2120-0724 2014

OMB Supporting Statement

Verification of Authenticity of Foreign License, Rating and Medical Certification

2120-0724

Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

Based on the International Civil Aviation Organization (ICAO) convention agreement, airmen may use their foreign license in lieu of an aeronautical knowledge test, experience, and a practical test when applying for a restricted or unrestricted U.S. certificate. After the events of September 11, 2001, it was determined that the Federal Aviation Administration (FAA) should verify, with the appropriate Civil Aviation Authority (CAA), that the foreign license and medical certificate being used to obtain a U.S. certificate are, in fact, current and valid.

A process was established that required a person who is applying for a U.S. certificate and/or rating, on the basis of a foreign license, to apply for that certificate at least 90 days before arriving at the designated FAA Flight Standards District Office (FSDO) where the applicant intends to receive the U.S. certificate. This allows time for the Airmen Certification Branch to ask for, and receive, verification from the appropriate CAA that the person’s foreign license is current and valid.

Attach a copy of the appropriate section of each statute and regulation mandating and authorizing the collection of information.

Acronyms used in the guidance:

ASI – Aviation Safety Inspector

AST – Aviation Safety Technician

CAA – Civil Aviation Authority

FSDO – Flight Standards District Office

Order 8900.1, Vol 5, Chapter 2, Section 14, Paragraph 5-600 J-P

J.    Process. ASIs and ASTs should become familiar with this process in order to advise applicants and examiners of these new procedures. For this familiarization, ASIs and ASTs are directed to the AFS‑760 Airmen Certification website at: http://www.faa.gov/licenses_certificates/airmen_certification. This website explains FAA procedures for issuing U.S. pilot certificates on the basis of a person holding a foreign pilot license.

K.    Information to Submit. Applicants for U.S. pilot certificates and ratings are required to submit the following information to AFS‑760:

1)    The applicant’s full name and date of birth.

2)    The address to which the person wishes to have the Verification of Authenticity letter mailed after AFS‑760 issues it.

3)    The certificate number and ratings on the foreign pilot license.

4)    The country of issuance of the person’s foreign pilot license.

5)    The location of the FAA FSDO where the person intends to make application for his/her U.S. pilot certificate.

6)    A statement that his/her foreign pilot license is not under an order of suspension or revocation.

L.    Optional Form. Applicants can also submit this required information using the optional form from AFS‑760’s website at: http://www.faa.gov/licenses_certificates/airmen_certification/foreign_license_verification.

M.    Completed Form Submission. The applicant can mail the completed form with the preferred documents to the FAA Airmen Certification Branch, AFS‑760, P.O. Box 25082, Oklahoma City, OK 73125‑0082 or fax the form and documents to 405‑954‑9922. The application must be signed, so the application packet must be faxed, mailed or a signed copy can be scanned and emailed.

NOTE:  The applicant should include a legible copy of his/her foreign pilot license and medical license or endorsement with all requests for verification of authenticity of the foreign pilot license. A person applying for a U.S. pilot certificate/rating on the basis of a foreign pilot license must apply for that pilot certificate at least 90 days before arriving at the designated FAA FSDO where the applicant intends to receive the U.S. pilot certificate. This initial application step is the responsibility of the applicant.

N.    Written Notification. When verification is received from a foreign CAA, the applicant will receive written notification that a copy of the verification of authenticity of the foreign pilot license has been forwarded to the designated FSDO in the applicant’s request. The verification of authenticity of the foreign pilot license is valid for 6 calendar‑months. Applicants may make application for their U.S. pilot certificate at the designated FSDO during that period.

O.    Request to Change Designated FSDO. A request to change the designated FSDO may be made by sending a letter to the FAA Airmen Certification Branch, AFS‑760, P.O. Box 25082, Oklahoma City, OK 73125‑0082 or by fax to 405‑954‑9922.

P.    Duties and Responsibilities of AFS‑760. AFS‑760 is responsible for:

1)    Verifying the authenticity of the applicant’s foreign pilot license and medical license with the foreign CAA.

2)    Ensuring the applicant’s foreign pilot license and medical license has not been surrendered, suspended, revoked, or expired.

3)    Issuing the Verification of Authenticity letter to the designated FSDO and a copy to the applicant. The Verification of Authenticity letter expires 6 calendar‑months from the dated month on the letter.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The Airmen Certification Branch will use the required information to properly identify the person for the purpose of requesting foreign license verification from the appropriate CAA and also to check the applicant’s information against a list of potential TSA threats.

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, e.g. permitting electronic submission of responses and the basis for the decision for adopting this means of collection.

The Verification of Authenticity of Foreign License, Rating, and Medical Certification is available for download on the “FAA Forms” website at: http://www.faa.gov/forms/.

The form must be completed and signed in ink, certifying that the information submitted is correct and accurate and giving the agency permission to contact the CAA on their behalf. Applications are accepted by mail, fax, or by email.

4. Describe efforts to identify duplication. Show specifically why any similar information already available can be used for the purpose described in Item 2 above.

No similar information has been collected from this population. Most of the applicants are airmen who are not currently in FAA’s system of records. These are pilots who intend on making application with the FAA to eventually receive an FAA certificate.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Collection of this information does not impact small businesses or other small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If the collection of this information is not conducted, the agency would not be able to complete the foreign verification process. FAA would lose the capability to properly identify the applicants and lose the applicant’s permission for our office to request verification from the appropriate CAA.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with 1320.5(d)(2)(i)-(viii).

There are no circumstances that would cause the collection of information to be conducted in a manner inconsistent with 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 recordkeeping, disclosure, or reporting format (if any) and on data elements to be recorded, disclosed, or reported.

A 60-day notice for public comments was published in the Federal Register on September 24, 2013, vol. 78, no. 185, page 58598. No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gifts to respondents were considered.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The information collected becomes part of the Privacy Act system of records DOT/FAA 847, General Air Transportation Records on Individuals and is subject to its published routine uses.

11. Provide additional justification for any questions of a sensitive nature.

No questions of a sensitive nature are asked.

12. Provide estimates of hour burden of the collection information. This information should: Provide number of respondents, frequency of response, annual burden, and an explanation of how the burden was estimated.

It should take the average person a maximum of 10 minutes to complete the form. The Airmen Certification Branch processes an average of 8,700 requests for foreign certificates each year. All foreign applicants are required to complete form 8060-71, Verification of Authenticity of Foreign License, Rating, and Medical Certification, receive a valid foreign verification letter, and meet in-person FAA/examiner approval prior to the issuance of their airman certificate. The frequency of response is once every time a person wants to use his/her foreign license to obtain a U.S. certificate and/or rating.

Annual number of responses	8,700
Time per form	10 minutes
TOTAL ANNUAL BURDEN	1450 hours

13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information.

The estimated annual cost burden to the respondents is $51,237.98. This result is based on a median salary of $73,500 per year at 2,080 hours, equals $35.34 an hour; divided by 6 (10 minutes in an hour), equals $5.89; multiplied by 8,700 respondents equals $51,237.98.

14. Provide estimates of annualized cost to the Federal government.

The estimated annualized cost of labor to the Federal government for processing of verifications received is $178,632.75.

15. Explain reasons for program changes or adjustments reported in Items 13 or 14 of OMB Form 83-I.

The actual number of foreign applications processed has significantly increased over several years. The Airmen Certification office changed from being staffed completely by contract employees to being staffed by federal employees. The actual worker cost decreased, but the workload increased by over 35%.

16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used.

There is no planned publication of this information.

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 to the certification for “Paperwork Reduction Act Submissions”.