2120-0680 for NPRM AK08_revised

SUPPORTING STATEMENT

OMB -2120-0680

Part 60 -- Flight Simulation Device Initial and

Continuing Qualification and Use

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 part 61, part 63, part 91, part 121, part 135, part 141, and part 142, to ensure safety-of-flight by ensuring that complete and adequate training, testing, checking, and experience is obtained and maintained by those who operate under these parts of the regulation and use flight simulation in lieu of aircraft for these functions. 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 allows and accepts electronic submission, and 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 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. Today, a significant amount of information is submitted via e-mail, on CD/DVD, or posted on SharePoint. We expect this to grow. The National Simulator Program has also designed a system to replace the current scheduling and regulatory management application in use today. Once funded and deployed it could digitize all aspects of information collection.

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 a specific flight simulation training device (FSTD), constructed for and delivered to a specific operator, the FSTD sponsor. The information necessary is available from that sponsor 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 a sponsor applicant will be guided through the administrative requirements by the local principal operations inspector or training center program manager and by representatives of the National Simulator Program staff regarding any FSTD for which the sponsor applicant seeks qualification.

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 for purposes of part 60 is for original qualification and continuing qualification of FSTDs used for flightcrew member training, evaluation, or flight experience requirements in lieu of the aircraft. If the applicant sponsor does not apply initially, evaluation of the FSTD and subsequent qualification will not occur. If the sponsor does not continue to provide this information, the FAA will not be able to determine if the FSTD continues to meet the required performance and handling qualities necessary for the FSTD to substitute completely and accurately for the aircraft in training, evaluation, or flight experience requirements.

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.

In order to resolve comments and provide a forum for the FAA and the aviation community to discuss and resolve issues regarding Flight Simulation Training Devices (FSTDs), the FAA established the Flight Simulation Device Aviation Rulemaking Committee (ARC) on July 2, 2003. The ARC provided a forum for the FAA and affected members of the aviation community to discuss issues. The ARC also allowed members of the aviation community to reach consensus on certain recommendations that would be submitted to the FAA and to develop resolutions to facilitate the evolution of FSTDs. After the FAA received recommendations from the ARC the comment period was reopened on February 10, 2004, to permit interested persons to review these recommendations and submit additional comments. The recommendations from the ARC are available online at http://dms.dot.gov by searching for entry 84 in docket number FAA-2002-12461. The comment period closed on March 11, 2004. The overwhelming majority of the clarifications and revisions contained in the final rule are consistent with the ARC recommendations.

A Notice of Proposed Rulemaking titled “Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks” (RIN 2120-AK08) that included provisions affecting the burden for this collection was published in the Federal Register on July 10, 2014, vol. 79, no. 132, pages 39462-39753 allowing 90 days for public comments. The FAA will incorporate any changes based on these comments into this collection request at the Final Rule stage for RIN 2120-AK08.

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.

The estimates for hours are broken down by sections of the rule below. For a cumulative estimate see the summary table at the end of this document.

§ 60.5 Quality Management System.

This section calls for a sponsor to develop, review, and have approved by the FAA, policies, procedures, and processes that they will follow for each of the sections of Part 60. The purpose of this program requires the sponsor to systematically plan for and implement the requirements of part 60 and the associated Qualification Performance Standard (QPS). The estimate for this section is based on a sponsor count of 46 which has remained consistent during the previous three years and is expected to remain at this level. Sponsors have been sub-grouped into small, medium, and large based on the number of training centers. The nature of QMS is such that a program applies to the sponsor’s entire operation however local differences from one site to another may exist. Single site sponsor QMS program will be relatively less complex than multi-site sponsor QMS programs.

For one-time cost on the industry side:

1. To develop and implement policies, procedures and processes, small sponsors would spend 56 hours, medium sponsors 112 hours, and large sponsors 720 hours. Based on the number of sponsors by size, this would result in 1,792 hours, 1,120 hours, and 2,880 hours respectively for a total of 5,792 hours.

2. To receive final approval on their QMS program, sponsors must complete an on-site assessment. During this assessment, sponsor time will be required to provide and explain records, answer questions regarding processes, and demonstrate procedures. Small and medium sponsors will spend 12 hours each in performing these actions and large sponsors would spend 60 hours. Given that large sponsors have significantly more locations, more than one visit is required and thus more effort is assigned. The total estimate for this activity is 744 hours.

See Table 1 and the Summary table at the end of this document for calculations.

For the continuing, annual cost on the industry side:

1. When a policy, procedure or process changes, either as a result of rule changes or a sponsor’s operation, the applicable section of the QMS program must be updated. The volume of these changes has been minimal and is not expected to increase. Small and medium sponsors will spend 30 minutes documenting and revising the QMS and large sponsors would spend one hour for 16 hours, 5 hours, and 4 hours respectively - a total of 25 hours.

2. In accordance with Part 60 QMS requirements, sponsors must perform self-assessments (internal audits) every six months. Each self-assessment will focus on one quarter of the Part 60 Appendix E requirements and will vary in time with the level of complexity of the sponsor’s program. Small sponsors are expected to spend 6 hours performing two internal assessments each year, medium sponsors are expected to spend 6 hours, and large sponsors 39 hours. A total of 312 hours will be spent by sponsors in this activity each year.

3. The status of each sponsor’s QMS program will be reviewed every two years. This review will be in the form of an on-site assessment exactly similar to the effort outlined in the one-time cost section above. The assumptions for the estimate are the same and will result in a total of 372 hours of effort annually.

4. As part of QMS requirements sponsors must set-up a process to collect feedback. Sponsors are also required to maintain this feedback for a period of time and present it during inspection/assessment periods. Based on direct observation during the initial assessment of sponsor programs, the volume of these feedback events are estimated at 360 for small sponsors, 720 for medium sponsors, and 3,600 for large sponsors each year. Each feedback item will take a sponsor approximately five minutes to record, process and file/maintain. The total effort is 2,760 hours annually.

5. Section 60.5 requires that each sponsor identify a Management Representative and make that person known to the FAA. Initially this effort was part of the documentation of policy, process, and procedures but on a continuing basis the MR may change. Any change must be reported to the FAA. Based on direct observation the average number of changes annually is approximately one. The total effort for this is estimated at 3.8 hours each year. Section 60.5 also requires that the sponsor’s MR regularly brief management on the status of their QMS program and qualification of their FSTDs. The typical period of these briefings, based on assessment of sponsor programs, is quarterly and the time involved is 30 minutes for small and medium sponsors, and 1 hour for large sponsors. The estimate of time for all sponsors is 100 hours per year.

See Table 2 and the Summary table at the end of this document for calculations.

§ 60.9 Additional Responsibilities of the Sponsor.

1. This section sets out requirements for the sponsor to establish a mechanism for receiving comments from those persons using the FSTD, posting of FSTD statements of qualification, designation of an MR, and defining MR duties. The time and costs involved are accounted for under the discussion of §60.5 Quality Management System, above.

§ 60.13 FSTD Objective Data Requirements.

The time and costs involved are addressed in § 60.15, FSTD Initial Qualification Requirements, below.

§ 60.15 Initial Qualification Requirements.

Sub-Sections (a) – (i) of this section set out the requirement that a request for evaluation must be submitted as well as the requirements for the contents of that request. With the exception of the calculation for conversion to electronic format for all QTG documents, existing practices/procedures provide an acceptable mechanism for meeting all other requirements in this section and sponsors of FSTDs will incur no additional time costs from present practice.

The estimated effort to convert paper MQTGs assumes that devices built after 2005 already have digitized copies of this guide and the sponsor simply has to provide that file to the FAA. There are approximately 569 devices that were built prior to 2006 and it is expected that the number of these devices which remain qualified, will shrink. For purposes of this estimate however it is assumed that the number will stay relatively constant. The devices have been categorized into levels which correspond to their fidelity. In general, lower level devices have smaller MQTGs and higher level devices have larger ones. This is directly related to the number of pages which have to be converted.

For one-time cost on the industry side:

The conversion of each page will take a clerk approximately 30 seconds. To see a detailed calculation based on the number of pages per device category and the numbers of devices in each category, see the tables at the end of this document. The total effort for this section is calculated at 8,329 hours.

See Table 3 and the Summary table at the end of this document for calculations.

For the continuing, annual cost on the industry side:

It is expected that approximately 100 changes per year will occur which will require a new conversion of 2 pages. It is again assumed that it will take a clerk 30 seconds to perform this conversion for a total effort estimate of 1356 hours per year.

See Table 4 and the Summary table at the end of this document for calculations.

§ 60.16 Additional Qualifications for a Currently Qualified FSTD.

This section sets out the requirements for sponsors to submit to the National Simulator Program Manager, a summary of all modifications to a qualified FSTD and/or notification of seeking additional qualifications. This is a one-time effort only without a continuing cost impact once completed. The number of notifications expected under this section is 200 per year with 50% requiring a change to the MQTG. The Management Representative will spend 0.5 hours in drafting a letter to the NSPM and a clerk would spend 0.1 preparing the letter for mailing for a total effort of 120 hours. For additional tasks (beyond those originally qualified) that require qualification test guide modification, the Management Representative would spend 0.25 hours in developing an appropriate change for a total of 25 hours. The combined total would be 145 hours [120 + 25].

See Table 5 and the Summary table at the end of this document for calculations.

Some of these hours can be attributed to the proposed revision to part 60 and are discussed immediately below with more details presented separately in question 15.

In the proposal to update Part 60, FSTD Directive #2 was introduced that will require Sponsors of previously qualified FSTDs to evaluate and modify FSTDs in order to qualify an FSTD to be used to conduct full stall, upset recovery, icing, gusting crosswind, and bounced landing recovery training. The compliance period has been proposed for three years after the publication of the final rule. The reporting of compliance for each of the five training tasks under the Directive will have a one-time information collection burden as described in § 60.16 and § 60.23. The training tasks described above are only required of air carriers, so it is expected that only Sponsors of Level C and Level D FSTDs used for air carrier training will report such modifications to comply with the FSTD Directive. At the time of this proposal, an estimated 322 previously qualified FSTDs may require modification in accordance with the Directive. Because compliance may be reported separately for each of the five training tasks, it is estimated that up to 1610 individual notifications may be required over the three year compliance period, resulting in an average of 537 additional notifications per year. Since each modification under the FSTD Directive will require an amendment to the MQTG, this additional one-time information collection burden will be approximately 1,369 hours distributed over the three year compliance period [322 * 5 * 0.85].

More details are presented under Question 15.

§ 60.19 Inspection, Maintenance, and Recurrent Evaluation Requirements.

1. The first Sub-Section requires sponsors to conduct objective testing of each FSTD in a minimum of four segments each year as described in the appropriate Qualification Performance Standard document. This testing, which is mostly automated would take an FSTD technician 0.1 hours per test. The number of tests required depends largely on the fidelity of the device. For a detailed calculation see the table at the end of this document. The total effort required on a continuing basis is 8,224 hours. Some of these hours can be attributed to the proposed revision to part 60 and are discussed separately in question 15.

2. The second Sub-section also requires a functional preflight check be completed prior to use each 24 hour period. FSTD usage is estimated at five days per week for each level device and the preflight check would take an FSTD technician 0.1 hours to document / record. The total estimate for pre-flight based on the time, usage, and number of devices is 20,358 hours per year.

3. The third sub-section requires that each FSTD be recurrently evaluated by the NSPM (typically each year). The Management Representative is required to contact the NSPM to schedule this evaluation which is estimated to take approximately 0.1 hours for each simulator. During the evaluation, an inspector will select objective tests (typically three) at random to be run. It will take a technician approximately 0.1 hours to run each test. The total effort estimate for this sub-section is 313 hours annually.

4. The fourth sub-section requires each sponsor to maintain a discrepancy log for each device. The sponsor must record a description, corrective actions, and the name and date of personnel taking action for each discrepancy. Approximately five to ten discrepancies per FSTD per week are recorded on average, depending on the level of fidelity, and the time required to record and update this information is 15 minutes. The total effort estimate for this sub-section is 30,306 hours annually.

See Table 7 and the Summary table at the end of this document for calculations.

§ 60.20 Logging FSTD Discrepancies.

This Section requires each instructor, check airman, or representative of the Administrator to document any discrepancies found. The estimate for the effort is included in section 60.19.

§ 60.23 Modifications to FSTDs.

This Section describes what must be done in order to modify a qualified FSTD as well as the procedure to follow. This section is essentially an expansion of section 60.16 and the estimate of the effort involved is included in the section for 60.16.

§ 60.25 Operation with Missing, Malfunctioning, or Inoperative Components.

This Section defines the requirements associated with missing, malfunctioning, or inoperative (MMI) components in an FSTD. An MMI is essentially a special type of discrepancy. The effort associated with discrepancy logs is included in 60.19 above. However, if an MMI cannot be repaired or replaced within 30 days, approval to extend the repair/replace time must be made by the NSPM. Approximately 220 extension requests as well as updates once repaired/replaced are made annually. Each request to extend an MMI will take the Management Representative 0.1 hours to make and another 0.1 hours to report completion of repair/replace. The total effort is calculated at 44 hours annually.

See Table 8 and the Summary table at the end of this document for calculations.

§ 60.31 Recordkeeping and Reporting.

1. This section requires the sponsor to maintain certain records.

(a) The time and costs of developing the Master Qualification Test Guide (MQTG) are addressed in the discussion on §60.15. No additional time or costs are involved.

(b) The time and costs of completing the quarterly objective tests and performance demonstrations are addressed in the discussion on §60.15. No additional time or costs are involved.

(c) The time and costs of completing the recurrent evaluations are addressed in the discussion on §60.19. No additional time or costs are involved.

(d) The time and costs of obtaining comments in accordance with §60.9(b)(1) are addressed in the discussion on §60.9.

(e) The time and costs of recording discrepancies are addressed in the discussions on §60.20. No additional time or costs are involved.

(f) The time and costs of recording modifications to the FSTD are addressed in the discussion on §60.23. No additional time or costs are involved.

The total estimated annual burden on the public is 68,509 hours. This is calculated by dividing the initial, one-time burden of 16,234 by 3 (for the 3-year clearance period, 5,411 hours) and adding it to the 63,098 recurring annual burden hours (5,411 + 63,098 = 68,509).

The total annualized cost for the respondents due to the 68,509 hours of information collection burden is estimated at $3,066,888.21. This estimation has been calculated as follows:

Employee	Wage Rate1	Total Annualized Hours2	Cost Basis
Management Representative	$73.74	6401	$472,009.74
Clerk	$29.70	2985	$88,654.50
Simulator Technician	$42.39	59123	$2,506,223.97
Total annualized cost to respondents:			$3,066,888.21

We approximate that we will receive a total of 16 to 17 requests for evaluation from each of the 46 Flight Simulation Device Operators (FSTD) per year, for an estimated total of 759 responses.

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 capital, startup, or operational costs for this information collection that are not already described in the previous section. The information collection and reporting requirements in this rule can be conducted through customary and usual business practices. All of the mechanisms and processes that the FSTD sponsors need to collect this information are already in place and have been required since the original publication of part 60 in 2008.

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

The estimates for hours and costs are broken down by sections of the rule below. For a cumulative estimate of the hours, see the summary table at the end of this statement.

§ 60.5 Quality Management System.

The burden estimate to the government associated with this section is limited to the review/approval of QMS policies, processes, and procedures as well as the evaluation of the sponsor’s QMS program on-site. The following is the breakdown by initial verses continuing costs.

Initial Cost

Review/Approval

A program analyst will spend 10 hours reviewing policies, processes and procedures for 32 separate small sponsors, 14 hours reviewing 10 medium sponsors, and 240 hours reviewing 4 large sponsor programs. This is a total of 1,420 hours. At $65.96/hour, the one-time cost to the Federal Government is $93,663.

On-site Assessment

A program analyst will spend 14 hours assessing 32 separate small sponsor program, 14 hours assessing 10 medium sponsor programs, and 70 hours assessing 4 large sponsor programs. This is a total of 868 hours. At $65.96/hour, the one-time cost to the Federal Government is $57,253.

The total one-time cost to the government for this section is $150,916 ($50,305 annually over the three year clearance period).

Continuing Cost

Review/Approval

Periodic updates will be made to sponsor QMS programs which require review/approval by the NSPM. A program analyst will spend 0.5 hours reviewing policies, processes and procedure updates for 32 separate small sponsors, 0.5 hours reviewing updates for 10 medium sponsors, and 1 hour reviewing updates for 4 large sponsor programs. This is a total of 25 hours. At $65.96/hour, the annual cost to the Federal Government is $1,649.

On-site Assessment

Assessment visits are conducted every two years. It is therefore assumed that 50% of the sponsors will be reviewed annually. An Aviation Inspector will spend 10 hours assessing 16 separate small sponsor program and a program analyst will spend 2 hours with processing the records/assessment report. An Aviation Inspector will spend 10 hours assessing 5 medium sponsor programs and a program analyst will spend 2 hours with processing the records/assessment report. An Aviation Inspector will spend 50 hours assessing 4 large sponsor programs and a program analyst will spend 10 hours with processing the records/assessment report. This is a total of 246 hours. At $65.96/hour, the annual cost to the Federal Government is $16,226.

The total annual cost to the government for this section is $17,875.

§ 60.15 Initial Qualification Requirements.

The burden estimate to the government associated with this section is limited to the review, approval, and storage of electronic MQTGs (EMQTG). The following is the breakdown by initial verses continuing costs:

Initial Cost

Review/Approval/Storage

An Aerospace Engineer will spend 1 hour reviewing/approving and a clerk 0.08 hours managing the storage of 569 EMQTGs for a total burden of 614.5 hours. At $65.96/hour, the one-time cost to the Federal Government is $40,532 ($13,510.8 annually over the three year clearance period).

Continuing Cost

Review/Approval/Storage

An Aerospace Engineer will spend 0.5 hours reviewing/approving and a clerk 0.08 hours managing the storage of approximately 100 EMQTGs changes each year for a total burden of 58 hours. At $65.96/hour, the annual cost to the Federal Government is $3,825.68.

The total annual cost to the government for this section is $17,336.48.

§ 60.16 Additional Qualifications for a Currently Qualified FSTD.

The burden to the government associated with this section is an annual estimated cost only for the review/approval of modifications to the FSTD in order to accommodate additional qualifications.

An Engineer/Pilot will spend 0.5 hours reviewing notifications of change on 200 FSTDs each year. A clerk will spend 0.1 hours preparing and mailing a letter to the sponsor in reply to those requests. The total estimate of effort is 120 hours [200 x (0.5+0.1)]. Additionally, 80 FSTDs are expected to require an evaluation based on the level of change/modification requested. It will take an Aviation Inspector approximately 0.5 hours to document that evaluation for a total of 40 hours. The total burden estimate for this section is 160 hours. At $65.96/hour for an engineer/pilot and $35.64/hour for a clerk, the annual cost to the Federal Government is $10,554.

In addition to the estimated annual burden, FSTD Directive #2 will require up to 1610 FSTD one-time modification notifications to review over the three year compliance period. Since the proposed Directive will not require a dedicated on-site FSTD evaluation (will be combined with an already scheduled continuing qualification evaluation), no additional evaluation documentation will be necessary. Details on this burden are also presented in question 15. The total estimated burden for the FSTD Directive is 966 hours [1610 x (0.5+0.1)]. At $65.96/hour for the engineer/pilot and $35.64 for a clerk, the one-time cost to the Federal Government is $58,835 ($19,612 annually over the three year clearance period).

The total annual cost to the government for this section is $30,166.

§ 60.19 Inspection, Maintenance, and Recurrent Evaluation Requirements.

The estimate to the government associated with this section is limited to continuing cost only. Costs are related to the time it takes to review sponsor completed objective testing and the time related to reporting the results of continuing evaluations. The following is a breakdown by each component.

Objective Testing Review

An Aviation Inspector will spend 0.1 hours reviewing each of approximately 33% of all tests performed annually by the sponsor. The number of these tests will vary by level of device. The total burden estimate for this section is calculated at 2,719.4 hours. At $65.96/hour for an FAA FSTD Inspector the annual recurring cost to the Federal Government is $179,372.

Part of these costs may be attributed to the change in the part 60 rule resulting in the issuance of the FSTD Directive 2. The burden attributed specifically to these changes is discussed below in question 15.

Continuing Evaluations

A Program Manager will spend 0.1 hours reviewing requests for evaluations and drafting a reply. An Aviation Inspector will spend 0.5 hours preparing an evaluation report and 0.1 hours reviewing three additional objective tests, picked at random, during the evaluation. The time burden for this section is calculated at 704.7 hours. At $65.96/hours the total annual cost to the Government is $46,482.

The total annual cost to the Government for this section is $225,854.

§ 60.25 Operation with Missing, Malfunctioning, or Inoperative Components.

The burden estimate to the government associated with this section is limited to continuing cost only. Costs are related to the time it takes to review a sponsor’s MMI extension/report, enter it into a tracking/history database, and to clear the report once the MMI is corrected/repaired. It will take a clerk 0.1 hours to enter the report and 0.1 hours to clear once corrected. It will take an Aviation Inspector 0.1 hours to review. The total time burden for this section is calculated at 66 hours annually. At $65.96/hour for an Aviation Inspector and $35.64 for a clerk, the total annual cost to the Government is $3,019.

The total annual cost to the Federal Government for initial and continuing collection processing procedures is $344,555.48.

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

There is an increase to the level of effort estimated for sponsors and the Government in both one-time costs and continuing costs. These changes are made primarily to address the documentation and reporting of FSTD modifications required in FSTD Directive #2. Specific changes and adjustments are discussed section by section below.

60.5. No differences

60.9. No differences

60.13. No differences

60.15. No differences

60.16. There is a slight increase in the information collection burden for both the sponsor and the Government. This section was modified to include (but not exclusively) the information collection burden of reporting FSTD modifications required for compliance with FSTD Directive #2. This is a one-time reporting event that is expected to be distributed annually over the three year compliance period of FSTD Directive #2.

Change in Paperwork Burden due to reporting compliance with the Proposed FSTD Directive #2 (60.16, 60.23, and Appendix A, Attachment 6)

The following estimates of the cost burden of the proposed amendments to the part 60 rule use the following estimated wage rates.

Private sector burden

The paragraphs immediately below describe the increase in paperwork burden specifically associated with the proposed Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks (14 CFR 60).

In the proposal to update Part 60, FSTD Directive #2 was introduced that would require Sponsors of previously qualified FSTDs to evaluate and modify FSTDs in order to qualify an FSTD to be used to conduct full stall, upset recovery, icing, gusting crosswind, and bounced landing recovery training. The compliance period has been proposed for three years after the publication of the final rule. The reporting of compliance for each of the five training tasks under the Directive will have a one-time information collection burden as described in § 60.16 and § 60.23. The training tasks described above are only required of air carriers, so it is expected that only Sponsors of Level C and Level D FSTDs used for air carrier training will report such modifications to comply with the FSTD Directive (referred to as a notification). At the time of this proposal, an estimated 322 previously qualified FSTDs may require modification in accordance with the Directive. Because compliance may be reported separately for each of the five training tasks, it is estimated that up to 1610 individual (322 x 5 = 1610) notifications may be required over the three year compliance period, resulting in an average of 537 additional notifications per year. Each modification under the FSTD Directive would require an amendment to the MQTG. Each amendment would require a management representative spend 0.5 hours in drafting a letter to the NSPM and a clerk spend .1 hour preparing the letter for mailing. In addition, the management representative would spend .25 on additional tasks that require qualification test guide modifications for each notification. This additional one-time information collection burden would be approximately 1,369 hours distributed over the three year compliance period [322 * 5 * 0.85].

Federal Burden

Change in Paperwork Burden due to documentation of compliance with the Proposed FSTD Directive #2 (60.16, 60.23, and Appendix A, Attachment 6)

The paragraphs immediately below describe the increase in paperwork burden to the federal government specifically associated with the proposed Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks (14 CFR 60).

In the proposal to update Part 60, FSTD Directive #2 was introduced that would require Sponsors of previously qualified FSTDs to evaluate and modify FSTDs in order to qualify an FSTD to be used to conduct full stall, upset recovery, icing, gusting crosswind, and bounced landing recovery training. The government would have to review the resulting 1610 FSTD one-time notifications over the three year compliance period. Since the proposed Directive would not require a dedicated on-site FSTD evaluation (would be combined with an already scheduled continuing qualification evaluation), no additional evaluation documentation would be necessary. An Engineer/Pilot would spend 0.5 hours reviewing notifications of change and a clerk would spend .1 hour preparing and mailing a letter to the sponsor in reply to these requests. The total estimated burden for the FSTD Directive is 966 hours [1610 x (0.5+0.1)]. At a burdened rate of $65.96 an hour for the engineer/pilot ³ and a burdened rate of $35.64 an hour for the clerk, the one-time cost to the Federal Government would be $58,836 ($19,612 annually over the three year clearance period).

60.19. There is a slight increase in the information collection burden for both the sponsor and the Government. Because the additional objective testing requirements of the proposed changes to the QPS appendices and FSTD Directive #2 may require up to four additional objective tests to be reviewed and documented on an annual basis, the average number of required objective tests for Level C and Level D FSTDs was revised upward by four tests. Furthermore, the total number of qualified FSTDs was updated to reflect the latest list of FAA qualified FSTDs. Estimates of the increase in paperwork attributed to the proposed revision to the part 60 rule are presented separately in the sections above.

Change in Paperwork Burden due additional continuing inspection requirements of the proposed FSTD Directive #2 (60.19 and Appendix A, Attachment 6)

The paragraphs immediately below describe the increase in paperwork burden specifically associated with the proposed Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks (14 CFR 60) proposed rule. The cost estimates use the wage rates presented in question 60.16 above.

Private Sector Burden

Because the number of objective tests required to maintain FSTD qualification would increase slightly with this proposal, the annual information collection burden would also increase under the FSTD inspection and maintenance requirements of § 60.19. This additional information collection burden is estimated by increasing the average number of required objective tests for all Level C and Level D FSTDs by four tests⁴. For the estimated 322 FSTDs that may be affected by the FSTD Directive, this will result in an additional 129 hours of annual information collection burden to FSTD Sponsors. This additional collection burden is based upon 0.1 hours⁵ per test for a simulator technician to document as required by § 60.19.

For new Level C and Level D FSTDs qualified after the effective date of this rule, there would also be an increase of approximately four objective tests⁶ required to maintain FSTD qualification under § 60.19. For the estimated 22 new Level C and Level D FSTDs that may be initially qualified on an annual basis, this would result in an additional 9 hours of annual information collection burden to FSTD Sponsors. Note that this increase in annual testing required by § 60.19 has been reflected in Table 7 by increasing the average number of objective tests for all Level C and Level D FSTDs by four tests.

Federal Burden

The paragraphs immediately below describe the increase in paperwork burden to the federal government specifically associated with the proposed Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks (14 CFR 60) proposed rule.

Because the number of objective tests required to maintain FSTD qualification would increase slightly with the proposal , the annual information collection burden would also increase under the FSTD inspection and maintenance requirements of § 60.19. This additional information collection burden is estimated by increasing the average number of required objective tests for all Level C and Level D FSTDs by four tests⁷. The additional information collection burden to the Federal government would increase by approximately 43 hours⁸ due to the additional tests that may be sampled and reviewed by the FAA during continuing qualification evaluations.

For new Level C and Level D FSTDs qualified after the effective date of this rule, there would also be an increase of approximately four objective tests⁹ required to maintain FSTD qualification under § 60.19. For the estimated 22 new Level C and Level D FSTDs that may be initially qualified on an annual basis, this would result in an additional 3 hours of annual information collection burden to the Federal Government. Note that this increase in annual testing required by 60.19 has been reflected in Table 7 by increasing the average number of objective tests for all Level C and Level D FSTDs by one test (the FAA typically will spot check up to 33% of tests during a continuing qualification evaluation).

60.20. No differences

60.23. No differences

60.25. No differences

60.31. No differences

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.

SUPPORTING STATEMENT

OMB -2120-0680

Table 1, Cost In Hours for §60.5 (One-Time Cost)

	Small Sponsors	Medium Sponsors	Large Sponsors	Total Hours
Private Sector:
Document Policies, Processes, Procedures
Management Rep hours per Sponsor	56	112	720	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	1792	1120	2880	5792
Initial On-Site Assessment
Management Rep hours per Sponsor	12	12	60	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	384	120	240	744
Government:
Review/Document/Report Results of Program
Program Analyst hours to review/approve	10	14	240	--
Number of Sponsors	32	10	4	--
Total Time for Each Type of Sponsor	320	140	960	1420
Initial On-Site Assessment
Program Analyst hours to audit/document	14	14	70	--
Number of Sponsors	32	10	4	--
Total Time for Each Type of Sponsor	448	140	280	868

SUPPORTING STATEMENT

OMB -2120-0680

Table 2, Cost In Hours for §60.5 (Recurring Cost)

	Small Sponsors	Medium Sponsors	Large Sponsors	Total Hours
Private Sector:
Policy, Process, Procedure Changes
Management Rep hours per Sponsor	0.5	0.5	1	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	16	5	4	25
Self-Assessments
Management Rep hours per Sponsor	3	6	39	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	96	60	156	312
Continuing On-Site Assessment
Management Rep hours per Sponsor	12	12	60	--
Number of Sponsors	16	5	2	--
Time for Each Type of Sponsor	192	60	120	372
Independent Feedback
Responses/Feedback items per year	360	720	3600	--
Management Rep hours per Sponsor	0.08	0.08	0.08	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	960	600	1200	2760
Identify Management Representative
Hours to notify NSPM of MR change	0.08	0.08	0.08	--
Number of changes per year	1	1	1	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	2.7	0.8	0.3	3.8
Regular Briefings to Sponsor Management
Hours to brief	0.5	0.5	1	--
Number of briefings per year	4	4	4	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	64	20	16	100

SUPPORTING STATEMENT

OMB -2120-0680

Table 2, Cost In Hours for §60.5 (Recurring Cost) - Continuing

	Small Sponsors	Medium Sponsors	Large Sponsors	Total Hours
Government:
Policy, Process, Procedure Changes
Program Analyst hours to review/approve	0.5	0.5	1	--
Number of Sponsors	32	10	4	--
Time for Each Type of Sponsor	16	5	4	25
Continuing On-Site Assessment
Program Analyst hours to audit/document	2	2	10	--
Aviation Inspector hours to audit/document	10	10	50	--
Number of Sponsors	16	5	2	--
Time for Each Type of Sponsor	192	60	120	372

Table 3, Cost In Hours for §60.15 (One-Time Cost)

	Level 5	Level 6	Level 7	Level A	Level B	Level C	Level D	Total Hours
Private Sector:
Convert MQTG to Electronic Format
Clerk hours to convert each page of MQTG	0.01	0.01	0.01	0.01	0.01	0.01	0.01	--
Number of pages to convert	500	1000	2000	1000	1000	1500	2000	--
Number of current FSTDs	0	34	36	13	12	159	315	--
Time for Each Type of Device	0	283.3	600.0	108.3	100.0	1987.5	5250.0	8329.2
Government:
Review/Storage of MQTG
Aerospace Engineer hours to review	1	1	1	1	1	1	1	--
Clerk hours to store	0.08	0.08	0.08	0.08	0.08	0.08	0.08	--
Number of current FSTDs	0	34	36	13	12	159	315	--
Time for Each Type of Device	0	36.8	39.0	14.1	13.0	172.3	341.3	616.4

Table 4, Cost In Hours for §60.15 (Recurring Cost)

	Level 5	Level 6	Level 7	Level A	Level B	Level C	Level D	Total Hours
Private Sector:
Convert MQTG to Electronic Format
Clerk hours to convert each page of MQTG	0.01	0.01	0.01	0.01	0.01	0.01	0.01	--
Changes to MQTG each year	14	14	14	14	14	14	14	--
Number of pages to convert	2	2	2	2	2	2	2	--
Number of current FSTDs	0	34	36	13	12	159	315	--
Time for Each Type of Device	0	8.1	8.6	3.1	2.9	37.9	75	135.5
Government:
Review/Storage of MQTG
Aerospace Engineer hours to review	0.5	0.5	0.5	0.5	0.5	0.5	0.5	--
Clerk hours to store	0.08	0.08	0.08	0.08	0.08	0.08	0.08	--
Changes to MQTG each year	14	14	14	14	14	14	14	--
Time for Each Type of Device	8.3	8.3	8.3	8.3	8.3	8.3	8.3	58.3

Table 5, Cost In Hours for §60.16 (Recurring Cost)

	Total Hours
Private Sector:
Additional Tasks / Modifications
Number of notifications per year	200
Management Rep hours to draft letter	0.5
Clerk hours to prepare / mail letter	0.1
Number of additional tasks/mods that require MQTG change	100
Management rep hours to make / insert MQTG change	0.25
Time for Each Sponsor	145
Government:
Additional Tasks / Modifications
Number of notifications per year	200
Aerospace Engineer hours to review	0.5
Clerk hours to prepare / mail response	0.1
Number of additional tasks/mods requiring evaluation	80
Aviation Inspector hours to draft/present report	0.5
Time for Each Sponsor	160

Table 6, Cost In Hours for §60.16 (FSTD Directive #2 - One Time Cost)

	Total Hours
Private Sector:
Additional Tasks / Modifications
Number of notifications	1610
Management Rep hours to draft letter	0.5
Clerk hours to prepare / mail letter	0.1
Number of additional tasks/mods that require MQTG change	1610
Management rep hours to make / insert MQTG change	0.25
Time for Each Sponsor	1369
Government:
Additional Tasks / Modifications
Number of notifications per year	1610
Aerospace Engineer hours to review	0.5
Clerk hours to prepare / mail response	0.1
Number of additional tasks/mods requiring evaluation	0
Aviation Inspector hours to draft/present report	0
Time for Each Sponsor	966

SUPPORTING STATEMENT

OMB -2120-0680

Table 7, Cost In Hours for §60.19 (Recurring Cost)

	Level 5	Level 6	Level 7	Level A	Level B	Level C	Level D	Total Hours
Private Sector:
Objective Testing
Number of FSTDs	55	54	5	13	12	151	493	--
Number of tests conducted	20	28	46	58	78	100	127	--
Simulator Tech hours per test	0.1	0.1	0.1	0.1	0.1	0.1	0.1	--
Time for Each Type of Device	110	151.2	23	75.4	93.6	1510	6261.1	8224.3
Functional Pre-Flight
Number of FSTDs	55	54	5	13	12	151	493	--
FSTD usage (5 days x 52 wks)	260	260	260	260	260	260	260	--
Number of pre-flights conducted (FSTD # x usage)	14300	14040	1300	3380	3120	39260	128180	--
Simulator Tech hours to document each pre-flight	0.1	0.1	0.1	0.1	0.1	0.1	0.1	--
Time for Each Type of Device	1430	1404	130	338	312	3926	12818	20358
Continuing Evaluations
Number of FSTDs	55	54	5	13	12	151	493	--
Management Rep hours to draft/send eval request	0.1	0.1	0.1	0.1	0.1	0.1	0.1	--
Simulator tech hrs to print/present additional tests	0.1	0.1	0.1	0.1	0.1	0.1	0.1	--
Number of additional tests run during evaluation	3	3	3	3	3	3	3	--
Time for Each Type of Device	22	21.6	2	5.2	4.8	60.4	197.2	313.2
Maintain a Discrepancy Log
Number of FSTDs	55	54	5	13	12	151	493	--
Number of discrepancies per week per FSTD	5	5	10	10	10	10	10	--
Simulator Tech hrs to record/update each	0.08	0.08	0.08	0.08	0.08	0.08	0.08	--
Time for Each Type of Device	1144	1123	208	541	499	6282	20509	30306

SUPPORTING STATEMENT

OMB -2120-0680

Table 7, Cost In Hours for §60.19 (Recurring Cost) - Continuing

	Level 5	Level 6	Level 7	Level A	Level B	Level C	Level D	Total Hours
Government:
Objective Testing
Number of FSTDs	55	54	5	13	12	151	493	--
Number of tests reviewed	7	9	15	19	26	33	42	--
Aviation Inspector hours to review each test	0.1	0.1	0.1	0.1	0.1	0.1	0.1	--
Time for Each Type of Device	38.5	48.6	7.5	24.7	31.2	498.3	2070.6	2719.4
Continuing Evaluations
Number of FSTDs	55	54	5	13	12	151	493	--
Program Manager hours to draft/send eval request reply	0.1	0.1	0.1	0.1	0.1	0.1	0.1	--
Aviation Inspector hrs to draft/present report	0.5	0.5	0.5	0.5	0.5	0.5	0.5	--
Number of additional tests run during evaluation	3	3	3	3	3	3	3	--
Aviation Inspector hrs to review each additional test	0.1	0.1	0.1	0.1	0.1	0.1	0.1	--
Time for Each Type of Device	49.5	48.6	4.5	11.7	10.8	135.9	443.7	704.7

SUPPORTING STATEMENT

OMB -2120-0680

Table 8, Cost In Hours for §60.25 (Recurring Cost)

	Total Hours
Private Sector:
MMI Reporting
Number of MMIs reported per year	220
Management Rep hours to document and report	0.1
Management rep hours to update and/or clear	0.1
Time for Each Sponsor	44
Government:
MMI Reporting
Number of MMIs reported per year	220
Clerk hours to enter into database and file report	0.1
Aviation Inspector hours to review	0.1
Clerk hours to enter clearance into database and file report	0.1
Time for Each Sponsor	66

Summary

Paperwork Reduction

Cost to the Sponsor and the Government

(Presented in Hours)

Relevant Section of Part 60	Initial Cost in Hours						Annual Recurring Cost in Hours
	To Sponsors			To Government			To Sponsors			To Government
	2012	Now	Change	2012	Now	Change	2012	Now	Change	2012	Now	Change
§60.5	6,536	6,536	0	2,288	2,288	0	3,573	3,573	0	397	397	0
§60.91	0	0	0	0	0	0	0	0	0	0	0	0
§60.132	0	0	0	0	0	0	0	0	0	0	0	0
§60.153	8,329	8,329	0	616	616	0	135	135	0	58	58	0
§60.164,5	145	1,369	1,224	160	966	806	0	145	145	0	160	160
§60.196,7	------------------------------Not Applicable---------------------------						58,084	59,201	1,117	3,268	3,424	156
§60.208	------------------------------Not Applicable---------------------------						0	0	0	0	0	0
§60.23	------------------------------Not Applicable---------------------------						0	0	0	0	0	0
§60.25	------------------------------Not Applicable---------------------------						44	44	0	66	66	0
§60.31	0	0	0	0	0	0	0	0	0	0	0	0
Totals	15,010	16,234	1,224	3,064	3,870	806	61,836	63,098	1,262	3,789	4,105	316

1. Calculations are included within the calculations for §60.5.

2. Calculations are included within the calculations for §60.15 and §60.16.

3. Calculations based on 569 FSTDs.

4. Reallocated estimated number of annual notifications into annual recurring costs

5. Added one-time initial cost of reporting compliance on FSTD Directive training tasks (within the 3 year compliance period)

6. Updated erroneous number of FSTDs per qualification level

7. Added an average of 4 additional objective test cases (for Level C and D simulators) to comply with FSTD Directive #2

8. Calculations are included within the calculations for §60.19.

Summary Paperwork Reduction due to Proposed Change to part 60 proposed Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks

1 See page 13 for wage rate data sources.

2 Detailed hourly breakdown between employee wage categories is defined in Table 1 through Table 8 of this document.

3 Equivalent GS is assumed to be GS 14 step one.

4 For previously qualified FSTDs, the requirements of FSTD Directive #2 will add a maximum of four additional objective test cases to the existing requirements.

5 The 0.1 hour burden is derived from the existing Part 60 Paperwork Reduction Act supporting statement (OMB-2120-0680), Table 6 (§ 60.19) and includes estimated time for the FSTD Sponsor’s staff to document the completion of required annual objective testing.

6 Comparison of the proposed QPS appendices with the current part 60 QPS appendices show that an average of four additional objective tests will be required. This is an average number because the actual number of tests may vary by FSTD.

7 For previously qualified FSTDs, the requirements of FSTD Directive #2 will add a maximum of four additional objective test cases to the existing requirements.

8 This information collection burden is based upon 0.1 hours per test required for FAA personnel to review. These four additional tests are subject to the approximately 33% of which may be spot checked by FAA personnel on site during a continuing qualification evaluation. [322 x.1 x 4 x 33% = 43

]

9 Comparison of the proposed QPS appendices with the current part 60 QPS appendices show that an average of four additional objective tests will be required. This is an average number because the actual number of tests may vary by FSTD.

17