cost
Dollars |
$424,071 |
Hours |
14,160.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$424,071 |
Hours |
14,160.0 |
Average per year
Dollars |
$42,407 |
Hours |
1416.0 |
c. § 121.1413 Aircraft dispatcher: Training and evaluation.
The FAA recognizes this is an increase in the record keeping requirements as this proposal requires operating familiarization for flag operations every 24 months for dispatchers qualified to dispatch in flag operations. The current requirement is to accomplish operating familiarization domestically. The FAA estimates documentation for an additional 320 dispatchers taking 320 hours total (industry wide) to update all the records. The Dispatch Manager would update the records.
Calculations:
Dispatch Manager |
1 |
Time cost for Dispatch Manager |
$41.55 |
Hours per Dispatch Manager |
320.0 |
First Year Cost
Dollars |
$13,295 |
Hours |
320.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$13,295 |
Hours |
320.0 |
Average per year
Dollars |
$1,329 |
Hours |
32.0 |
d. § 121.1417 Aircraft dispatcher: Supervised operating experience.
The FAA recognizes this is an increase in the record keeping requirements, as this proposal requires a minimum of 8-hours of Supervised Operating Experience for domestic operations and per flag area of operations. Currently, there is no requirement to provide Supervised Operating Experience, but it is industry practice is to provide some On-Job-Training to the dispatchers. The operators surveyed currently meet or exceed this requirement. No additional documentation will be needed, and so, there would be no additional paperwork burden.
e. § 121.1421 Dispatcher instructor and check dispatcher: Eligibility, training, and evaluation.
The FAA recognizes this is an increase in the record keeping requirements, as this proposal requires the use of a current and qualified dispatcher to instruct specified training categories. Currently this is not a requirement. The FAA estimates that only 1 operator does not use a current and qualified dispatcher instructor. The FAA estimates 2-hours to update the record and the Dispatch Manager would accomplish the record keeping.
Calculations:
Air Carriers |
1 |
Dispatch Manager |
1 |
Time cost for Dispatch Manager |
$41.55 |
Hours per Dispatch Manager |
2 |
First Year Cost
Dollars |
$83 |
Hours |
2 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$83 |
Hours |
2 |
Average per year
Dollars |
$8 |
Hours |
0.2 |
f. § 121.1433 Training Program: General curriculum by aircraft type and operation.
1. The FAA recognizes this is an increase in the record keeping requirements, as this proposal requires a Letter of Authorization from the FAA for instructors and check dispatchers. This information will have to be provided to the FAA from the operator. It is currently industry practice to maintain record keeping on Air Transportation Supervisors, which is the current term for Check Dispatchers. No additional record keeping will be required from the operator.
2. The following addresses the development of the required program changes:
(a) Existing Training review, revision, printing, and collation:
Requires 1 Dispatch Instructor, 1 hour review of each of 5 existing training curriculum, (Basic Indoctrination, Group I and Group II Initial Equipment, Transition and Recurrent,), equals --for 71 affected air carriers.
Calculations:
Air Carriers |
71 |
Dispatch Instructor |
1 |
Time cost for Dispatch Instructor |
$37.39 |
Hours per training curriculum |
1 |
Number of training curricula |
5 |
First Year Cost
Dollars |
$13,273 |
Hours |
355.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$13,273 |
Hours |
355.0 |
Average per year
Dollars |
$1,327 |
Hours |
35.5 |
(b) New Training program development, printing, and collation.
(i) Requires 1 Dispatch Instructor, 20 hours for development of each of 3 new training category (General Knowledge and Skills for Initial, Recurrent, and Requalification training categories), for 71 affected air carriers.
Calculations:
Air Carriers |
71 |
Dispatch Instructor |
1 |
Time cost for Dispatch Instructor |
$37.39 |
Hours per training category |
20 |
Number of training categories |
3 |
First Year Cost
Dollars |
$159,281 |
Hours |
4260.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$159,281 |
Hours |
4260.0 |
Average per year
Dollars |
$15,928 |
Hours |
426.0 |
(ii) Requires 1 Dispatch Instructor, 20 hours for development of each of 3 new training category (Basic Aircraft and Aircraft Type for Initial, Recurrent, Requalification training categories), for 71 affected air carriers.
Calculations:
Air Carriers |
71 |
Dispatch Instructor |
1 |
Time cost for Dispatch Instructor |
$37.39 |
Hours per training category |
20 |
Number of training categories |
3 |
First Year Cost
Dollars |
$159,281 |
Hours |
4260.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$159,281 |
Hours |
4260.0 |
Average per year
Dollars |
$15,928 |
Hours |
426.0 |
(iii) Requires 1 Dispatch Instructor 10 hours each for development of each evaluation and performance standard for Initial, Transition, Recurrent and Requalificiation, for 71 affected air carriers.
Calculations:
Air Carriers |
71 |
Dispatch Instructor |
1 |
Time cost for Dispatch Instructor |
$37.39 |
Hours per evaluation |
10 |
Number of evaluation and performance standards |
4 |
First Year Cost
Dollars |
$106,188 |
Hours |
2840.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$106,188 |
Hours |
2840.0 |
Average per year
Dollars |
$10,619 |
Hours |
284.0 |
(iv) Dispatch Instructors, Check Dispatchers, and Dispatch Program Designee: Requires 1 Dispatch Instructor, 2 hours multiplied by 8 modules, for 71 affected air carriers.
Calculations:
Air Carriers |
71 |
Dispatch Instructor |
1 |
Time cost for Dispatch Instructor |
$37.39 |
Hours per module |
2 |
Number of modules |
8 |
First Year Cost
Dollars |
$42,475 |
Hours |
1136.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$42,475 |
Hours |
1136.0 |
Average per year
Dollars |
$4,248 |
Hours |
113.6 |
g. § 121.1441 Training program: Continuous analysis process (see § 121.1353)
h. Training Category requirements:
1. § 121.1457 Training Category requirements: Dispatcher instructor initial and recurrent training. The FAA recognizes this is an increase in the record keeping requirements, as this proposal requires the initial and recurrent training for dispatch instructors. Currently this is not a requirement. Out of the operators surveyed, 5 do not currently comply. The FAA estimates 80 hours to update the records and the Dispatch Manager would update the records.
Calculations:
Air Carriers |
5 |
Dispatch manager |
1 |
Time cost for dispatch manager |
$41.55 |
Time per dispatch manager |
80 |
First Year Cost
Dollars |
$16,618 |
Hours |
400.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$16,618 |
Hours |
400.0 |
Average per year
Dollars |
$1,662 |
Hours |
40.0 |
2. § 121.1459 Training Category requirements: Check dispatcher initial and recurrent training. The FAA recognizes this is an increase in the record keeping requirements, as this proposal requires the initial and recurrent training for check dispatchers. Currently this is not a requirement. Out of the operators surveyed, 5 do not currently comply. The FAA estimates 80 hours (multiplied by 5) to update the records and the Training Manager would update the records.
Calculations:
Air Carriers |
5 |
Dispatch manager |
1 |
Time cost for dispatch manager |
$41.55 |
Time per dispatch manager |
80 |
First Year Cost
Dollars |
$16,618 |
Hours |
400.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$16,618 |
Hours |
400.0 |
Average per year
Dollars |
$1,662 |
Hours |
40.0 |
i. §§ 121.1201 through 121.1323. While requiring the gathering and maintaining of information and, in certain cases, the reporting of some of that information to the FAA, these sections require no additional burdens on the certificate holders beyond what is currently required by rule or that which is currently borne by certificate holders in regular practice. Exceptions to this are the following:
1. § 121.1305: Flight attendant: Aircraft operating experience.
(a) The FAA recognizes that this in an increase in the record keeping requirements as this proposal requires operating experience on each aircraft type on which the flight attendant will serve, where the current requirement is that operating experience is acquired and documented only once for an aircraft group. Requires a Check Flight Attendant an additional 0.15 hour of time to complete the necessary operating experience documentation for each Flight Attendant (F/A). The FAA estimates 31,987 F/As are affected.
Calculations:
Check Flight Attendant |
1 |
Cost for Check Flight Attendant |
$38.21 |
Initial time per flight attendant |
0.15 |
Flight attendants affected |
31,987 |
Aircraft types |
2 |
First Year Cost
Dollars |
$366,662 |
Hours |
9595.98 |
Subsequent Years – per year costs
Dollars |
$366,662 |
Hours |
9595.98 |
Total over 10 years
Dollars |
$3,666,624 |
Hours |
95,959.8 |
Average per year
Dollars |
$366,662 |
Hours |
9595.98 |
(b) The FAA estimates that the time required for a clerk to properly enter the data or file the report for the additional operating experience documentation is 0.1 hour per qualifying flight attendant. The FAA also estimates that there are 106,622 F/As currently serving.
Calculations:
Clerk/secretary |
1 |
Cost for clerk/secretary |
$16.93 |
Time cost per flight attendant |
0.1 |
Flight attendants currently serving |
106,622 |
First Year Cost
Dollars |
$180,541 |
Hours |
10,662.2 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$180,541 |
Hours |
10662.2 |
Average per year
Dollars |
$18,054 |
Hours |
1066.22 |
2. § 121.1307: Flight attendant: Recent experience.
The FAA recognizes that this is an increase in the record keeping requirements for a “look-back” capability for F/As. The FAA believes that current certificate holders use an automated record keeping system for managing schedules and payroll. The FAA believes this requirement may be satisfied with a modification of this system to confirm recency of experience. The FAA estimates that such a modification would take an experienced programmer 40 hours to modify existing programs to provide the necessary information, for 71 affected air carriers.
Calculations:
Air Carriers |
71 |
Programmers |
1 |
Time cost for programmer |
$37.19 |
Time for programmer |
40 |
First Year Cost
Dollars |
$105,618 |
Hours |
2840.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$105,618 |
Hours |
2840.0 |
Average per year
Dollars |
$10,562 |
Hours |
284.0 |
j. § 121.1331: Training program: General. This part of the paperwork package describes the requirements for training programs for Pilot, Instructor Pilot, Check Pilot, APD, F/E, F/E Instructors, Check F/E, F/A, F/A Instructors, Check F/A, and Persons authorized to administer F/A proficiency tests, and deals with the individual requirements for the structure and content of each distinct training program, including the specific requirements for the review (and where required, modification and re-structure of a particular training program), development, construction, printing, and collation of the required training programs. The overall commitment of time and the documents and information gathered or generated are addressed here. The single exception to this is § 121.1353: Training program: Continuous analysis process, addressed in paragraph k(1).
(1) Existing Training module review, revision, printing, and collation, per certificate holder:
(a) Pilots: (includes PIC, SIC, Instructor Pilot, Check Pilot, and APD):
(i) Requires 1 Instructor Pilot, 0.4 hours each for each existing module reviewed, multiplied by 15 modules for each aircraft type, multiplied by 3 aircraft types and 118 air carriers.
Calculations:
Air Carriers |
118 |
Instructor Pilot |
1 |
Time cost for instructor pilot |
$98.05 |
Time per existing module |
0.4 |
Modules |
15 |
Aircraft types |
3 |
First Year Cost
Dollars |
$208,253 |
Hours |
2124.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$208,253 |
Hours |
2124.0 |
Average per year
Dollars |
$20,825 |
Hours |
212.5 |
(ii) Requires 1 Instructor Pilot; 10 hours for each additional new module developed, multiplied by 3 new modules per aircraft type, multiplied by 3 aircraft types, and 118 air carriers.
Calculations:
Air Carriers |
118 |
Instructor Pilot |
1 |
Time cost for instructor pilot |
$98.05 |
Time per additional new module |
10 |
Modules |
3 |
Aircraft types |
3 |
First Year Cost
Dollars |
$1,041,266 |
Hours |
10620.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$1,041,266 |
Hours |
10620.0 |
Average per year
Dollars |
$104,127 |
Hours |
1062.0 |
(b) Flight Engineers: (includes F/E, F/E Instructors, and Check F/E):
(i) Requires 1 F/E Instructor, 2 hours each for each existing module reviewed, multiplied by 1 modules for each aircraft type, multiplied by 1 aircraft type requiring a F/E for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Engineer Instructor |
1 |
Time cost for F/E instructor |
$37.06 |
Time per existing module |
2 |
Modules |
1 |
Aircraft types |
1 |
First Year Cost
Dollars |
$5,263 |
Hours |
142.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$5,263 |
Hours |
142.0 |
Average per year
Dollars |
$526 |
Hours |
14.2 |
(ii) Requires 1 F/E Instructor, 5 hours each for each additional new module, multiplied by 3 new modules for each aircraft type, multiplied by 1 aircraft type requiring a F/E for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Engineer Instructor |
1 |
Time cost for F/E instructor |
$37.06 |
Time per additional new module |
5 |
Modules |
3 |
Aircraft types |
1 |
First Year Cost
Dollars |
$39,469 |
Hours |
1065.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$39,469 |
Hours |
1065.0 |
Average per year
Dollars |
$3,947 |
Hours |
106.5 |
(c) Flight Attendants:
(i) For review and modification of existing training modules.
A. Requires 1 F/A Instructor, 1 hour for review of each existing module, multiplied by 15 modules for each aircraft type, multiplied by 3 aircraft types for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Attendant Instructor |
1 |
Time cost for F/A instructor |
$38.21 |
Time per existing module |
1 |
Modules |
15 |
Aircraft types |
3 |
First Year Cost
Dollars |
$122,081 |
Hours |
3195.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$122,081 |
Hours |
3195.0 |
Average per year
Dollars |
$12,208 |
Hours |
319.5 |
B. Requires 1 F/A Instructor 2 hours each for review of each existing emergency training module (3 modules) for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Attendant Instructor |
1 |
Time cost for F/A instructor |
$38.21 |
Time per existing emergency training module |
2 |
Modules |
3 |
First Year Cost
Dollars |
$16,277 |
Hours |
426.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$16,277 |
Hours |
426.0 |
Average per year
Dollars |
$1,628 |
Hours |
42.6 |
C. Requires 1 F/A Instructor 1 hour for review of each existing basic indoctrination (3) modules, for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Attendant Instructor |
1 |
Time cost for F/A instructor |
$38.21 |
Time per existing basic indoctrination |
1 |
Modules |
3 |
First Year Cost
Dollars |
$8,139 |
Hours |
213.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$8,139 |
Hours |
213.0 |
Average per year
Dollars |
$814 |
Hours |
21.3 |
(ii) For development of new, additional training modules:
A. Requires 2 F/A Instructors, 20 hours each for development of each new airplane specific module, multiplied by 2 modules for each aircraft type, multiplied by 3 aircraft types, for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Attendant Instructor |
2 |
Time cost for F/A instructor |
$38.21 |
Time per new airplane specific module |
20 |
Modules |
2 |
Aircraft Types |
3 |
First Year Cost
Dollars |
$651,098 |
Hours |
17,040.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$651,098 |
Hours |
17,040.0 |
Average per year
Dollars |
$65,110 |
Hours |
1704.0 |
B. Requires 2 F/A Instructors 20 hours each for development of each new emergency training module (5 modules), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Attendant Instructor |
2 |
Time cost for F/A instructor |
$38.21 |
Time per new emergency training module |
20 |
Modules |
5 |
First Year Cost
Dollars |
$542,582 |
Hours |
14,200.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$542,582 |
Hours |
14,200.0 |
Average per year
Dollars |
$54,258 |
Hours |
1420.0 |
C. Requires 2 F/A Instructors 20 hours each for development of each new basic indoctrination module (1 modules), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Flight Attendant Instructor |
2 |
Time cost for F/A instructor |
$38.21 |
Time per new basic indoctrination module |
20 |
Modules |
1 |
First Year Cost
Dollars |
$108,516 |
Hours |
2840.0 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$108,516 |
Hours |
2840.0 |
Average per year
Dollars |
$10,852 |
Hours |
284.0 |
(d) Requires 1 Clerk/Secretary 0.5 hours to generate cover/transmittal letter and send to FAA.
Calculations:
Air Carriers |
71 |
Time per clerk/secretary |
0.5 |
Time cost for clerk/secretary |
$16.93 |
First Year Cost
Dollars |
$601 |
Hours |
35.5 |
Subsequent Years – per year costs
Dollars |
$0 |
Hours |
0.0 |
Total over 10 years
Dollars |
$601 |
Hours |
35.5 |
Average per year
Dollars |
$60 |
Hours |
3.55 |
k. §§ 121.1333 through 121.1391. These sections deal with the individual requirements for the structure and content of each distinct training program, including the specific requirements for the development or the review and modification (where required), construction, printing, and collation of the new training programs or the re-structure of existing training programs. The inclusive commitment of time and the documents and information gathered or generated are addressed in paragraph j, above, with the following exception:
1. § 121.1353: Training program: Continuous analysis process. Air carriers would be required to measure and monitor the outcome of the training program. The cost of the Continuous analysis process is divided into three parts: flight crewmembers, flight attendants, and dispatchers. To calculate the flight crewmember part, the following assumptions were used, paralleling those in the regulatory evaluation:
Calculations:
Air Carriers |
118 |
Flight crewmember manager |
1 |
Time cost for crewmember manager |
$89.03 |
Time per flight crewmember manager |
8 |
Recurrent time per flight crewmember manager |
2 |
First Year Cost
Dollars |
$84,041 |
Hours |
944.0 |
Subsequent Years – per year costs
Dollars |
$21,010 |
Hours |
236.0 |
Total over 10 years
Dollars |
$273,133 |
Hours |
3068.0 |
Average per year
Dollars |
$27,313 |
Hours |
306.8 |
Calculations:
Air Carriers |
71 |
Flight attendant manager |
1 |
Time cost for F/A manager |
$43.33 |
Time per F/A manager |
8 |
Recurrent time per F/A manager |
2 |
First Year Cost
Dollars |
$24,609 |
Hours |
568.0 |
Subsequent Years – per year costs
Dollars |
$6,152 |
Hours |
142.0 |
Total over 10 years
Dollars |
$79,980 |
Hours |
1846.0 |
Average per year
Dollars |
$7,998 |
Hours |
184.6 |
Calculations:
Air Carriers |
71 |
Dispatcher manager |
1 |
Time cost for Dispatcher manager |
$41.55 |
Time per Dispatcher manager |
8 |
Recurrent time per Dispatcher manager |
2 |
First Year Cost
Dollars |
$23,598 |
Hours |
568.0 |
Subsequent Years – per year costs
Dollars |
$5,899 |
Hours |
142.0 |
Total over 10 years
Dollars |
$76,693 |
Hours |
1846.0 |
Average per year
Dollars |
$7,669 |
Hours |
184.6 |
Summary of time and costs (10-year) addressed in question 12:
Section |
Cost |
Hours |
121.133/121.135: |
|
|
Flight Crew Operating Manual |
$1,272,212 |
42,480.0 |
Crew Operating Manual |
$424,071 |
14,160.0 |
121.1413 |
$13,295 |
320.0 |
121.1421 |
$83 |
2.0 |
121.1433 |
|
|
(a)(i) |
$13,273 |
355.0 |
(b)(i) |
$159,281 |
4,260.0 |
(b)(ii) |
$159,281 |
4,260.0 |
(b)(iii) |
$106,188 |
2,840.0 |
(b)(iv) |
$42,475 |
1,136.0 |
121.1457 |
$16,618 |
400.0 |
121.1459 |
$16,618 |
400.0 |
121.1305 |
|
|
a |
$3,666,624 |
95,959.8 |
b |
$180,541 |
10,662.2 |
121.1307 |
$105,618 |
2,840.0 |
121.1331 |
|
|
(a)(i) |
$208,253 |
2124.0 |
(a)(ii) |
$1,041,266 |
10620.0 |
(b)(i) |
$5,263 |
142.0 |
(b)(ii) |
$39,469 |
1065.0 |
(c)(i)A |
$122,081 |
3195.0 |
(c)(i)B |
$16,277 |
426.0 |
(c)(i)C |
$8,139 |
213.0 |
(c)(ii)A |
$651,098 |
17,040.0 |
(c)(ii)B |
$542,582 |
14,200.0 |
(c)(ii)C |
$108,516 |
2,840.0 |
d |
$601 |
35.5 |
121.1353 |
|
|
Pilots and Flight Engineers |
$273,133 |
3068.0 |
Flight Attendants |
$79,980 |
1,846.0 |
Dispatchers |
$76,963 |
1,846.0 |
|
|
|
TOTAL |
$9,349,531 |
238,735.5 |
AVERAGE PER YEAR |
$934,953.10 |
23,873.55 |
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There are no additional costs not already included in questions 12.
14. Provide estimates of annualized cost to the Federal Government.
The estimates for hours and costs are broken down by sections of the proposed rule, below, including a section-by-section calculation. For a cumulative estimate of the hours and cost burden, see the chart at the end of this section. Computations involving salaries [including fringe benefits estimated at 32.45%] are based on the following positions distributed all over the United States:
FAA Principal Operations Inspector, GS14 $61.50 per hour.
FAA Operations Inspector, Pilot, GS13 $52.04 per hour.
FAA Operations Inspector, Dispatcher, GS13 $52.04 per hour.
FAA Cabin Safety Inspector, GS13 $52.04 per hour.
FAA Clerk/Secretary, GS07 $24.67 per hour.
b. Proposed changes, dealing with manuals for operations in accordance with part 121 (§ 121.133 Preparation, and § 121.135 Contents) will require revisions to the manual requirements in § 121.133. The manual must include the instructions and information necessary to allow the crewmember or aircraft dispatcher to perform their required safety related duties and responsibilities. The manual, and any changes, must be approved by the Administrator and contain the following sections:
(1) A Flight Attendant Operating Manual (FAOM) for all of the aircraft types operated by the certificate holder in operations under this part.
(2) A Flight Crewmember Operating Manual (FCOM) for each aircraft type operated by the certificate holder in operations under this part.
(3) An Aircraft Dispatcher Procedures Manual (ADPM) for all types of operations and aircraft types, if required.
The FAA estimates that, for a certificate holder operating under part 121 with 1 aircraft type, on average, 35% of the content of these manuals (including the FAOM/FCOM/ADPM) will require revision. For the FCOM, this constitutes, on average, 75 pages for each aircraft type and, for the FAOM and the ADPM, on average, 11 pages for each manual for each aircraft type will be revised. The FAA estimates that a part 119 certificate holder, operating in accordance with part 121, operates an average of 3 aircraft types. Review of the proposed changes will be required by the FAA and will require 1) an assigned Operations Inspector, Pilot; 2) a Cabin Safety Inspector (CSI); and 3) a Operations Inspector, Dispatcher, qualified to administer Dispatch Competency Checks. The final review and acceptance of these manual revisions will be made by the POI and will require 1 day for review.
Calculations:
■ For FCOM:
Air Carriers |
118 |
POI |
1 |
Operations Inspector, Pilot |
1 |
Operations Inspector, Dispatcher |
1 |
CSI |
1 |
Clerk/secretary |
1 |
Time per POI |
8 |
Time per Operations Inspector, Pilot |
40 |
Time per Operations Inspector, Dispatcher |
40 |
Time per CSI |
40 |
Time per clerk/secretary |
0.50 |
Aircraft types |
3 |
First Year Cost
Dollars |
$2,268,701 |
Hours |
43,424.5 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$2,268,701 |
Hours |
43,424.5 |
Average per year
Dollars |
$226,870 |
Hours |
4342.45 |
■ For FAOM and ADPM:
Air Carriers |
118 |
POI |
1 |
Operations Inspector, Pilot |
1 |
Operations Inspector, Dispatcher |
1 |
CSI |
1 |
Clerk/secretary |
1 |
Time per POI |
8 |
Time per Operations Inspector, Pilot |
24 |
Time per Operations Inspector, Dispatcher |
24 |
Time per CSI |
24 |
Time per clerk/secretary |
0.50 |
Aircraft types |
3 |
First Year Cost
Dollars |
$1,384,446 |
Hours |
26,432.5 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$1,384,446 |
Hours |
26,432.5 |
Average per year
Dollars |
$138,445 |
Hours |
2643.25 |
c. § 121.1413 Aircraft dispatcher: Training and evaluation (operating familiarization).
The FAA recognizes this is an increase in the record keeping requirements for the certificate holder, but this requirement will have no impact on the government.
d. § 121.1417 Aircraft dispatcher: Supervised operating experience.
The FAA recognizes this is an increase in the record keeping requirements for the certificate holder, but this requirement will have no impact on the government.
e. § 121.1421 Dispatcher instructor and check dispatcher: Eligibility, training, and evaluation.
The FAA recognizes this is an increase in the record keeping requirements for the certificate holder, but this requirement will have no impact on the government.
f. § 121.1433 Training Program: General curriculum by aircraft type and operation.
1. For review of the modified existing training modules.
Requires 1 Operations Inspector, Dispatcher, 1 hour for review of each existing module, multiplied by the 5 existing training modules (Basic Indoctrination, Group I and Group II Initial Equipment, Transition, and Recurrent), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Operations Inspector, Dispatcher |
1 |
Cost per hour for Operations Inspector, Dispatcher |
$52.04 |
Time per existing module |
1 |
Number of modules |
5 |
First Year Cost
Dollars |
$18,474 |
Hours |
355.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$18,474 |
Hours |
355.0 |
Average per year
Dollars |
$1,847 |
Hours |
35.5 |
2. For review of the new, additional training modules.
(a) Requires 1 Operations Inspector, Dispatcher, 4 hours for review of each of 3 new training modules (General Knowledge and Skills for Initial, Recurrent, and Requalification training categories), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Operations Inspector, Dispatcher |
1 |
Cost per hour for Operations Inspector, Dispatcher |
$52.04 |
Time per existing module |
4 |
Number of new modules |
3 |
First Year Cost
Dollars |
$44,338 |
Hours |
852.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$44,338 |
Hours |
852.0 |
Average per year
Dollars |
$4,434 |
Hours |
85.2 |
Requires 1 Operations Inspector, Dispatcher, 4 hours for review of each of 3 new training categories (Basic Aircraft and Aircraft Type for Initial, Recurrent, and Requalification training categories), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Operations Inspector, Dispatcher |
1 |
Cost per hour for Operations Inspector, Dispatcher |
$52.04 |
Time per new training module |
4 |
Number of new training modules |
3 |
First Year Cost
Dollars |
$44,338 |
Hours |
852.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$44,388 |
Hours |
852.0 |
Average per year
Dollars |
$4,434 |
Hours |
85.2 |
©Requires 1 Operations Inspector, Dispatcher, 4 hours for review of each evaluation and performance standard, multiplied by the 4 categories (Initial, Transition, Recurrent, and Requalification), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Operations Inspector, Dispatcher |
1 |
Cost per hour for Operations Inspector, Dispatcher |
$52.04 |
Time per review of each evaluation and performance standard |
4 |
Number of training categories |
4 |
First Year Cost
Dollars |
$59,117 |
Hours |
1136.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$59,117 |
Hours |
1136.0 |
Average per year
Dollars |
$5,912 |
Hours |
113.6 |
Requires 1 Operations Inspector, Dispatcher, 4 hours for review of each of the 3 modules (Dispatch Instructors, Check Dispatchers, and Dispatch Program Designee), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Operations Inspector, Dispatcher |
1 |
Cost per hour for Operations Inspector, Dispatcher |
$52.04 |
Time per module |
4 |
Number of modules |
3 |
First Year Cost
Dollars |
$44,338 |
Hours |
852.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$44,338 |
Hours |
852.0 |
Average per year
Dollars |
$4,434 |
Hours |
85.2 |
Requires 1 clerk/secretary 0.5 hours per certificate holder per training program (1 Dispatcher training program), for 71 air carriers.
Calculations:
Air Carriers |
71 |
Clerk/secretary |
1 |
Cost per hour for clerk/secretary |
$24.67 |
Time per air carrier |
0.5 |
First Year Cost
Dollars |
$876 |
Hours |
35.5 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$876 |
Hours |
35.5 |
Average per year
Dollars |
$88 |
Hours |
3.55 |
g. § 121.1441 Training program: Continuous analysis process (see paragraph “14.l.”)
h. Training Category requirements:
1. § 121.1457 Training Category requirements: Dispatch instructor initial and recurrent training. The FAA recognizes this is an increase in the record keeping requirements for the certificate holder, but this requirement will have no impact on the government.
2. § 121.1459 Training Category requirements: Check dispatcher and recurrent training. The FAA recognizes this is an increase in the record keeping requirements for the certificate holder, but this requirement will have no impact on the government.
i. §§ 121.1201 through 121.1323. While requiring the gathering and maintaining of information and, in certain cases, the reporting of some of that information to the FAA, these sections require no additional burdens on the FAA beyond what is currently completed by the FAA to determine compliance with the rules.
j. § 121.1331: Training program: General. This part of the paperwork package describes the requirements for training programs for Pilot, Instructor Pilot, Check Pilot, APD, F/E, F/E Instructors, Check F/E, F/A, F/A Instructors, Check F/A, and Persons authorized to administer F/A proficiency tests, and deals with the individual requirements for the structure and content of each distinct training program, including the specific requirements for the review (and where required, modification and re-structure of a particular training program), development, construction, printing, and collation of the required training programs. The overall commitment of time to review and approve the appropriate training program or program revision impact the FAA through Principal Operations Inspectors; Aircrew Program Designees; Operations Inspectors, Pilot; Cabin Safety Inspectors; and FAA Clerks/Secretaries. The documents and information reviewed and approved or rejected are addressed here. The single exception to this is § 121.1353: Training program: Continuous analysis process, and is addressed in paragraph l, below.
1. Existing Training program review:
(a) Pilots (includes training programs for PIC, SIC, Instructor Pilot, Check Pilot, and APD):
(i) Existing module review: Requires 1 Operations Inspectors, Pilot,1 hour for review of each existing module; multiplied by 15 modules for each aircraft type, multiplied by 3 aircraft types, for 118 air carriers.
Calculations:
Air Carriers |
118 |
Operations Inspector, Pilot |
1 |
Cost per hour for Operations Inspector, Pilot |
$52.04 |
Time per existing module |
1 |
Modules |
15 |
Aircraft types |
3 |
First Year Cost
Dollars |
$276,330 |
Hours |
5310.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$276,330 |
Hours |
5310.0 |
Average per year
Dollars |
$27,633 |
Hours |
531.0 |
Additional, new module development: Requires 1 Operations Inspector, Pilot; 5 hours to review each newly developed module; multiplied by 3 new modules per aircraft type, multiplied by 3 aircraft types, for 118 air carriers.
Calculations:
Air Carriers |
118 |
Operations Inspector, Pilot |
1 |
Cost per hour for Operations Inspector, Pilot |
$52.04 |
Time per additional new module |
5 |
Modules |
3 |
Aircraft types |
3 |
First Year Cost
Dollars |
$276,330 |
Hours |
5310.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$276,330 |
Hours |
5310.0 |
Average per year
Dollars |
$27,633 |
Hours |
531.0 |
Review by POI of complete Pilot training program equals
Calculations:
Air Carriers |
118 |
POI |
1 |
Cost per hour for POI |
$61.50 |
Time per review |
4 |
First Year Cost
Dollars |
$29,026 |
Hours |
472.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$29,026 |
Hours |
472.0 |
Average per year
Dollars |
$2,903 |
Hours |
47.2 |
(b) Flight Engineers (includes training programs for F/E, F/E Instructors, and Check F/E):
(i) Existing module review: Requires 1 Operations Inspector, Pilot, 1 hour for review of each existing module, multiplied by 3 modules for each aircraft type, multiplied by 1 aircraft type requiring a F/E, for 71 air carriers.
Calculations:
Air Carriers |
71 |
Operations Inspector, Pilot |
1 |
Cost per hour for Operations Inspector, Pilot |
$52.04 |
Time per existing module |
1 |
Modules |
3 |
Aircraft types |
1 |
First Year Cost
Dollars |
$11,084 |
Hours |
213.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$11,084 |
Hours |
213.0 |
Average per year
Dollars |
$1,108 |
Hours |
21.3 |
Additional, new model development: Requires 1 Operations Inspector, Pilot, 20 hours each for each new module, multiplied by 2 new modules for each aircraft type, multiplied by 1 aircraft type requiring a F/E, for 71 air carriers.
Calculations:
Air Carriers |
71 |
Operations Inspector, Pilot |
1 |
Cost per hour for Operations Inspector, Pilot |
$52.04 |
Time per additional new module |
20 |
Modules |
2 |
Aircraft types |
1 |
First Year Cost
Dollars |
$147,792 |
Hours |
2840.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$147,792 |
Hours |
2840.0 |
Average per year
Dollars |
$14,779 |
Hours |
284.0 |
Review by POI of complete F/E training program equals
Calculations:
Air Carriers |
71 |
POI |
1 |
Cost per hour for POI |
$61.50 |
Time per review |
2 |
First Year Cost
Dollars |
$8,732 |
Hours |
142.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$8,732 |
Hours |
142.0 |
Average per year
Dollars |
$873 |
Hours |
14.2 |
© Flight Attendants:
(i) For review of the modified existing training modules.
A. Requires 1 CSI, 1 hour for review of each existing module, multiplied by 15 modules for each aircraft type, multiplied by 3 aircraft types, 71 air carriers.
Calculations:
Air Carriers |
71 |
CSI |
1 |
Cost per hour for CSI |
$52.04 |
Time per existing module |
1 |
Modules |
15 |
Aircraft types |
3 |
First Year Cost
Dollars |
$166,266 |
Hours |
3195.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$166,266 |
Hours |
3195.0 |
Average per year
Dollars |
$16,627 |
Hours |
319.5 |
Requires 1 CSI 8 hours for review of each existing emergency training module (3 modules), for 71 air carriers.
Calculations:
Air Carriers |
71 |
CSI |
1 |
Cost per hour for CSI |
$52.04 |
Time per existing emergency training module |
8 |
Modules |
3 |
First Year Cost
Dollars |
$88,675 |
Hours |
1704.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$88,675 |
Hours |
1704.0 |
Average per year
Dollars |
$8,868 |
Hours |
170.4 |
Requires 1 CSI 4 hours each for review of each existing basic indoctrination (3 modules) for 71 air carriers.
Calculations:
Air Carriers |
71 |
CSI |
1 |
Cost per hour for CSI |
$52.04 |
Time per existing basic indoctrination module |
4 |
Modules |
3 |
First Year Cost
Dollars |
$44,338 |
Hours |
852.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$44,338 |
Hours |
852.0 |
Average per year
Dollars |
$4,434 |
Hours |
85.2 |
(ii) For review of the new, additional training modules.
Requires 1 CSI, 8 hours for review of each new airplane specific module, multiplied by 2 modules for each aircraft type, multiplied by 3 aircraft types, for 71 air carriers.
Calculations:
Air Carriers |
71 |
CSI |
1 |
Cost per hour for CSI |
$52.04 |
Time per new airplane specific training module |
8 |
Modules |
2 |
Aircraft types |
3 |
First Year Cost
Dollars |
$177,351 |
Hours |
3408.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$177,351 |
Hours |
3408.0 |
Average per year
Dollars |
$17,735 |
Hours |
340.8 |
Requires 1 CSI 8 hours for review of each new emergency training module (5 modules), for 71 air carriers.
Calculations:
Air Carriers |
71 |
CSI |
1 |
Cost per hour for CSI |
$52.04 |
Time per new emergency training module |
8 |
Modules |
5 |
First Year Cost
Dollars |
$147,792 |
Hours |
2840.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$147,792 |
Hours |
2840.0 |
Average per year
Dollars |
$14,779 |
Hours |
284.0 |
Requires 1 CSI 8 hours for review of each new basic indoctrination module (1 modules), for 71 air carriers.
Calculations:
Air Carriers |
71 |
CSI |
1 |
Cost per hour for CSI |
$52.04 |
Time per new basic indoctrination module |
8 |
Modules |
1 |
First Year Cost
Dollars |
$29,558 |
Hours |
568.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$29,558 |
Hours |
568.0 |
Average per year
Dollars |
$2,956 |
Hours |
56.8 |
Review by POI of complete F/A training program, for 71 air carriers.
Calculations:
Air Carriers |
71 |
POI |
1 |
Cost per hour for POI |
$61.50 |
Time |
2 |
First Year Cost
Dollars |
$8,732 |
Hours |
142.0 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$8,732 |
Hours |
142.0 |
Average per year
Dollars |
$873 |
Hours |
14.2 |
(d) Cover, approval letter: Requires 1 Clerk/Secretary 0.5 hours per certificate holder per training program (1 pilot, 1 F/E, 1 F/A,); equals 1.5 hours, for 71 air carriers.
Calculations:
Air Carriers |
71 |
Clerk/secretary |
1 |
Cost per hour for clerk/secretary |
$24.67 |
Time |
1.5 |
First Year Cost
Dollars |
$2,627 |
Hours |
106.5 |
Subsequent Years – per year costs
Dollars |
$0.00 |
Hours |
0.0 |
Total over 10 years
Dollars |
$2,627 |
Hours |
106.5 |
Average per year
Dollars |
$263 |
Hours |
10.65 |
k. §§ 121.1333 through 121.1391. These sections deal with the individual requirements for the structure and content of each distinct training program, including the specific requirements for the development or the review and modification (where required) of new training programs or the re-structure of existing training programs. The inclusive commitment of time and the documents and information gathered or generated are addressed in paragraph 14.j., with the following exception:
l. § 121.1353: Training program: Continuous analysis process. Air carriers would be required to measure and monitor the outcome of the training program. The cost of the continuous analysis process is divided into three parts: flight crewmembers, flight attendants, and dispatchers. To calculate the flight crewmember part, the following assumptions were used, paralleling those in the regulatory evaluation:
Pilots and Flight Engineer:
Air Carriers |
118 |
Operations Inspector, Pilot |
1 |
Cost per hour for Operations Inspector, Pilot |
$52.04 |
Time per Operations Inspector, Pilot |
2 |
Recurrent time per Operations Inspector, Pilot |
1 |
First Year Cost
Dollars |
$12,281 |
Hours |
236.0 |
Subsequent Years – per year costs
Dollars |
$6,141 |
Hours |
118.0 |
Total over 10 years
Dollars |
$67,547 |
Hours |
1298.0 |
Average per year
Dollars |
$6,755 |
Hours |
129.8 |
Flight Attendants:
Air Carriers |
71 |
CSI |
1 |
Cost per hour for CSI |
$52.04 |
Time per CSI |
2 |
Recurrent time per CSI |
1 |
First Year Cost
Dollars |
$7,390 |
Hours |
142.0 |
Subsequent Years – per year costs
Dollars |
$3,695 |
Hours |
71.0 |
Total over 10 years
Dollars |
$40,643 |
Hours |
781.0 |
Average per year
Dollars |
$4,064 |
Hours |
78.1 |
Aircraft Dispatchers:
Air Carriers |
71 |
Operations Inspector, Dispatcher |
1 |
Cost per hour for Operations Inspector, Dispatcher |
$52.04 |
Time per Operations Inspector, Dispatcher |
2 |
Recurrent time per Operations Inspector, Dispatcher |
1 |
First Year Cost
Dollars |
$7,390 |
Hours |
142.0 |
Subsequent Years – per year costs
Dollars |
$3,695 |
Hours |
71.0 |
Total over 10 years
Dollars |
$40,643 |
Hours |
781.0 |
Average per year
Dollars |
$4,064 |
Hours |
78.1 |
Summary of time and costs (10-year) addressed in question 14:
Section |
Cost |
Hours |
121.133, 121.135 |
|
|
FCOM |
$2,268,701 |
43,424.5 |
FAOM/ADPM |
$1,384,446 |
26,432.5 |
121.1131 |
|
|
1(i) |
$18,474 |
355.0 |
2(i) |
$44,338 |
852.0 |
2(ii) |
$44,338 |
852.0 |
2(iii) |
$59,117 |
1,136.0 |
2(iv) |
$44,338 |
852.0 |
2(v) |
$876 |
35.5 |
121.1331 |
|
|
1(a)(i) |
$276,330 |
5,310.0 |
1(a)(ii) |
$276,330 |
5,310.0 |
1(a)(iii) |
$29,026 |
472.0 |
1(b)(i) |
$11,084 |
213.0 |
1(b)(ii) |
$147,792 |
2,840.0 |
1(b)(iii) |
$8,732 |
142.0 |
1©(i)A |
$166,266 |
3195.0 |
1©(i)B |
$88,675 |
1,752.0 |
1©(i)C |
$44,338 |
852.0 |
1©(ii)A |
$177,351 |
3,408.0 |
1©(ii)B |
$147,792 |
2,840.0 |
1©(ii)C |
$29,558 |
568.0 |
1©(iii)A |
$8,732 |
142.0 |
D |
$2,627 |
106.5 |
121.1353 |
|
|
Pilots and Flight Engineer |
$67,547 |
1,298.0 |
Flight Attendants |
$40,643 |
781.0 |
Aircraft Dispatcher |
$40,643 |
781.0 |
|
|
|
TOTAL |
$5,428,092 |
103,902.0 |
AVERAGE PER YEAR |
$542,809.20 |
10,390.2 |
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
This is a new collection, therefore it is a program change.
16. For collections of information whose results are planned to be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
There is no plan for tabulation or publication.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
No such approval is being sought.
18. Explain each exception to the certification statement identified in Item 19. "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
There are no exceptions.
1 All fringe benefits use a factor of 1.2345, as shown in U.S. Department of Transportation, Federal Aviation Administration, Office of Aviation Policy and Plans, Economic Analysis of Investment and Regulatory Decision - A Guide. (FAA APO-98-4: January 1996), Table 4-5.
File Type | application/msword |
File Title | SUPPORTING STATEMENT |
Author | Taylor CTR Dahl |
Last Modified By | Taylor CTR Dahl |
File Modified | 2009-01-12 |
File Created | 2009-01-12 |