SUPPORTING STATEMENT
OMB-2120-0039
Part 135- Operating Requirements: Commuter and on-Demand Operations and Rules
Governing Persons on Board such Aircraft
Justification
1. Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the collection.
Title 49 USC, Section 44702 empowers the Secretary of Transportation to issue air carrier certificates and to establish minimum safety standards for the operation of the air carrier
to whom such certificates are issued. Under the authority of Title 49 USC, Section
44701, Title 14 Code of Federal Regulations (14 CFR) part 135 prescribes the terms, conditions, and limitations as are necessary to ensure safety in air transportation.
This collection of information supports the Department of Transportation’s strategic goal of safety.
2. Indicate how, by whom, and for what purpose the information is to be used.
Each operator which seeks to obtain, or is in possession of, an air carrier or FAA operating certificate must comply with the requirements of 14 CFR part 135 in order to maintain data which is used to determine if the carrier is operating in accordance with minimum safety standards. Air carrier and commercial operator certification is completed in accordance with 14 CFR part 119. Part 135 contains operations and maintenance requirements.
3. Describe whether, and to what extend, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.
The burden associated with 14 CFR part 135 is associated with reporting and recordkeeping. The FAA has encouraged the use of automation by the air carriers and commercial operators to reduce their burden. The FAA has deployed an automated Operations Specifications subsystem which facilitates issuance of operators’ operations specifications. This system also facilitates reporting requirements by its report features. This system allows operators to electronically generate and electronically sign the operations specifications. It contains standard template paragraphs. Currently, operators have the option of using the electronic operations specifications subsystem to generate their specifications and electronically transmit them for approval. Currently 307 operators with part 135 operating authority have elected and are equipped to use the electronic operations specifications subsystem. This generation and approval of operations specifications is 100% submittable electronically and is fully compliant with the Government Paperwork Elimination Act.
In addition, the required maintenance and inspection programs are authorized to be kept and maintained electronically. Certain relief is provided from carrying maintenance manuals onboard the aircraft.
Most recordkeeping provisions and approval processes can be accomplished electronically; however, certain documents such as passenger briefing cards and flight and operational manuals must currently be available in paper form for safety reasons.
The FAA continues to work with operators to develop procedures to allow expedited changes to operations specifications, such as adding aircraft that are substantially similar to aircraft currently approved for operation.
Email facilitates communications between the operator and the FAA.
Operations specifications are issued to approve of new authorizations/limitations or new aircraft. In addition to operations specifications, changes to manuals, procedures, minimum equipment lists, briefing cards or other documents are required.
Approximately 10% of all of the estimated 8 to 10 million responses could be accomplished electronically. These include all or portions of the recordkeeping requirements (135.63), maintenance manuals and records (135.21) and the review/approval process of manuals and training programs. Use of email facilitates the approval process. Electronic submission of recordkeeping is voluntary on the part of the operator. Some documents such as passenger briefing cards and flight operational manuals must be available in paper form for safety reasons.
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 our other FAA public-use reports and find no duplication. Also, we know of no other agency collecting information from air carriers and commercial operators prescribing the terms, conditions, and limitations of their operating certificate.
This information, required by 14 CFR part 135, is to ensure safety in air transportation.
Further the information collected is only available from the applicant applying for an operating certificate and from certificate holders operating under part 135. The applicant/operator must prescribe his/her own data based on the operation. The information is not available from any other source.
However, if a certificate holder also conducts fractional ownership programs under part
91 of the regulations, the proposed rule for those operations authorizes the operator to use certain records required by part 135 to satisfy the equivalent requirements and recordkeeping provisions of a fractional ownership program. The paperwork reduction provisions are further discussed and applied in the fractional ownership proposed rule and paperwork reduction package for that rule.
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.
All applicants are provided guidance for the certification and administrative processes by the Certificate Holding District Office. FAA guidance documents (guidance for FAA inspectors for approving programs) are available to the public through the internet. This information and availability greatly assists in the preparation of required documents. Use of email facilitates communications between the approving inspectors and the applicants. Automation of the operations specifications subsystem facilitates issuance of authorizations. Paragraphs outlining authorizations and limitations are issued specific to an operator’s operation. For other reporting or recordkeeping burdens listed, the smaller operators have burdens in proportion to the size of their operation. For example, single pilot operations are not required to prepare a manual or training program which significantly reduces the burden. The number of records and required reports are proportional to the number of pilots and aircraft used by the operator. Further, in several cases, such as for passenger briefings or aircraft checklists, commercially produced products are available from the aircraft manufacturer.
6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
The frequency of information collection is dependent on the applicant’s business plan and application for new kinds of operation or types of aircraft. The frequency of information collection, for the most part, is determined by the business activity of the operator. There may be safety implications for some forms of information.
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), with the exception that some records are maintained longer than three years. Qualification records for crewmembers are maintained for as long as the person is employed by the operator. With respect to maintenance recording/recordkeeping requirements, section 135.439 specifies maintenance record and retention requirements and states the records must be transferred with the aircraft at the time it is sold. This means that there are certain aircraft maintenance records that stay with the aircraft for the life of the aircraft and are transferred from owner to owner.
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 recordkeeping, disclosure, or reporting format (if any) and on the data elements to be recorded, disclosed, or reported.
A notice was published in the Federal Register on July 9, 2012, volume 77, #131, pages 40404-40405. No comments were received.
9. Explain any decision to provide any payment or 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.
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.
The specific 14 CFR part 135 reporting requirements are prescribed by the following regulatory sections. This report lists the numbers of affected air carriers and commercial operators and bases cost figures on updated salary estimates. The number of air carriers and commercial operators’ changes daily as a result of mergers or by the surrendering of certificates. Numbers used in this report represent 2011 levels; the most recent available.
Operator employee salaries in all of question 12 are based on 2012 data (real wages that are adjusted for inflation) provided by PayScale, Inc., 542 1st Avenue S, Suite 400, Seattle, WA juxtaposed with pay guidelines provided by the National Business Aviation Association (NBAA). The hourly wage scale signifies no changes from the previously reported per-hour salary reports.
FBO General Manager = $41.00 per hour
Flight Operations Manager = $43.00 per hour
Secretary = $15.00 per hour
Maintenance Manager = $33.00 per hour
Pilot = Note: There is a wide range in salaries that reflects the diversity of the part 135 industry. The salary survey provided numbers based on types of turbojet airplanes, rotorcraft, turboprops, fractional ownership operations, but did not consider lower salaries of pilots for single engine or multiengine reciprocating powered airplanes that make up a large segment of the industry (4000 reciprocating powered airplanes). An average salary was estimated based on the pilot in command/ second in command turboprop, turbojet, fractional ownership, and helicopter average salaries and an estimate of small airplane pilot salaries = $30.00 per hour; Flight Attendant = $22.00 per hour. Salary estimate were provided by the National Business Aviation Association (NBAA) June 2012. The estimates reflect no changes or increases on the previously reports.
§135.2, Compliance Schedule for Transition to Part 121. This was a one-time event associated with the transition of part 135 operators with aircraft of 10 or more seats that are operated in scheduled service, to comply with part 121 requirements. This action was completed by March 20, 1997.
§135.3, Rules applicable to operations subject to this part. Required a one-time application burden for a transition plan. This plan was to be submitted by March 19,
1996, and detail plans for compliance with the training requirement by March 19, 1997.
This section also has a voluntary provision for operators to comply with the training requirements of subparts N and O of part 121 instead of the training requirements of subparts E, G, and H of part 135.
§135.19, Emergency operations. Requires a person who exercises emergency authority to deviate from a rule of part 135 to send a report of the aircraft operation, description of the deviation and reasons for it. This report must be sent to the FAA Flight Standards
District Office charged with the overall inspection of the certificate holder.
Estimated number of reports a year 50
Estimated technical time x .5
Total estimated technical time 25.0 hrs.
Estimated cost for technical time (pilot) x$30 per hour
Total estimated burden of technical time $750
Total hour burden: 25 hrs
Total cost burden: $750
§135.21 Manual requirements
Requires each certificate holder, except those who use only one pilot, to prepare and keep current a manual for the use of flight, ground, and maintenance personnel. The original preparation of a manual is part of certification and covered in part 119 (119.35) under
OMB clearance number #2120-0593, Certification: Air Carriers and Commercial Operators—FAR Part 119.
§135.21 (d) requires that the manual, or appropriate portions of the manual (and changes
and additions) be made available to maintenance, ground personnel, flight crewmembers,
and representatives of the Administrator.
§135.21 (e) requires each employee to keep his/her manual up-to-date with changes
furnished to them.
135.21 (b), (f), and (g), requires parties to maintain copies of the manual at specified locations. In a change effective 1997, it allows the maintenance part of the manual to be provided in other than printed form provided there is a compatible reading device available and instructions, or a system able to retrieve maintenance information.
Certificate holders of a limited size operation are authorized deviations from all or part of the manual. Additionally, §135.23 contains guidance as to the content of the manual.
Numerous procedures are listed that require inclusion in the manual. Manual guidance is required appropriate to the size and authorizations applicable to an individual operator. A single pilot operator is not required to have a manual. There are approximately 2426 operators of which 780 operators are single pilot operations and not required to have a manual.
Estimated number of operators required to have a manual 1,646
Estimated revisions per year x 7
Total estimated number of revisions 11,522
Estimate 2 technical hrs. per revision x 2
Total estimated technical time 23,044
Cost of technical time (Flt ops mgr/Maint mgr averages) x $38
Total estimated burden for technical time $875,672
Estimated number of revisions 11,522
Estimate .5 secretary hrs per revision x .5
Total estimated secretary time 5,761
Cost of secretary time x $15
Total estimated burden for secretary time $86,415
Total hour burden 28,805
Total cost burden: $962,087
§135.25, Aircraft requirements.
135.25 (d)(4) requires the operator to file a copy of an aircraft lease or charter agreement with the FAA Aircraft Registry. This requirement only applies to foreign registered aircraft.
Estimated number of agreements annually 3
Approximately .2 hours of secretary time x.2
Total estimated secretary time .6
Cost of secretary time x$15
Total estimated burden for secretary time $9.00
Total hour burden: .6
Total cost burden: $9.00
§135.63 Recordkeeping requirements.
(a) Each certificate holder shall keep the following records:
Current list of aircraft used or available for use It is estimated that one half of all operators will update aircraft records each year. It is estimated that these operators will update records 2 times per year.
Estimated number of revisions 2,426
x .5 (one half of operators)
x 2 records per year
2,426 revisions
Approximately .1 hours of technical time per revision 242.6 hours
Cost of technical time (Flt ops/Maint. Mgr average) x $ 38
Total estimated burden cost $9,218.8
Total estimated burden hours 242.6
Requires individual records of each pilot be maintained. This includes information on certificates, ratings, experience, duties, medical information, results of tests, flight time, training and action concerning release from employment.
PILOTS:
Estimated number of pilots (pilot in command and second in command) 18,000
Average number of entries annually per pilot (other than flight and duty)
x 4
Total estimated number of entries 72,000
Approximately .1 hour of technical time per entry x .1
Total estimated technical time 7,200
Cost of technical time (pilot) x $30
Total estimated cost burden for technical time $216,000
Flight and duty for pilots:
Estimated number of pilots 18,000
Average number of entries annually per pilot x 200
Total estimated number of entries 3,600,000
Approximately .1 hour of technical time x .1
Total estimated technical time 360,000 hrs
Cost of technical time (pilot) x $30
Total estimated cost burden for technical time $10,800,000
Requires individual records for each flight attendant showing compliance with duty and rest requirements.
Estimated number of flight attendants 120
Average number of flight attendant personnel records x3
Total estimated number of records 360
Approximately .1 hour of technical time per record .1
Total estimated technical time 36.0
Cost of technical time (flight attendant) x$22
Total estimated cost burden for technical time $792
Flight and duty for flight attendants:
Estimated number of flight attendants 120
Average number of entries annually per attendant x 200
Total estimated number of entries 24,000
Approximately .1 hour technical time per entry x .1
Total technical time 2,400
Cost of technical time (flight attendant) x$22
Total estimated cost burden for technical time $52,800
Requires for multiengine aircraft, the preparation of a load manifest for each flight.
Approximately 7000 multiengine aircraft make an average of 2 takeoffs daily making the paper burden for technical time approximately .1 hour per takeoff.
Approximate number of multiengine aircraft 7,000
Average number of takeoffs daily x2
14,000
Estimated number of annual takeoffs x365
Estimated total takeoffs annually 5,110,000
Approximately .1 hour technical time per takeoff x .1
Total estimated technical time 511,000
Cost of technical time (pilot) x$30
Total estimated burden for technical time $15,330,000
The total burden for 135.63 is 880,879 hours and $26,408,811.
§135.64 Retention of contracts and amendments: Commercial operators who conduct intrastate operations for compensation or hire.
It is estimated:
15 contracts annually x 50 operators = 750 contracts:
670 (written contracts) x .5 hour technical time
80 (oral contracts) x .5 hour secretary time (memo)
Total estimated number of written contracts 670
Approximately .5 hours technical time x .5
Total estimated technical time 335
Cost for technical time (General Mgr) x$41
Total estimated burden of technical time $13,735
Total estimated number of oral contracts 80
Approximately .5 hour secretary time x.5
Total estimated secretary time 40
Cost for secretary time x$15
Total estimated burden of secretary time $600
Total time and cost of burden 375 hours and $14,335
§135.65 Reporting mechanical irregularities. Pilots are required to record each mechanical irregularity that comes to the pilot’s attention during flight.
Estimated number of operators 2,426
Estimated 75 irregularities per year per operator x75
Total number of irregularities 181950
Approximately .25 hours of technical time per entry x .25
Total estimated technical time 45,487.5
Cost of technical time (Pilot) x $30
Total estimated cost burden of technical time $1,364,625
§135.79 Flight locating requirements. Each certificate holder must have procedures for locating each flight for which a flight plan is not filed. This procedure is part of the manual requirement of 135.21. Flight plans are cleared by OMB 2120-0026, Domestic and International Flight Plans. The flight locating information shall be prepared for each flight that is not on a FAA flight plan, and shall be retained until completion of the flight.
Approximate number of newly certificated operators per year 60
Approximate 25% will apply for separate flight locating procedures x .25
Total estimated number of applicants 15
Estimate .5 hours technical time x .5
Total estimated technical time 7.5
Cost of technical time (Flt Ops Mgr) x$43
Total estimated cost burden of technical time $322.50
§135.83 Operating information required: Requires each operator to provide cockpit checklists. Most companies will use checklists provided by the aircraft manufacturer.
Some will develop their own checklists based on manufacturer’s procedures. It is estimated that 10% of the companies will develop their own checklists (average of 2 aircraft types per company).
Number of part 135 operators x 10% x 2 checklists per co. 560
Estimate 2 hours technical time x 2
Total estimated technical time 1120 hr
Cost of technical time (Flt Ops Mgr) x$43
Total estimated cost burden of technical time $48,160
§ 135.117, Briefing of passengers before flight. This section requires an oral safety briefing supplemented by a printed briefing card. Many companies will use briefing cards provided by the aircraft manufacturer. Others will develop their own customized briefing cards. Cards must be available at each aircraft seat and an oral briefing must be given for each flight, unless the passengers have been previously briefed on another leg.
Part 91, Subpart K, Section 91.1035 requires oral briefings and briefing cards. This section requires additional information be provided. Figures reflect the differences in requirements. Figures are adjusted to account for passengers that were previously briefed on another leg, and for the use of recorded briefings. It is estimated that 10% of the companies will develop their own printed briefing cards (average 2 aircraft types per operator)
Number of part 135 operators x 10% x 2 cards per co. 486
Estimate 2 hours technical time x 2
Total estimated technical time 972 hr
Cost of technical time (Flt Ops Mgr) x$43
Total estimated cost burden of technical time $41,796
Oral briefings:
Est. number of briefings per year (adjusted for recorded/ previous briefings) 1,100,000
Estimate average time per briefing x 2 minutes
Total estimated hours 36,667 hours
Cost of technical time (pilot) x 30
Total estimated technical burden for oral briefings $1,100,010
The total burden for 135.117 = 37,639 hours and $1,141,806 cost.
§135.129, Exit row seating. Each new entrant operator with airplanes of 20-30 seats would be required to submit an exit row seating program for approval. This program requires information on passenger information cards available at each exit seat.
Estimated number of new applicants annually (required to submit program) 20
Estimate 2 hours of technical time x 2
Total technical time 40
Cost of technical time (Flt Ops Mgr) x$43
Total estimated burden of technical time $1720
Estimate 2 hours of secretary time per applicants 20 x 2
Total estimated secretary time 40
Cost of secretary time x$15
Total estimated burden of secretary time $600
Totals for new applicants 80 hours and $2320 cost of burden
Revisions to programs of 20-30 seat airplanes
Estimated number of revisions 20
Estimate 1 hour technical time x 1
Total estimate technical time 20
Cost of technical time (Flt Ops Mgr) $43
Total estimated burden of technical time $860
Estimated number of revisions 20
Estimate 1 hour of secretary time x 1
Total estimated secretary time 20
Cost of secretary time x$15
Total estimated burden of secretary time $300
Totals for revisions to programs 40 hours and $1160 cost of burden
Total burden for 135.129 = 120 hours and $3,480.
§135.153, Ground proximity warning system. Requires a maintenance entry whenever a ground proximity system is deactivated. Cost is estimated in malfunction and defect reporting above.
§135.179, Inoperable instruments and equipment. Requires an approved minimum equipment list to authorize operation with certain instruments and equipment inoperative.
It is estimated that there are 60 new applicants per year, each with one aircraft requiring a minimum equipment list. In addition, approximately 200 operators will add/change aircraft in their fleets requiring a new minimum equipment list. Approximately 500 operators per year will add equipment requiring a revision to an existing minimum equipment list.
Initial:
Approximate number of new minimum equipment lists annually 260
Estimate 10 hours of technical time per list x 10
Total estimated technical time 2,600
Cost of technical time (Flt Ops Mgr/ Maint Mgr average) x$38
Total estimated burden of technical time 98,800
Estimated 3 hours of secretary time per list 780
Cost of secretary time x$15
Total estimated burden of secretary time $11,700
Total initial costs: 3380 hours and $110,500 cost of burden
Revisions:
Approximate number of revisions annually 500
Estimate 1 hour of technical time per revision x 1
Total estimated technical time 500
Cost of technical time x$38
Total estimated burden of technical time $19000
Estimated .5 hours of secretary time per revision 250 hrs
Cost of secretary time x$15
Total estimated burden of secretary time $3750
Total revision costs: 750 hours and $22,750 cost of burden
Total burden for 135.179 = 4130 hours and $133,250 cost.
§ 135.227, Icing limitations. Requires a deicing program or checking procedures which are contained in the operator’s manual. New entrants would be required to submit a program or manual procedures. Approximately 1/4th of these operators would submit a full program; the other 3/4th would submit manual procedures for pre-takeoff checks, or not operate in icing conditions.
Costs are computed for program development and program revisions only. If an operator elects manual procedures, those costs are contained in part 119 for initial certification. Revisions to the manual are covered in 135.21 above.
Estimated number of new entrant operators electing to have a deicing program 15
Approximately 20 hours technical time per program x20
Total estimated technical time 300 hrs
Cost of technical time (Flt Ops Mgr/ Maint Mgr average) x$38
Total estimated burden for technical time $11,400
Approximately 5 hours of secretary time per new program 15 x 5 75 hrs
Cost of secretary time x$15
Total estimated burden for secretary time $1125
Estimated number of program revisions per year 50
Approximately 2 hours of technical time per program revision x 2
Total estimated technical time 100
Cost of technical time x$38
Total estimated burden for technical time $3800
Approximately 1 hour of secretary time per program revision 50 hrs
Cost of secretary time x$15
Total estimated burden for secretary time $750
Total burden for deicing program option (new and program revisions)
525 hours and $17,075
§135.273(c), Duty period limitations and rest time requirements. This paragraph establishes an alternate provision for flight attendant flight and duty limits. If the operator does not use the flight crewmember limits, it can establish written procedures for flight attendants that are approved by the Administrator and referenced in operations specifications.
It is estimated that all companies use the flight and duty time requirements specified above in the recordkeeping section (same as the flight crewmembers (pilots)). No cost is associated with this burden.
§ 135.325, Training program and revision. Each applicant for a certificate, other than a single pilot operator, must submit an outline of the proposed curriculum for a training program that meets the minimum standards in the regulation. This outline varies depending on the size and complexity of the operations. A single pilot operator has no training program requirements. A small operator with 2 or 3 pilots and/or 2 or 3 aircraft, or aircraft of the same type, would require approximately 80 to 100 hours to prepare such a curriculum outline. A large operator with, for example 30 to 40 pilots and a variety of aircraft might require 600 to 800 hours. The contents of the curriculum are determined in accordance with section 135.327 and will vary dependent on numbers and types of aircraft and kinds of operations authorized. Paragraph (b) (2) of 135.327 requires a list of all training aids that the operator will use.
The operator applies for initial approval; and after evaluation of the effectiveness of the program, the operator would be issued final approval, with or without revision to the outline as required by the FAA. The operator may also make revision to the curriculum based on changes in its operation, such as addition of another type of aircraft or a change in procedures or authorizations.
There are 2,426 part 135 operators. 780 of these are single pilot operations that do not require a training program. Therefore, 1646 operators require a training program; complexity of the program will vary based on size of the operator. It is expected that one half of new applicants (approximately 30) will require a training program approval.
Initial (new applicants):
Estimated number of new applicants annually requiring manual 30
Estimated average number of hours to prepare training program x 300
Estimated technical hours to prepare new training program 9,000
Cost of technical time (Flt Ops Mgr) x$43
Total estimated burden of technical time $387,000
Total estimated secretary time of 100 hours per program x 30 programs 300
Cost of secretary time x$15
Total estimated burden of secretary time 4500
Total initial manual requirements (new entrants) 9,300 hours and $391,500
Assuming each operator holding a manual would submit one revision annually, estimated revisions would total 1,646 taking 15 hours of technical time and 5 hours secretary time
per revision:
Estimated number of revisions: 1646
Estimate 15 hours of technical time x 15
Total estimated technical time 24,690
Cost of technical time (Flt. Ops Mgr) x$43
Total estimated burden of technical time $1,061,670
Total estimated secretary time of 5 hours per revision x 1646 revisions = 8230
Cost of secretary time x$15
Total estimated burden of secretary time $123,450
Total revision requirements 32,920 hours and $1,185,120 cost of burden
Total burden for 135.325 = 42,220 and 1,576,620 cost.
§ 135.415, Mechanical reliability reports—Requires the operator to report occurrences or detection of each failure, malfunction, or defect in an aircraft.
Estimated number of aircraft 2765
Average number of reports per aircraft annually x 1
Total number of reports 2,765
Estimate 1 technical hour per report x 1
Total technical hours 2,765
Cost of technical time (Maint Mgr) x$33
Total estimated burden of technical time $91,245
§ 135.417, Mechanical interruption summary report. An operator shall mail or deliver a monthly summary report of the following occurrences that happen to multiengine aircraft: each interruption to a flight, unscheduled change of aircraft en route, or unscheduled stop or diversion from a route, caused by known or suspected mechanical difficulties or malfunctions that are not required to be reported under 135.415.
Estimated number of operators with multiengine aircraft 1,500
Estimate 12 reports annually per operator x12
Total estimated number of reports 18,000
Estimate 1 hour technical time 18,000
Cost of technical time (Maint. Mgr) x$33
Total estimated burden of technical time $594,000
§ 135.419, Approved aircraft inspection program. Certificate holders are required to have an approved aircraft inspection program. The program is part of their operations specifications. This section says that the Administrator may amend the certificate holder’s operations specifications and it says that the certificate holder may apply for any amendment to an approved program. The application for amendment must include the proposed changes to the aircraft inspection program. After the inspection program or amendments are approved, they become a part of the manual required by section 135.21.
The burden for the initial preparation of the inspection program and the subsequent amendments are covered by OMB 2120-0028, Operations Specifications.
Estimated number of amendments to program 50
Estimate 1 hour technical time x 1
Total estimated technical time 50
Cost of technical time (Maint. Mgr) x$33
Total estimated burden of technical time $1,650
Estimate number of amendments to program 50
Estimate .5 hours secretary time x .5
Total estimated secretary time 25
Cost of secretary time x$15
Total estimated burden of secretary time $375
Totals: Time 75 hours and $2,025
§135.421, Additional maintenance requirements. Certificate holders operating aircraft of nine seats or less must comply with either a manufacturer’s recommended maintenance program or one approved by the FAA for aircraft engines, propellers, rotors, or items of emergency equipment. Operators covered by this section tend to elect the manufacturer’s maintenance program. Therefore, no reporting burden is anticipated. If an operator of single engine aircraft desires to use this aircraft in passenger carrying instrument operations, it must incorporate into its maintenance program either the manufacturer’s recommended engine trend monitoring program or an FAA approved engine trend monitoring program. In addition, written maintenance instructions are required to maintain the additional equipment required for this authorization. Most single engine programs are limited to turbine powered aircraft. A program and instructions would be the same for all same type aircraft in an operator’s fleet.
Estimated number of new single engine IFR trend monitoring programs 20
Estimate 20 hours technical time for program and instructions x20
Total estimated technical time 400
Cost of technical time (Maint. Mgr) x$33
Total estimated burden of technical time $13,200
Estimate 5 hours of secretary time 100 hrs
Cost of secretary time x$15
Total estimated burden of secretary time $1,500
Total: 500 hours and $14,700
§ 135.427, Manual requirements. Certificate holders operating aircraft of 10 or more seats must provide in their manual, adequate maintenance and inspection programs for the airworthiness of all these aircraft and inform personnel of their responsibilities.
Maintenance, preventative maintenance, alteration procedures, inspection methods, and procedures to release aircraft for service must be included. The manual will also contain a maintenance organization and list of persons with whom it has arranged for the performance for any required inspection. The burden for this initial requirement is included under section 119.35 and burden for revisions are addressed under 135.21.
§135.429, Required inspection personnel. Certificate holders are required to determine that each person with whom it arranges to perform its required inspections maintain a
15 current listing of persons who have been trained, qualified, and authorized to conduct required inspections. These persons must be identified by name, occupational title, and the inspections they are authorized to perform.
§135.431, Continuing analysis and surveillance. Certificate holders are required to establish and maintain a system for the continuing analysis and surveillance of the performance and effectiveness of its inspection program and the program covering other maintenance, preventive maintenance, and alterations and for the correction of any deficiency of those programs, regardless of whether those programs are carried out by the certificate holder or by another person.
Estimated number of operators maintaining a system 100
Estimate 70 hours of technical time x 70
Total estimated technical time 7,000
Cost of technical time (Maint. Mgr) x$33
Total estimated burden of technical time $231,000
§135.439, Maintenance record requirement. Certificate holders are required to keep certain maintenance records using the system specified in the manual by section 135.427.
The records must contain information necessary for the issuance of an airworthiness release. The records must contain information regarding total time in service of the airframe, engine, and propeller; the current status of life-limited parts of each airframe, engine, propeller, rotor and appliance; the items installed on the aircraft which are required to be overhauled on a specified time basis. The records must contain the current inspection status of the aircraft, the current status of applicable airworthiness directives, and a list of current major alterations to each airframe, engine, propeller, rotor, and appliance. Each certificate holder shall retain the records for a certain specified time and make them available for inspection by the Administrator or any representative of the National Transportation Safety Board (NTSB).
Estimated number of aircraft involved in recordkeeping system 200
Estimate 60 hours of technical time x60
Total estimated technical time 12,000
Cost of technical time (Maint. Mgr) x$33
Total estimated burden of technical time $396,000
§135.443, Airworthiness release or aircraft log entry. Certificate holders are required to prepare or cause the person with whom the certificate holder arranges for the performance of the maintenance, preventive maintenance, or alterations to prepare an airworthiness release or an appropriate entry in the aircraft log. The airworthiness release or log entry must be prepared in accordance with the procedure set forth in the certificate holder’s manual and be signed by an authorized certificated mechanic or repairman.
Estimated number of aircraft requiring airworthiness release or
aircraft log entry daily 200
Estimate 1 daily entry per aircraft x365
Total estimated number of entries annually 73,000
Estimate 1 hour technical time 73,000 hrs
Cost of technical time (Maint. Mgr) x$33
Total estimated burden of technical time $2,409,000
SUMMARY OF BURDEN
Hours Cost Total
FAR Section |
Technical |
Admin |
Total Hours |
Technical |
Admin |
Total Cost |
135.2 |
0 |
0 |
0 |
- |
- |
- |
135.3 |
0 |
0 |
0 |
- |
- |
- |
135.19 |
25.00 |
0 |
25.00 |
$ 750 |
- |
$ 750 |
135.21 |
23044 |
5761 |
28,805 |
$ 875,672 |
$86,415 |
$ 962,087 |
135.25 |
0 |
0.60 |
0.60 |
- |
$ 9.00 |
$ 9.00 |
135.63 |
880879 |
0 |
880,879 |
$26,408,811 |
- |
$26,408,811 |
135.64 |
335.00 |
40.00 |
375.00 |
$ 13,735 |
$ 600 |
$ 14,335 |
135.65 |
45487.5 |
0 |
45487.5 |
$ 1,364,625 |
- |
$ 1,364,625 |
135.79 |
7.50 |
0 |
7.50 |
$ 322.50 |
- |
$ 322.50 |
135.83 |
1120 |
0 |
1120 |
$ 48,160 |
- |
$ 48,160 |
135.117 |
972 |
0 |
37639 |
$ 1,141,806 |
- |
$ 1,141,806 |
135.129 |
60 |
60 |
120 |
$ 2,580 |
$ 900 |
$ 3,480 |
135.153 |
0 |
0 |
0 |
0 |
0 |
0 |
135.179 |
3100 |
1030 |
4130 |
$ 117,800 |
$15,450 |
$ 133,250 |
135.227 |
400 |
125 |
525 |
$ 15,200 |
$ 1,875 |
$ 17,075 |
135.273 (c) |
0 |
0 |
0 |
0 |
0 |
0 |
135.325 |
33690 |
8530 |
42220 |
$ 1,448,670 |
$127,950 |
$ 1,576,620 |
135.415 |
2765.00 |
00.00 |
2765.00 |
$ 91,245 |
0 |
$ 91,245 |
135.417 |
18000.00 |
0 |
18000.00 |
$ 594,000 |
0 |
$ 594,000 |
135.419 |
50.00 |
25.00 |
75.00 |
$ 1,650 |
$ 375 |
$ 2,025 |
135.421 |
400.00 |
100.00 |
500.00 |
$ 13,200 |
$ 1,500 |
$ 14,700 |
135.427 |
0 |
0 |
0 |
0 |
0 |
0 |
135.429 |
0 |
0 |
0 |
0 |
0 |
0 |
135.431 |
7000 |
0 |
7000 |
$ 231,000 |
0 |
$ 231,000 |
135.439 |
12000.00 |
0 |
12000.00 |
$ 396,000 |
0 |
$ 396,000 |
135.443 |
73000.00 |
0 |
73000.00 |
$ 2,409,000 |
0 |
$ 2,409,000 |
TOTAL |
1102335 |
15671.6 |
1,154,674 |
$35,174,226.50 |
$235,074 |
$35,409,300.50 |
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
The burden is shown in question 12. There are no additional costs.
14. Provide estimates of annualized cost to the Federal Government.
The FAA estimates that the total estimated annual cost to the Federal Government is $25,900,000. This cost is based on the FAA employee time spent reviewing and processing carrier information and secretary support to issue written approvals and authorizations submitted to the FAA as identified in this document.
15. Explain the reasons for any program changes of adjustments reported in items
13 or 14 of the OMB Form 83-I.
The burden is based on current numbers and in some cases realistic estimates of certificate holders, crewmembers, and aircraft. The annual number of responses has been revised in the ROCIS ICR Summary of Burden table to reflect a more accurate total figure as reported in this statement.
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 publication plan.
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.
Not applicable.
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 in Item 19 OMB Form 83-I.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | DOT/FAA |
| Last Modified By | Taylor CTR Dahl |
| File Modified | 2013-03-28 |
| File Created | 2013-03-28 |