SUPPORTING STATEMENT
for
Certification of Airmen for the Operation of Light-Sport Aircraft
2120-0690
Justification
Explain the circumstances that make the collection of information necessary.
The purpose of Title 49 United States Code, Subtitle VII, Aviation Programs, is to encourage and foster the development of civil aeronautics, and to promote safety in air commerce.
Section 40113(a) empowers the Secretary of Transportation (or the Administrator of the Federal Aviation Administration with respect to aviation safety duties and powers designated to be carried out by the Administrator) to take action he/she considers necessary to carry out this part, including conducting investigations, prescribing regulations, standards and procedures, and issuing orders.
Section 44701 empowers the Administrator to promote safety by prescribing minimum safety standards and regulations necessary for safety in air commerce. It also empowers the Administrator to grant an exemption from a requirement of a regulation‑if it is in the public interest.
Section 44702(a) specifies that applications shall be as the Administrator prescribes as to form, content, retention, and manner served.
Section 44702(d) empowers the Administrator to delegate to a qualified private person, or an employee under the supervision of that person, matters related to examination, testing and inspection necessary to issue a certificate; and issuing the certificate.
Section 44703 specifically empowers the Administrator to issue airman certificates to properly qualified persons.
Part 21
Federal Aviation Regulation (FAR) Part 21, Certification Procedures for Products and Parts, implements the provisions of 49 U.S.C., Subtitle VII, Sections 40113, 44701, 44702, and 44704, prescribing procedural requirements for the issue of of airworthiness approvals; the certificates; the issue of support airworthiness approvals; the issue of Technical Standard Orders; the related approval of materials, parts, processes and appliances; and rules governing the holder of such certificates and approvals.
Part 43
Federal Aviation Regulation (FAR) Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alterations, implements Section 44713(d)empowers the Administrator to make modifications in the system for processing forms for major repairs or alterations to fuel tanks and fuel systems of aircraft not used to provide air transportation. The purpose of these major repair and alteration forms is to ensure that a record is maintained that documents that the repair or alteration was performed using approved data that meets the aircraft’s or product’s type design standard.
Part 61
Title 49, United States Code, Section 44703 specifically empowers the Secretary of Transportation to issue airman certificates to properly qualified persons. This clearance request covers the burden imposed on airmen directly responsible for the control of light-sport aircraft. Each certificate issued specifies the capacity in which the holder is authorized to serve as an airman in connection with the operation of a light-sport aircraft.
Federal Regulations Part 61, Certification: Pilots, Flight Instructors, and Ground Instructors, prescribes minimum standards and requirements for the issuance of airman certificates, and they establish procedures for applying for airman certificates.
Part 65
Title 49, United States Code, Sections 44702 and 44703 empowers the Secretary of Transportation to issue airman certification and to specify the terms, conditions, and limitations, and to authorize the regulations that prescribe the reporting requirement discussed in this support statement. FAR Part 65 prescribes, among other things, rules governing the issuance of certificates for repairmen.
The information collected on the submitted forms is evaluated by the FAA and is necessary for issuing a certificate and/or rating. Certification is necessary to ensure qualifications of the applicant.
FAA has estimated the action will require the registration of an estimated 23,160 repairman over ten years (19,200 repairman-inspection/3,960 repairman- maintenance). The FAA estimates the annual response to be 2,316 (10%).
Part 183
Title 49, United States Code, Section 44702, states that the Secretary of Transportation may, subject to such regulations as he may prescribe, delegate to any properly qualified private person, the examination and testing necessary for issuance of certificates.
Part 183 of the federal regulations (14 CFR 183), Representatives of the Administrator, implements the provisions of Section 44702. Part 183 of the federal regulations describes the requirements for delegating to private individuals the authority to examine and test persons for the purpose of issuing airman certifications to those individuals.
In addition to the regulatory basis, the purpose of this information collection is to make designated examiners readily available to the public, especially in those areas where Federal Aviation Administration (FAA) inspector resources are limited.
This final rule required the addition of designated pilot examiners to certificate sport pilots and flight instructors with a sport pilot rating who are qualified in these new light sport aircraft. Also, it will require additional designated airworthiness representatives to issue experimental airworthiness certificates for the 15,300 existing light sport aircraft and the 13,100 special, light-sport and experimental, kit-built airworthiness certificates for the newly manufactured light-sport aircraft over the course of ten years. The annual response rate is to issue experimental airworthiness certificates for the 1,530 existing light sport aircraft and the 1,310 special, light-sport and experimental, kit-built airworthiness certificates for the newly manufactured light-sport aircraft.
This information collection supports the Department of Transportation's strategic goals on safety and security. This collection is fundamental in order to promote the public health and safety by working toward the elimination of transportation‑related deaths, injuries, and property damage.
2. Indicate how, by whom, and for what purpose the information would be used.
Part 21
FAA designated inspectors confirm the appropriate manufacturer’s self-certification is presented with the aircraft, and inspects the aircraft to confirm that it is in a condition for safe operation. Those products that comply with the minimum requirement are issued the appropriate airworthiness certificate. The airworthiness certificate indicates to the purchaser of the aircraft that the product was designed and produced in compliance with the referenced industry developed consensus airworthiness standards. This will permit the purchaser of the aircraft to use the aircraft for purposes of flight instruction and rental for pilot proficiency training. This will lead to a higher skill level and resulting higher level of safety for the owners and operators of these aircraft.
It is expected that over the next ten years these aircraft will be certificated and hold these new airworthiness certificates:
Existing
15,300 (14,000 + 1300) Experimental light-sport aircraft (ELSA) (21.191(i)(1)
14,000 – No compensation or hire
1,300 – Training aircraft
The existing fleet will be replaced at an annual rate of 10%.
New (other than replacement aircraft)
In the first year 25% of new light-sport aircraft will be factory-built (i.e. special) and 75% will be kit-built (experimental); in the second and third years, half will be factory-built and half will be kit-built; and in all the subsequent years, 75% of new aircraft will be factory-built and 25% will be kit-built. Over the ten years examined by this analysis, of the 13,100 new aircraft (one for each new pilot and flight instructor, about 70% will be factory-built and 30% will be kit-built.
Annual impact:
Existing
1,530 (1400 + 130) Experimental light-sport aircraft (ELSA) (21.191(i)(1))
1,400 – No compensation or hire
130 – Training aircraft
New
Of 1,310 new aircraft, on average, about 70% will be factory-built and 30% will be kit-built.
Part 43
Form 337 for major repairs and major alterations will only be used if the special light sport aircraft has a major repair or major alteration performed on a FAA approved product installed on that aircraft. The form is filled out by a person certificated under part 65. The purpose of the form is to ensure that the repair or alteration to a FAA approved product or appliance has been accomplished in accordance with approved data and the product or appliance meets its type design standard.
Part 61
The Airman certificate and/or Rating Application Form and the required records/logbooks/statements required by the federal regulations are submitted to Federal Aviation Administration (FAA) district offices or its representatives to determine qualifications of the applicant for issuance of a pilot or instructor certificate, rating, privilege, or authorization.
There are approximately 28,400 pilots and flight instructors who will seek certification. Approximately 2,840 of these pilots and flight instructors (2,600 pilots/240 flight instructors) are estimated to provide data on an annual basis. Flight instructor certificates must be renewed every 24 months to remain effective.
Average No. of Sport Pilots (SP) and Flight Instructors (FI) Impacted Annually
|
EXISTING SPs EXISTING FIs NEW SPs NEW FIs AVG. YEARLY TOTAL
|
3407 560 2347 450 6764
|
Applicants for a new certificate for the student pilot, sport pilot, ground, and flight instructor with a sport pilot rating or new category or class privileges are required to submit FAA Form 8710-11, Sport Pilot Airman Certificate and/or Rating Application.
(The FAA used FAA Form 8710-1, Airman Certificate and/or Rating Application, in the regulatory evaluation. This form will not be used, a new form that is applicable only to the pilot certification activity conducted as a result of this rulemaking will be used. That form is FAA Form 8710-11, Sport Pilot Airman Certificate and/or Rating Application. However, because FAA Form 8710-11 had not yet been approved, the FAA used FAA Form 8710-1 in the regulatory evaluation.) If the information collection was not conducted, the FAA would be unable to issue the appropriate certificates and ratings.
Part 65
Applicants for repairman must complete and submit FAA Form 8610‑2, Airman Certificate and/or Rating Application, to the appropriate FAA district office for review and certificate eligibility determination. If the applicant meets the certification requirements, the requested certificate is issued. FAA Form 8610‑2 is used for original certification of repairman whenever they apply. It is also used for additional ratings.
The FAA has estimated the action will require the registration of an estimated 23,760 repairman over ten years (19,200 repairman-inspection, 3,960 repairman-maintenance). The FAA estimates the annual response to be 2,316 (10%).
Average No. of Repairman Impacted Annually
|
Repairman Repairman Annual TOTAL Inspection Rating Maintenance Rating 1,920 396 2,316 |
Part 183
This rule will require the addition of new designated examiners and will require modifications to the forms listed below. Collection of this information is for the purpose of obtaining essential information concerning the applicants' professional and personal qualifications. The FAA uses the information provided to screen and select the designees who act as representatives of the Administrator in performing various certification and examination functions.
The collection of information is accomplished by use of the following forms:
(a) Form 8110‑14. Statement of Qualifications (DAR – ODAR – DMIR - DER). The designated representatives impacted by this rule:
• DAR ‑ Designated Airworthiness Representative
(b) FAA Form 8110‑28, Statement of Qualifications (DME‑DPRE‑DAR‑ODAR). The designated representatives impacted by this rule:
• DAR ‑ Designated Airworthiness Representative
(c) FAA Form 8710‑12. Light-Sport Standardization Board-Designated Pilot Examiner Candidate Application. The designated examiners impacted by this rule:
DPEs – Sport pilot Examiners and Sport Pilot Flight Instructor Examiners (SPE and SFIEs).
(The FAA stated, in the regulatory evaluation, that Form 8710-6 and FAA Form 8710-10 would be used to collect this data. They are both existing forms used to establish qualifications and make application to become a designated pilot examiner. The FAA is now using a new form, FAA Form 8710-11, that will only be used by Sport pilot Examiners and Sport Pilot Flight Instructor Examiners (SPE and SFIEs) to collect this information.
3. Describe any consideration of the use of improved information technology to reduce burden and any technical or legal obstacles to reducing burden.
Part 21
Efforts are ongoing to improve information technology through internal automation systems designed to collect, organize, store, and transmit diverse information. We are working with industry to develop systems for allowing on-line data entry of safety reporting data to reduce burden in industry. Currently, in compliance with the Government Paperwork Elimination Act (GPEA), 100% of the information collection is available electronically through pdf-fillable forms and online data bases.
Part 43
FAA estimates that the need to fill out the Form 337 for major repairs or major alteration for special light sport aircraft will average from 50 to 100 a year. FAA Form 337 is available in pdf-fillable format on the FAA website. (http://www.faa.gov/). Once on the home page, you would click on “Access FAA Forms. The burden for form 337 is approved under OMB control number 2120-0020.
Part 61, Part 65, Part 183
At the present time, there are two methods available to evaluate an applicant's qualifications. One is a review of the form completed and signed by the applicant and the other is a major automation initiative being developed by the FAA. The initiative is defined as Integrated Airman Certification and Rating Application (IACRA).
The system is now complete and is fully implemented, and the use electronic signatures has been authorized. All airmen that will be issued airman certificates under this rulemaking initiative will be utilizing IACRA. The IACRA initiative incorporates the capability of the applicant and the designee to digitally sign the airman application for a designee to meet the initiatives of the Government Paperwork Reduction Act (GPEA) P.L. 105-277, Title XVII.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
Part 21
We have checked our other public reports and are satisfied that no duplication exists. No other agency is responsible for collecting information on the certification of aircraft products and parts. The rule revision specifically excludes existing type certificated aircraft from its applicability, so there is no duplication and only new categories of aircraft are subject to its data collection requirements.
The information requested by the FAA established a record of essential data concerning the applicant and product(s) involved and is available only from the applicant. The information is not available elsewhere.
Part 43
We have checked our other public reports and are satisfied that no duplication exists. No other agency is responsible for collecting information on major repairs and alterations made to individual aircraft or related products. The information requested by the FAA established a record of essential what kind of a major repair or major alteration data was performed, who performed the work, and what kind of approved data was used to perform the work, concerning the product(s) involved. This information is made part of the aircraft’s file in Aircraft registry in Oklahoma.
Part 61, Part 65, Part 183
We have reviewed other FAA public-use reports and find no duplication. Also, we know of no other agency collecting information from pilots and flight instructors prescribing the terms, conditions, and limitations of their operating certificates. This information is required under part 61 of the federal regulations.
5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
Part 21
The manufacturer of the aircraft is permitted to use any means or methods for recordkeeping that will support the manufacturer’s issuance of the statement of compliance. The information is not submitted to the government, nor is it submitted to the purchaser of the aircraft. It is retained by the manufacturer as process and product records.
Part 43
No information collected involves small business or other small entities Recording of major repairs or major alterations on form 337 is accomplished by a person certificated under part 65. The person may be a private individual or an employee of a small business. The single page, two sided form 337 has been used by the FAA and its predecessor agency CAA for over 60 years to document the major repair or major alteration performed on Type Certificated products. FAA estimates approximately 50 to 100 of these forms will be filled out annually to document major repairs or major alterations to special light aircraft.
Part 61, Part 65, Part 183
This information collection does not involve small businesses. It involves only individuals who are required to complete an application form.
6. Describe the consequences to Federal program or policy activities if the collection were conducted less frequently.
Part 21
The frequency of collection of this information is not a set time; it is established as needed by the respondent.
The frequency of collection of this information is not determined by a FAA mandated requirement. The recording of major repairs and major alterations is determined by the respondent as needed.
Part 61
The frequency of information collection is determined by the applicants who submit certification applications to the FAA. A decrease in the frequency of collection is governed by the applicant, not the FAA, unless safety dictates otherwise (i.e. numerous violations of the federal regulations).
Part 65
If the collection of this information were not conducted, FAA inspectors would not be able to determine applicant eligibility and qualifications. Without this determination, the appropriate certificate could not be issued.
Part 183
The information is collected only when the applicant wishes to apply for a designated examiner/representative position and such a designation is necessary to provide adequate certification service.
7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5(d)(2).
Part 21, Part 61, Part 65, Part 183
The collection of information is consistent with the guidelines in 5 CFR 1320.5(d)(2)(i)‑(viii), except records concerning aircraft registration which are maintained for the life of each aircraft. Consensus standards call for the manufacturer to permanently retain design and performance analysis information for safety of the product, and liability and marketability of the manufacturer’s design.
Part 43
The collection of information is consistent with the guidelines in 5 CFR 1320.5(d)(2)(i)‑(viii), except records concerning major alterations to the aircraft’s FAA approved product’s type design. These form 337s which are maintained by FAA registry and the owner for the life of each aircraft product installed on a special light sport aircraft.
8. Describe efforts to consult with person outside the Agency to obtain their views on the availability of data.
A notice was published in the Federal Register on May 29, 2015, vol. 80, no. 103, page 30757. No comments were received.
Explain why decision to provide any payment or gift to respondents, other than re‑enumeration of contractors or grantees.
Respondents are provided no payment or gift in connection with the information collection burden.
10. Describe any assurance of confidentiality.
Part 21, Part 43, Part 183
No assurance of confidentiality is provided or needed.
Part 61, Part 65
The information collected will become Part of the Privacy Act system of records DOT/FAA 847, General Aviation Records on Individuals and afforded the protection offered under the Privacy Act and that particular system.
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.
There are no sensitive questions in this collection of information.
Part 61
The Airman Certificate and/or Rating Application requires the applicant to respond to questions concerning a conviction under Federal or State statutes pertaining to narcotic drugs, marijuana, and or stimulant drugs or substance. This information is necessary to determine whether the applicant is in compliance with appropriate federal regulation 61 certification requirements.
12. Provide estimates of the hour burden of the collection of information. Provide estimates of cost to respondents for the hour burdens for collections of information.
Pilot and Instructor Certification
Over the ten years of the rule, the FAA assumes the following numbers:
Existing pilots – 14,000
Existing flight instructors – 1,300
New pilots – 12,000
New flight instructors – 1,100
New ground instructors – 18,670
Hence, in an average year, 1,400 existing pilots, 130 existing flight instructors, 1,200 new pilots, 110 new flight instructors, and 1,867 ground instructors will be subject to this rule. Pilots and instructors who will be replacing their aircraft over the next ten years are used in this analysis when appropriate. In an average year, 1,400 pilots and 130 instructors will replace their existing aircraft.
The FAA is using the following hourly wages, which include all fringe benefits:
DAR wage: |
$65.00 |
Management wage for manufacturer: |
$55.00 |
Pilot wage: |
$31.50 |
Instructor wage: |
$34.65 |
DPE wage: |
$100.00 |
Clerical wage for manufacturer: |
$17.93 |
The FAA is also using the following assumptions:
Percent of pilots with associations |
75% |
Percent of pilots not with associations |
25% |
Percent of Pilots and instructors that fail knowledge test |
10% |
Percent of Pilots and instructors that fail practical test |
10% |
Percent of instructors who buy training course from Associations, as the FAA assumes that it would be cheaper for them to buy the training courses from Associations rather than developing courses themselves |
100% |
Cost of the training |
$100 |
Part 21
This analysis of the cost to the public of the light-sport aircraft airworthiness certification program uses the following assumptions and data from the Regulatory Evaluation for this rulemaking project:
Approximately 14,000 existing light-sport aircraft operators and 1,300 existing light-sport aircraft flight instructors will obtain the "experimental - operating light-sport aircraft" certificate issued under §21.191(i)(1) over the course of three years (2 years to register the aircraft and 1 year after to certificate it).
Based on information from the program office, five eights of the manufacturers produce “simple” class products (powered parachute or weight-shift-control aircraft), while the rest produce “complex” class products (more typical (rigid fixed wing) airplanes). Given 45 manufacturers, the FAA assumes that 28 produce “simple” class products (2 new models per year per manufacturer), while the rest produce more complex class aircraft (1 new model per year per manufacturer).
This analysis assumes that the cost of the inspection required prior to issuance of an "experimental-operating light sport aircraft" certificate for an aircraft is either $350, if the inspection was performed at a workshop or the factory, or $650, if the inspection is not performed at a workshop or factory. If the inspection was performed at the workshop or factory, the inspector would be able to do several at once, and possibly charge a lower amount, hence, the FAA’s use of $350. In such a situation, the DAR will be available at a workshop especially designated for pilots wishing to bring in their existing light-sport aircraft to be issued an experimental certificate. The aircraft inspection and any other necessary paper work should be accomplished already or can be done on the spot. This means that the DAR should be able to inspect one aircraft after another without any delay or travel time costs. On the other hand, if he had to travel, he would have to charge for the travel time, hence, the FAA’s use of $650.
§21.190(b)(3) states that to be eligible for a special airworthiness certificate in the light-sport category, the aircraft must be inspected and found to be in a condition for safe operation. This cost is paid by the customer to obtain the inspection needed to obtain the special light-sport category airworthiness certificate. §21.191(i)(1) requires the applicant for an experimental airworthiness certificate for an existing aircraft that meets the light-sport aircraft definition must obtain that certificate within 3 years of the final rule.
§21.191(i)(2) applies to obtaining experimental certificates for eligible aircraft that have been assembled from a kit. The DAR will process the applications. As mentioned above, the total charge for the DAR is $350 if the inspection is performed at the factory or at a workshop, and $650 if the inspection is not performed at the factory or at a workshop. The FAA is assuming an average of about 5.4 hours per inspection for the former situation and 10 hours per inspection for the latter, given the DAR’s hourly rate of $65. The relevant table is Table 1 on page 40 of the Regulatory Evaluation.
The burden for these sections is covered under OMB #2120-0018.
§21.190(c)(2) states that the manufacturer must determine that the aircraft complies with the industry-developed consensus standard. FAA Form 8130-15 is available for the public, for providing this information. For the customer, there is no new cost. For each manufacturer, this is a recordkeeping requirement that applies for each new aircraft model produced for sale to customers.
Based on information from industry, the amount of time for determining that all applicable airworthiness requirements have been met for the project ranged from 12 hours for a simple project to 150 hours for a fairly complex project. Costs are calculated using this range of hours assuming that ¾ of the time will be supplied by management and ¼ by a clerical assistant. The relevant table is Table E.1 on page 172 of the Regulatory Evaluation.
Annualized cost burden:
- “simple” class products – 28 manufacturers X 2 new models X 12 hours per model X ($55 per hour x ¾ + $17.93 per hour x ¼) = $30,732
- more complex class aircraft – 17 manufacturers X 1 new model X 150 hours per model X ($55 per hour x ¾ + $17.93 per hour x ¼) = $116,618
- Total cost = $147,350
Annualized hour burden:
- “simple” class products – 28 manufacturers X 2 new models X 12 hours per model = 672 hours
- more complex class aircraft – 17 manufacturers X 1 new model X 150 hours per model = 2,550 hours
- Total hours = 3,222 hours
§21.190(c)(3) states that the manufacturer must determine that the aircraft conforms to the manufacturer’s design data using an acceptable quality assurance system. This cost applies only to the manufacturer of new aircraft seeking to obtain the special light sport aircraft airworthiness certificate. For the “simple” class aircraft, this is assumed to require two hours for recordkeeping, while for the more complex aircraft, this is multiplied a ratio of 12 equivalent to that used in the preceding cost item ("Complex" is 12 times the burden of "simple"). For the 1,980 aircraft per year, the average recordkeeping burden will be 10.3 hours per aircraft, which is derived by taking the average of 2 hours for the 28 manufacturers of “simple” aircraft and 24 hours for 17 manufacturers of “complex” aircraft. Costs are calculated using this range of hours assuming that ¾ of the time will be supplied by management and ¼ by a clerical assistant. The relevant table is Table E.2 on page 173 of the Regulatory Evaluation.
# respondents: 1,980
Annualized cost burden = 1,980 aircraft X 10.3 hours X ($55 per hour x ¾ + $17.93 per hour x ¼) = $932,669
Total time = 1,980 aircraft X 10.3 hours = 20,394 hours
§21.190(c)(5) requires manufacturers to monitor and correct safety-of-flight issues, using a continued airworthiness system that meets the identified consensus standard. The relevant table is Table E.6 on page 176 of the Regulatory Evaluation.
Annualized cost burden:
- “simple” class products – 28 manufacturers X 2 hours per model X ($55 per hour x ½ + $17.93 per hour x ½) = $2,042
- more complex class aircraft – 17 manufacturers X 24 hours per model X ($55 per hour x ½ + $17.93 per hour x ½) = $14,878
- Total cost = $16,917
Annualized hour burden:
- “simple” class products – 28 manufacturers X 2hours per model = 56 hours
- more complex class aircraft – 17 manufacturers X 24 hours per model = 408 hours
- Total time = 464 hours
Total cost = $16,917
Total hour burden = 464 hours
§21.190(c)(7) states that the manufacturer must have a final acceptance test procedure for evaluation of completed aircraft, and that records for each aircraft produced must show successful completion of the test procedure. This cost applies only to the manufacturer of new aircraft seeking to obtain the special light sport aircraft airworthiness certificate. For this analysis, inspection, test, and documentation for “simple” class aircraft is assumed to require one hour, while the same task for more complex aircraft is assumed to require three hours. Average required recordkeeping time is 1.75 hours, which is derived by taking the average of 1 hours for the 28 “simple” aircraft and 3 hours for 17 “complex” aircraft. Costs are calculated using this range of hours assuming that ¾ of the time will be supplied by management and ¼ by a clerical assistant. The relevant table is Table E.2 on page 173 of the Regulatory Evaluation.
# respondents – 1,980 aircraft annually
Total cost = 1,980 aircraft X 1.75 hours per aircraft X ($55 per hour x ¾ + $17.93 per hour x ¼) = $158,463
Total time = 1,980 aircraft X 1.75 hours per aircraft = 3,465 hours
Section |
Cost |
Hours |
Class Aircraft |
21.190(c)(2) |
$30,732 |
672 |
simple |
|
$116,618 |
2,550 |
complex |
21.190(c)(3) |
$932,669 |
20,394 |
|
21.190(c)(5) |
$16,917 |
464 |
|
21.190(c)(7) |
$158,463 |
3,465 |
|
Total |
$1,255,399 |
27,545 |
|
Part 61
A breakdown of the applicable sections of Federal Regulation Part 61 is listed below, showing the number of respondents impacted by this rule, frequency of response, annual hour burden, and how the burden has been estimated for the completion of FAA Form 8710-11 (the regulatory evaluation referenced FAA Form 8710-1) or required logbook endorsement.
Average No. of Sport Pilots (SP) and Flight Instructors (FI) Impacted Annually
|
EXISTING SPs EXISTING FIs NEW SPs NEW FIs AVG. YEARLY TOTAL
|
1,400 130 1,200 110 2,840
# of existing pilots with organizations (annual) – 1,050 # of existing instructors with organizations (annual) – 130 |
A. Costs of Training, Testing, and Registering Sport Pilots
§ 61.309 require a candidate for sport pilot certification to receive and log ground training on specified knowledge and proficiency areas. While the time spent in training is not a paperwork burden, the cost of the home study course is. The relevant tables are Tables 9A and 9B on page 55 of the Regulatory Evaluation.
# of existing pilots not with associations (annually) - 350
# of new pilots not with associations (annually) – 300
# of new pilots with associations (annually) - 900
Cost of home study course - $55
Paperwork burden = (350 + 300 + 900) x $55 = $85,250
§ 61.307 stipulates that one must take and pass a knowledge test in order to receive sport pilot certification. Before taking the knowledge test, the applicant must receive a logbook endorsement from an authorized instructor:
a) Each pilot must receive a logbook endorsement from an authorized instructor and all pilots must purchase a knowledge test ($90), and
b) For purposes of this evaluation, we estimate that 10% of the pilots will fail the knowledge test and be required to retake the test. Under § 61.49, an applicant who fails a knowledge or practical test may reapply for the test only after receiving training from an authorized instructor and a logbook endorsement from an authorized instructor. This includes repurchasing a knowledge test.
For a), as shown in Table 10 on page 58 of the Regulatory Evaluation:
# of existing pilots (annually) – 1,400
# of new pilots not with associations (annually) – 300
# of existing instructors (annually) - 130
Amount of time for logbook endorsement – 5 minutes
Cost of logbook endorsement to pilots and instructors = (1,400 + 300) x 5/60 x $31.50/hour + 130 x 5/60 x $34.65/hour = $4,838
Cost of logbook endorsement from instructors = (1,400 + 300 + 130) x 5/60 x $34.65 = $5,284
Cost of purchasing knowledge test = (1,400 + 300 + 130) x $90 = $164,700
Amount of time for logbook endorsement for pilots and instructors = (1,400 + 300 + 130) x 5/60 = 152.5 hours
Amount of time for logbook endorsement from instructors = (1,400 + 300+ 130) x 5/60 = 152.5 hours
Total Cost = $4,838 + $5,284 + $164,700 = $174,822
Total Time = 152.5 + 152.5 = 305 hours
For b), as shown in Table 11 on page 58 of the Regulatory Evaluation, the FAA assumes that 10% of the pilots will need to get logbook endorsements again as well as repurchasing the test.
# of existing pilots (annually) – 140
# of new pilots not with associations (annually) – 30
# of existing instructors (annually) – 13
Cost of logbook endorsement to pilots and instructors = (140 + 30) x 5/60 x $31.50/hour + 13 x 5/60 x $34.65 = $484
Cost of logbook endorsement from instructors = (140 + 30 + 13) x 5/60 x $34.65/hour = $528
Cost of purchasing knowledge test = (140 + 30 + 13) x $90 = $16,470
Amount of time for logbook endorsement for pilots and instructors = (140 + 30 + 13) x 5/60 = 15.25 hours
Amount of time for logbook endorsement from instructors = (140 + 30 + 13) x 5/60 = 15.25 hours
Total Cost = $484 + $528 + $16,470 = $17,482
Total Time = 15.25 + 15.25 = 30.5 hours
§ 61.329(a)(3) will allow ultralight pilots with FAA-recognized ultralight organizations to take the practical and knowledge tests without any additional flight training. They will have to provide the FAA with a certified copy of their ultralight pilot records from the organization. The relevant table is Table 12 on page 60 of the Regulatory Evaluation.
# of existing pilots with organizations (annual) – 1,050
# of existing instructors with organizations (annual) - 130
Average pilot/instructor time spent writing letter – 5 min.
Average pilot/instructor time to send certified copy to the DPE – 5 min.
Average clerical time needed to process letter – 10 min.
Postage - $0.37
Cost for pilots – 1,050 x ($31.50 x (10/60) + $0.37) = $5,901
Cost for instructors – 130 x ($34.65 x (10/60) + $0.37) = $799
Cost for clerk = 1,180 x ($17.93 x (10/60) + $0.37) = $3,963
Time for pilots = 1,050 x (10/60) = 175 hours
Time for instructors = 130 x (10/60) = 21.67 hours
Time for clerk = 1,180 x (10/60) = 196.67 hours
Total cost = $5,901 + $799 + $3,963 = $10,663
Total time = 175 + 21.67 + 196.67 = 393.33 hours
§ 61.311 requires that an applicant for a sport pilot certificate receive and log ground and flight training from an authorized instructor on certain areas of operation. The relevant tables are Tables 13A and 13B on page 64 of the Regulatory Evaluation.
# of existing and new pilots not with associations (annual) = 650
Average hours spent in training = 20
Average logbook endorsement = 5 minutes
Cost of logbook endorsements for pilots = 650 x 20 x (5/60) x 31.50 = $34,125
Cost of logbook endorsements for instructors = 650 x 20 x (5/60) x $34.65 = $37,538
Time for logbook endorsements (pilots and instructors) = 2 x 650 x 20 x (5/60) = 2,166.67
# of existing and new pilots with associations (annual) = 900
Average hours spent in training = 10
Average logbook endorsement = 5 minutes
Cost of logbook endorsements for pilots = 900 x 10 x (5/60) x 31.50 = $23,625
Cost of logbook endorsements for instructors = 900 x 10 x (5/60) x 34.65 = $25,988
Time for logbook endorsements (pilots and instructors) = 2 x 900 x 10 x (5/60) = 1,500
Total cost = $34,125 + $37,538 + $23,625 + $25,988 = $121,276
Total time = 2,166.67 + 1500 = 3,666.67
§ 61.13 requires the applicant for a pilot certificate and/or flight instructor certificate to submit FAA Form 8710-11 (the regulatory evaluation referenced FAA Form 8710-1) to the FAA district office or its representatives to determine qualifications of the applicant for issuance of a pilot or flight instructor certificate, rating, or authorization. Both pilots and instructors will need to work with an existing instructor in filling out the form. The relevant table is Table 14 on page 66 of the Regulatory Evaluation.
# of new and existing pilots (annual) – 2,600
# of existing instructors (annual) - 130
Time to fill out form for both pilot and instructor – 15 min.
Time for DPE to verify form – 10 min.
Cost to fill out application for pilots = (2,600 x 0.25 x $31.50) + (2,600 x 0.25 x $34.65) = $42,998
Cost to fill out applications for instructors = 2 x (130 x 0.25 x $34.65) = $2,252
Cost of DPE verifying information = (2,600 + 130) x (10/60) x $100 + (2,600 x (10/60) x $31.50) + (130 x (10/60) x $34.65) = $59,901
Time to fill out applications = 2 x (2,600 + 130) x 0.25 = 1,365 hours
Time for DPE to verify information = 2 x (2,600 + 130) x (10/60) = 910 hours
Total cost = $42,998 + $2,252 + $59,901 = $105,151
Total time = 1,365 + 910 = 2,275 hours
§ 61.39 - Except for 75 percent of new pilots and 100 percent of new instructors that will have taken the practical test through their associations, the rest of sport pilot candidates are required to take this test. The relevant tables are Tables 15 and 16 on page 68 of the Regulatory Evaluation.
a) As a prerequisite to taking the
practical test,
§ 61.39 states
that the applicant must have a logbook endorsement signed by an
authorized instructor, and each pilot must purchase the practical
test, which costs $200.
b) An estimated 10% who take the practical test may fail it. These pilots and instructors will need to reapply to take the test using FAA Form 8710-11 (the regulatory evaluation referenced FAA Form 8710-1) after failure, resulting in the logbook endorsement time and costs, as well as purchasing another practical test.
a) # of existing pilots (annual) – 1,400
# of new pilots (annual) – 1,200
# of existing instructors (annual) – 130
Time for logbook endorsement – 5 minutes
Cost of practical test = $200
Cost for pilots – (1,400 + 1,200) x $31.50 x (5/60) + ((1,400 + 1,200) x $200) = $526,825
Cost for instructors – (1,400 + 1,200 + 130) x $34.65 x (5/60) + (130 x $200) = $33,883
Time for pilots - (1,400 + 1,200) x (5/60) = 216.67
Time for instructors – (1,400 + 1,200 + 130) x (5/60) = 227.5
Total cost = $526,825 + $33,883 = $560,708
Total time = 216.67 + 227.5 = 444.17 hours
b) # of existing pilots (annually) – 140
# of new pilots not with associations (annually) – 120
# of existing instructors (annually) – 13
Amount of time to fill out form – ¼ hour
Cost of practical test = $200
Cost to pilots to fill out form = (140 + 120) x ¼ x $31.50/hour = $2,048
Cost to instructors to fill out form = 13 x ¼ x $34.65 = $113
Amount of time for pilots to fill out form = (140 + 120) x ¼ = 65 hours
Amount of time for instructors to fill out form = 13 x ¼ = 3.25 hours
Total Cost = $2,048 + $113 = $2,161
Total Time = 65 + 3.25 = 68.25 hours
Cost of logbook endorsement to pilots and purchase test = (140 + 120) x 5/60 x $31.50 + ((140 + 120) x $200) = $52,683
Cost of logbook endorsement to instructors and purchase test = (140 + 120 + 13) x 5/60 x $34.65 + (13 x $200) = $3,388
Amount of time for logbook endorsement for pilots = (140 + 120) x 5/60 = 21.67 hours
Amount of time for logbook endorsement for instructors = (140 + 120 + 13) x 5/60 = 22.75 hours
Total Cost = $52,683 + $3,388 = $56,071
Total Time = 21.67 + 22.75 = 44.42 hours
Totals for § 61.39:
Total Cost = $560,708 + $2,161 + $56,071 = $618,940
Total Time = 444.17 + 68.25 + 44.42 = 556.84 hours
The current rule (in § 61.56) requires pilots to take a flight review (BFR) every two years. This flight review includes a logbook endorsement, which generates a paperwork burden. The first BFR occurred in 2006 so the paperwork burden only occurs in 8 of the 10 years of this analysis. The relevant tables are Tables 17 and 18 on page 70 of the Regulatory Evaluation.
# of existing pilots (annual) = 5,600 (80% (8 of 10 years) of 7,000 to take into account that there will be no BFR in the first two years of this rule)
# of existing instructors (annual) = 520 (80% of 650 to take into account that there will be no BFR in the first two years of this rule)
# of new pilots (annual) = 1,600 (80% of 2,000 to take into account that there will be no BFR in the first two years of this rule)
Cost of logbook endorsement for pilots = (5,600 + 1,600) x $31.50 x (5/60) = $18,900
Cost of logbook endorsement for instructors = 520 x $34.65 x (5/60) = $1,502
Time for logbook endorsement for pilots = (5,600 + 1,600) x 5/60 = 600 hours
Time for logbook endorsement for instructors = 520 x 5/60 = 43.33 hours
Total cost = $18,900 + $1,502 = $20,402
Total time = 600 + 43.33 = 643.33 hours
§ 61.57 states that no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days. The number of pilots and instructors affected is cumulative. The relevant table is Table 19 on page 71 of the Regulatory Evaluation.
# of pilots affected – 2,600
# of instructors affected – 130
Time for logbook endorsement – 5 minutes
Number of logbooks endorsements per year - 12
Cost of logbook endorsements for pilots = 2,600 x 12 x (5/60) x $31.50 = $81,900
Cost of logbook endorsements for instructors = 130 x 12 x (5/60) x $34.65 = $4,505
Time for logbook endorsements for pilots = 2,600 x 12 x (5/60) = 2,600 hours
Time for logbook endorsement for instructors = 130 x 12 x (5/60) = 130 hours
Total cost = $81,900 + $4,505 = $86,405
Total time = 2,600 + 130 = 2,730 hours
The FAA requires FAA Form 8710-11, Sport Pilot Airman Certificate and/or Rating Application, (the regulatory evaluation referenced FAA Form 8710-1), be completed by the airman receiving this additional category or class privilege, and signed by the recommending instructor, and the authorized instructor conducting the proficiency check. The authorized instructor conducting the proficiency check will be required to submit the completed FAA Form 8710-11, Sport Pilot Airman Certificate and/or Rating Application, (the regulatory evaluation referenced FAA Form 8710-1) to the FAA upon satisfactory completion of the proficiency check. While this requirement will result in additional paperwork, the FAA has no record as to the number of sport pilots who would seek additional category and class ratings. Accordingly, the FAA is unable to estimate the cost and hour burden.
§ 61.309 – Training Courses:
a) Cost of Organizations to develop and maintain training courses for Pilots - This reflects the costs of an FAA-recognized ultralight organization to develop and maintain their training courses. The relevant table is Table E.9 on page 180 of the Regulatory Evaluation.
# of organizations = 4
Instructor time to develop the course (annual) = 7 hours
Clerical time to develop the course (annual) = 3 hours
Instructor time to maintain the course (annual) = 6.3 hours
Clerical time to maintain the course (annual) = 2.7 hours
Cost of instructor to develop & maintain the course = 4 x (7 + 6.3) x $34.65 = $1,843
Cost of clerical time to develop and maintain the course = 4 x (3 + 2.7) x $17.93 = $409
Time for instructor to develop and maintain the course = 4 x (7 + 6.3) = 53.2 hours
Time for of clerk to develop the course = 4 x (3 + 2.7) = 22.8 hours
Total cost = $1,843 + $409 = $2,252
Total time = 53.2 + 22.8 = 76 hours
b) Buying the training courses from the associations – The FAA assumes that every instructor will purchase a training course from an FAA-recognized ultralight organization. There is no hour burden.
# of instructors purchasing training courses (annual) = 11
Average cost for a training course = $100
Cost of buying the training courses = 11 x $100 = $1,100
Summary of the Costs of Training, Testing, and Registering Sport Pilots:
Part Number |
Number of Respondents |
Hours |
Costs |
Comment |
61.311, 319 |
1,550 |
N/A |
$85,250 |
|
61.307 |
1,830 |
305.00 |
$174,822 |
Initial |
61.307 |
183 |
30.50 |
$17,482 |
Retake the test |
61.329 (a)(3) |
1,180 |
393.33 |
$10,663 |
|
61.311 |
650 |
2,166.67 |
$37,538 |
Not with Associations |
61.311 |
900 |
1,500.00 |
$25,988 |
With Associations |
61.13 |
2,730 |
2,275.00 |
$105,151 |
|
61.39 |
1,830 |
444.17 |
$560,708 |
Initial |
61.39 |
183 |
112.67 |
$58,232 |
Retake the test |
61.56 |
7,720 |
643.33 |
$20,402 |
Flight Review (BFR) |
61.57 |
2,730 |
2,730.00 |
$86,405 |
|
61.309 |
4 |
76.00 |
$2,252 |
Develop and maintain |
61.309 |
11 |
N/A |
$1,100 |
Buy course |
TOTAL |
|
10,676.67 |
$1,185,993 |
|
B. Cost to become certified as a flight instructor with a sport pilot rating
Cost of the knowledge test - A person applying for a flight instructor certificate with a sport pilot rating must pass knowledge tests on the fundamentals of instructing, as listed in § 61.407(a) and the aeronautical knowledge areas listed in § 61.407(c). While there is no hour burden with this, there is a paperwork cost; the relevant table is Table 20 on page 74 of the Regulatory Evaluation:
# of existing and new instructors (annually) – 130
Cost of the knowledge test - $90
Total cost of purchasing training courses = 130 x $90 = $11,700
An estimated 10% who take the knowledge test may fail it. These pilots and instructors will need to reapply to take the test completing FAA Form 8710-11, Sport Pilot Airman Certificate and/or Rating Application, (the regulatory evaluation referenced FAA Form 8710-1)after failure, as well as repurchase the knowledge test; the relevant table is Table 21 on page 75 of the Regulatory Evaluation.
# of existing instructors (annually) – 13
Amount of time to fill out 8710-11 form – ¼ hour
Cost of the knowledge test - $90
Cost to fill out form and purchase knowledge test = (13 x ¼ x $34.65) + (13 x $90) = $1,283
Amount of time to fill out 8710-11 form = 13 x ¼ = 3.25 hours
§ 61.433 will not require ultralight instructors with FAA-recognized ultralight organizations to meet the aeronautical knowledge requirements, the flight proficiency requirements, and the aeronautical experience requirements; however, they have to meet the minimum total flight time requirements. They will have to submit a copy of their ultralight pilot records from the organization; the relevant table is Table 22 on page 77 of the Regulatory Evaluation.
# of existing instructors with organizations (annual) - 130
Average instructor time spent writing letter – 5 min.
Average instructor time to send certified copy to the DPE – 5 min.
Average clerical time needed to process letter – 10 min.
Postage - $1.11
Cost for instructors – 130 x ($34.65 x (10/60) + $1.11) = $895
Cost for clerk = 130 x $17.93 x (10/60) = $388
Time for instructors = 130 x (10/60) = 21.67 hours
Time for clerk = 130 x (10/60) = 21.67 hours
Total cost = $895 + $388 = $1,283
Total time = 21.67 + 21.67 = 43.33 hours
Flight training costs - The FAA estimates, on average, an applicant will need an additional 10 hours of flight training with an instructor before being ready for the practical test. Each of these tests requires a logbook endorsement; the relevant table is Table 23 on page 79 of the Regulatory Evaluation.
# of new instructors (annual) – 110
Hours of flight training experience – 10
Cost for new instructors – 110 x 10 x (5/60) x $31.50 = $2,888
Cost for instructors teaching the new instructors – 110 x 10 x (5/60) x $34.65 = $3,176
Time for instructors = 2 x 110 x 10 x (5/60) = 183.33 hours
Total Cost = $2,888 + $3,176 = $6,064
Cost of purchasing training courses - The FAA assumes all instructors will purchase the training curriculum that has been developed by the ultralight associations and other organizations; the relevant table is Table 24 on page 80 of the Regulatory Evaluation.
# of new and existing instructors (annual) = 240
Cost for training course = $100
Total cost = $24,000
Applying to become an instructor - The FAA estimates, on average, that an instructor and a DPE will each need ¼ hour for the paperwork for existing and new instructors to become an instructor; the relevant table is Table 25 on page 81 of the Regulatory Evaluation.
# of new instructors (annual) – 110
# of existing instructors (annual) - 130
Cost of applying = (110 x $31.50 x ¼) + (130 x $34.65 x ¼) + (240 x $100 x ¼) = $7,992
Time to apply = (240 x ¼) + (240 x ¼) = 120 hours
Practical tests for instructor candidates - Except for new instructors that will have taken the practical tests through their associations, the rest of candidates are required to take this test; the relevant tables are Table 26 and 27 on page 83 of the Regulatory Evaluation.
a) As a prerequisite to taking the practical test, the applicant must have a logbook endorsement signed by a DPE.
b) An estimated 10% who take the practical test may fail it. These instructors will need to reapply to take the test completing FAA Form 8710-11, Sport Pilot Airman Certificate and/or Rating Application, (the regulatory evaluation referenced FAA Form 8710-1) after failure.
a) # of existing instructors (annual) – 130
Time for logbook endorsement – 5 minutes
Cost for instructors – 130 x $34.65 x (5/60) = $375
Cost for DPE’s - 130 x $100 x (5/60) = $1,083
Time for instructors - 130 x (5/60) = 10.83
Time for DPE – 130 x (5/60) = 10.83
Total cost = $375 + $1,083 = $1,458
Total time = 10.83 + 10.83 = 21.67 hours
b) # of existing instructors (annually) – 13
Amount of time to fill out form – ¼ hour
Cost to instructors to fill out form = 13 x ¼ x $34.65 = $113
Time for instructors to fill out form = 13 x ¼ = 3.25 hours
Cost of logbook endorsement to instructors = 13 x 5/60 x $34.65/hour = $38
Cost of logbook endorsement to DPE = 13 x 5/60 x $100/hour = $108
Time for logbook endorsement for instructors = 13 x 5/60 = 1.08 hours
Time for logbook endorsement for DPE = 13 x 5/60 = 1.08 hours
Total cost = $113 + $38 + $108 = $259
Total time = 3.25 + 1.08 + 1.08 = 5.41 hours
For practical test:
Total cost = $1,458 + $259 = $1,717
Total time = 21.67 + 5.41 = 27.08 hours
§ 61.309 - Developing ground-training courses for instructors – The paperwork costs are included in the costs of training, testing, and registering sport pilots
Summary of costs to become certified as a flight instructor with a sport pilot rating:
Part |
Number of respondents |
Time |
Cost |
Comment |
61.407(a) |
130 |
|
$11,700 |
Cost of knowledge test |
|
13 |
3.25 |
$1,283 |
Reapply & retake test |
61.433 |
130 |
43.33 |
$1,283 |
|
|
110 |
183.33 |
$6,064 |
Flight training costs |
|
240 |
|
$24,000 |
Purchase training course |
|
240 |
120.00 |
$7,992 |
Apply to become instructor |
|
143 |
27.08 |
$1,717 |
Practical test for instructors |
TOTAL |
|
376.99 |
$54,039 |
|
Maintenance
Training to be a repairman with an inspection rating – All sport pilots who purchased kit-built aircraft will take the course. The FAA assumes that on an annual basis, 1,980 pilots will take this course. While there are no paperwork costs involved with taking the course per se, the cost of the course ($500) is a paperwork-related burden. Hence, total costs sum to $990,000 (calculation: 1,980 x $500).
Training to be repairmen with a maintenance rating - The FAA assumes that 20% of pilots who own factory built aircraft and all instructors who own factory built aircraft take a maintenance course at a cost of $2,816. On an annual basis, 396 pilots and instructors will take the course. As above, the cost of the course is a paperwork-related burden. Costs sum to $1,115,136 (calculation: 396 x $2,816).
Form 8610‑2 — Repairmen will have to complete Form 8610-2 in order to apply for the repairman certificate (light-sport aircraft) with an inspection rating or a maintenance rating. The relevant table is Table 32 on page 93 of the Regulatory Evaluation. The burden for this section is covered under OMB #2120-0022.
§ 43.11 prescribes maintenance record entries after any inspection performed in accordance with Part 91 (and other parts). § 91.319 will require that experimental light-sport aircraft being used for instruction have a 100 hour inspection, while § 91.327 will require that special light-sport aircraft have a 12-month condition inspection. Therefore, § 43.11 requires logbook endorsements of these aircraft because the inspection is performed in accordance with Part 91. Logbook endorsements are also required by the operating limitations after a condition inspection on an experimental aircraft. The relevant table is Table 33 on page 95 of the Regulatory Evaluation.
# of sport pilots with kit built aircraft (annual) = 9,723
# of sport pilots with manufactured aircraft (annual) = 513
# of instructors with manufactured aircraft (annual) = 922
Time for logbook endorsement = 5 minutes
Cost for pilots = (9,723 + 513) x $31.50 x 5/60 = $26,870
Cost for instructors = 922 x $34.65 x 5/60 = $2,662
Time for pilots = (9,723 + 513) x 5/60 = 853 hours
Time for instructors = 922 x 5/60 = 76.83 hours
Total cost = $26,870 + $2,662 = $29,532
Total time = 853 + 76.83 = 929.83 hours
Summary of maintenance-related costs:
Part |
Number of respondents |
Time |
Cost |
Comment |
|
1,980 |
|
$990,000 |
Inspection Rating |
|
396 |
|
$1,115,136 |
Maintenance Rating |
43.11 |
10,236 |
853.00 |
$26,870 |
Pilots |
43.11 |
922 |
76.83 |
$2,662 |
Instructors |
Total |
|
929.83 |
$2,134,668 |
|
Part 183 - Designated Airworthiness Representatives (DAR’s) and Designated Pilot Examiners (DPE’s)
The FAA estimated that the cost of completing applications and writing renewal letters for Designated Airworthiness Representatives (DAR’s) and Designated Pilot Examiners (DPE’s) relate to the forms 8110-14, 8110-28, and 8710-11:
FAA Form 8710‑12. Light-Sport Standardization Board-Designated Pilot Examiner Candidate Application. This is the form that will be used by new DPEs (SPE and SFIEs). (The FAA referenced in the regulatory evaluation that FAA Form 8710-6 and FAA Form 8710-10 would be used to collect this data).
a) Form 8110-14 deals with DAR applications and renewals, which are processed through the Manufacturer Inspection District Office (MIDO), as part of Office of Aircraft Certification (AIR). This burden is approved under OMB control number 2120-0033.
b) Form 8110-28 deals with the cost of applications and renewal letters, which are applied through the Flight Service District Offices (FSDO’s), as part of the Office of Flight Standards (AFS). This burden is approved under OMB control number 2120-0033.
c) Form 8710-12 (The FAA referenced in the regulatory evaluation FAA Form 8710-6 and FAA Form 8710-10) deals with the time that DPE’s need to process these forms. The FAA estimates that 5 DPE’s will need 30 minutes to process the forms. At $100 per hour, this sums to an annual cost of $$250, taking 2.5 hours. The relevant table is Table E.5 on page 176 of the Regulatory Evaluation.
§ 183.23 - Training of DPE’s - All sport pilot DPE’s will require special training. Because before sport pilots and flight instructors with a sport pilot rating can be certified there must be sport pilot designated pilot examiners (DPE’s). The relevant table is Table E.12 on page 183 of the Regulatory Evaluation.
# of DPE’s initially applying (annual) – 34.5
Time for DPE to fill out application FAA Form 8710-12 (The FAA referenced in the regulatory evaluation FAA Form 8710-6 and FAA Form 8710-10= 1 hour
Cost of knowledge test = $100
Postage per application = $0.37
Total cost = 34.5 x ($100 + $100 + $0.37) = $6,913
Total time = 34.5 x 1 = 34.5 hours
§ 183.33 - Training of DAR’s
The costs that designated airworthiness representatives will incur to become trained are included here in the aircraft certification discussion, because before light-sport aircraft can be certified there must be light-sport DAR’s to inspect and certify the aircraft. The relevant table is Table E.8 on page 179 of the Regulatory Evaluation.
# of DAR’s initially applying (annual) – 63
# of DAR’s reapplying (annual) – 12
Time for DAR to fill out application = 1 hour
Postage per application = $0.37
Total cost = (63 + 12) x (1 x $34.65 + $0.37) = $2,627
Total time = (63 + 12) x 1 = 75 hours
Summary of part 183 costs:
Part |
Number of respondents |
Time |
Cost |
Comment |
|
5 |
2.50 |
$250 |
8710-12 |
183.23 |
34.5 |
34.50 |
$6,913 |
|
183.33 |
74.9 |
75.00 |
$2,627 |
|
Total |
|
112 |
$9,790 |
|
Summary of all Burden Hours and Costs:
Part |
Time |
Cost |
Comment |
21 |
27,545 |
$1,255,399 |
|
61 |
10,676.67 |
$1,185,993 |
Pilots |
61 |
376.99 |
$54,039 |
Instructors |
|
929.83 |
$2,134,668 |
Maintenance |
183 |
112 |
$9,790 |
|
Total |
39,640.49 |
$4,639,889 |
|
|
|
|
|
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in items 12 and 14).
There are no additional startup costs associated with this collection not already included in item number 12.
Provide estimates of annualized cost to the Federal Government.
Aircraft certification – This includes the cost of working with industry to develop consensus standards, the cost of training Designated Airworthiness Representatives (DAR’s), the cost of appointing, supervising and renewing DAR’s, and the cost of aircraft registration which will include the cost of registering aircraft and assigning N-numbers.
Cost of Working with Industry to Develop Consensus Standards – The relevant table is Table 34 on page 98 of the Regulatory Evaluation.
# of employees – 2 full time the first year and 0.25 employees in subsequent years, averaging .425 employees per year
Loaded salary = $117,479
Cost of helping to develop consensus standards = .425 x $117,479 = $49,929
Time to help to develop consensus standards = .425 x 2080 = 884 hours
Appointing, supervising, and renewing a DAR - In order to certify aircraft a new type of light-sport aircraft Designated Airworthiness Representative (DAR) must be appointed, trained, supervised and renewed. The relevant table is Table 35 on page 100 of the Regulatory Evaluation.
Initial number of DAR's applying (annual) - 63
Number of DAR's reapplying (annual) – 12
Designee Process Coordinator prepares application package – 1 hour
FG-13 appointment activities – 7.75 hours
FG-14 appointment activities – 3.625 hours
FG-15 appointment activities – 0.625 hours
DAR's to be supervised (annual) – 125
FG-13 oversight activities – 27.4 hours
DAR's renewals (annual) - 60
FG-13 renewal activities – 2 hours
Cost of DAR’s applying and reapplying = (63 + 12) x ((1 x $47.80) + (7.75 x $47.80) + (3.625 x $56.48) + (0.625 x $66.44)) = $49,839
Time involved with DAR applying and reapplying = (63 + 12) x (1 + 7.75 + 3.625 + 0.625) = 975 hours
Cost of DAR’s to be supervised = 125 x 27.4 x $47.80 = $163,715
Time for DAR’s to be supervised = 125 x 27.4 = 3,425 hours
Cost of DAR’s renewal = 60 x 2 x $47.80 = $5,736
Time for DAR’s renewal = 60 x 2 = 120 hours
Total cost = $49,839 + $163,715 + $5,736 = $219,290
Total time = 975 + 3,425 + 120 = 4,520 hours
Aircraft Registration existing pilots, new pilots, exiting instructors, and new instructors must register their aircraft - The relevant table is Table 36 on page 101 of the Regulatory Evaluation.
Cost to assign a registration number = $12.00
Cost for a certificate of aircraft registration = $19.17
# of aircraft (annual) = 4,064
Cost of aircraft registration – 4,064 x ($12 + $19.17) = $126,675
Time for aircraft registration – Impossible to determine. The airman and aircraft registry contracts out part of costs of assigning a registration number and processing the aircraft registration certificate. Its bookkeeping is recorded as a certain cost per number assigned or certificate processed, and does not keep track of the amount of time that the contractor requires to do these tasks.
# of special numbers assigned (annual) – 15
Time to assign a special number – 1 hour by FG-10 personnel
Cost of assigning a special number = 15 x 1 x $30.52 = $458
Time for assigning a special number = 15 x 1 = 15 hours
Process the certification as to true copy of identification form - The relevant table is Table 38 on page 102 of the Regulatory Evaluation.
# of certification forms assigned (annual) – 10
Time to assign a certification form – 1 hour by FG-10 personnel
Cost of processing certification forms = 10 x 1 x $30.52 = $305
Time for assigning a special number = 10 x 1 = 10 hours
Summary of Aircraft Certification:
Activity |
Time |
Cost |
Develop Consensus Standards |
884.00 |
$49,929 |
Appointing, supervising, and renewing a DAR |
4,520 |
$219,290 |
Aircraft Registration |
N/A |
$126,675 |
Assigning a Special Number |
15.00 |
$458 |
True Copy of Identity |
10.00 |
$305 |
Total |
5,429 |
$396,657 |
Review and process original pilot applications (§ 61) - The relevant table is Table 42 on page 105 of the Regulatory Evaluation:
# of existing and new pilots (annual) – 2,970
Time to review and process the applications – 10 minutes
Total costs = 2,970 x (10/60) x $30.52 = $15,107
Total time = 2,970 x (10/60) = 495 hours
§61.13 - Cost of reviewing and processing original flight instructor applications and renewals - The relevant table is Table 42 on page 105 of the Regulatory Evaluation.
# of existing instructors (annual) - 240
Time per instructor – 20 minutes
Cost to review and process = 240 x $30.52 x (1/3) = $2,442
Time to review and process = 240 x (1/3) = 80 hours
Cost of airmen registration - The relevant table is Table 43 on page 106 of the Regulatory Evaluation:
# of airmen (existing pilots, new pilots, existing instructors, and new instructors) (annual) – 2,840
Cost to process each airmen certificate = $4.84
Cost to process average annual number of airmen certificates = 2,840 x $4.84 = $134757
Time to process certificates – Impossible to determine. The airman and aircraft registry contracts out part of costs of processing the airman registration certificate. Its bookkeeping is recorded as a certain cost per certificate processed, and does not keep track of the amount of time that the contractor requires to do these tasks.
Costs to Develop Practical Test Standards and Knowledge Test Standards to Test Airmen - The relevant table is Table E.16 on page 187 of the Regulatory Evaluation.
# of hours (annual) = 12
Cost to develop test standards = 12 x $56.48 = $678
Time to develop test standards = 12 hours
Summary of Pilot and Instructor Qualifications:
Activity |
Time |
Cost |
Review and Process – pilot |
495 |
$15,107 |
Review and Process - Instructor |
80 |
$2,442 |
Airmen Registration |
N/A |
$13,757 |
Develop Practical Test Standards |
12 |
$678 |
Total |
587 |
$31,984 |
Maintenance Provisions
Develop supporting materials for repairmen certification and inspection requirements - The relevant table is Table 44 on page 107 of the Regulatory Evaluation.
# of hours required (annual) – 132
# of employees required = 1 FG-15 employee
Cost to develop supporting materials = 132 x $66.44 = $8,770
Time to develop supporting materials = 132 hours
# of applications (annual) = 2,376
# of hours required = .25 hours (1 FG-14 employee)
Cost to review and process form = 2,376 x $56.48 x .25 = $33,549
Time to review and process form = 2,376 x .25 = 594 hours
The FAA will update the repairman paths in ACRA so that applicants for repairman light-sport aircraft can enter the 8610-2 information directly into ACRA. The relevant table is Table 46 on page 108 of the Regulatory Evaluation.
# of hours at M level for stand-alone program – 11
# of hours at O level for stand-alone program – 20
# of hours at M level to add functionality to the web based application - 30
# of hours at O level to add functionality to the web based application – 16
Total cost at M level = (11 + 30) x $47.36 = $1,942
Total cost at O level = (20 + 16) x $33.84 = $1,218
Total time at M level = 41 hours (annually)
Total time at O level = 36 hours (annually)
Summary of Maintenance Provisions:
Activity |
Time |
Cost |
Supporting Materials |
132 |
$8,770 |
Review and process form 8610-2 |
594 |
$33,549 |
Update ACRA |
77 |
$3,160 |
Total |
803 |
$45,479 |
Keep records to make sure that repairmen, DAR’s, and DPE’s have the proper training - The relevant table is Table 48 on page 112 of the Regulatory Evaluation.
# of respondents = 2,474
Time for each training record = 5 min. (FG-5 employees)
Cost of training records = 2,474 x (5/60) x $18.29 = $3,771
Time = 2474 x (5/60) = 206.2 hours
This rule will register new two-seat ultralights and unregistered ultralight-like aircraft. Accidents of these vehicles will be investigated, leading to additional accident investigation costs. The relevant table is Table 49 on page 114 of the Regulatory Evaluation.
# of airplanes (annual) = 2,730
Cumulative # of airplanes (annual) = 19,540
Cumulative # of accidents (annual)= 32
Time per accident for investigation = 17.7 hours
Cost per accident for investigation = $846
Annual Cost of accident investigation = 32 x $846 = $27,072
Annual Time for accident investigation = 32 x 17.7 = 566.4
Activity |
Time |
Cost |
Keep training records |
206.19 |
$3,771 |
Accident investigation costs |
566.4 |
$27,072 |
New sports pilot DPE |
124.80 |
7,522 |
Placing DPE's |
31.00 |
1,325 |
Total |
928.39 |
$39,690 |
Summary of all Burden Hours and Costs:
Category |
Time |
Cost |
Aircraft Certification |
5,429 |
$397,027 |
Pilot and Instructor Qualifications |
587 |
$31,984 |
Maintenance |
803 |
$45,479 |
Miscellaneous |
928.39 |
$39,690 |
TOTAL |
7,747.39 |
$514,180 |
15. Explain reasons for changes in burden, including the need for increase.
The burden associated with 14 CFR Part 47 that was previously included in this information collection request has been incorporated into the existing collection 2120-0042. This submission cites the use of form 8130-15 for the recordkeeping requirement in §21.190(c)(2); this does not add additional burden, only the use of the form to complete the requirement that was included in previous submissions. Additionally, Federal government processing costs for activities that have been completed have been removed from the Federal Government burden calculations.
16. For Collections of information whose results are planned to be published for statistical use, outline plans for tabulation, statistical analysis, etc.
There are no plans to publish this information for statistical or other purposes.
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.
The FAA is seeking approval to not display the expiration date. Due to the new technologies used to automate the completion, processing, and retention of these forms we do not want to impose an unnecessary need for software modifications.
The subject FAA forms are also recurring forms that are printed and stocked for continuous use. When the supply gets low, the forms are automatically reprinted and stocked so that there will be no interruption in services. It would not be cost effective to destroy unused, dated stock.
18. Explain each exception to the certification statement identified in Item 19, Certification of Paperwork Reduction Act Submissions, of OMB Form 83‑1.
No exception to the certification statement of OMB Form 83‑1 is requested.
| File Type | application/msword |
| Author | Jim & Sue Gardner |
| Last Modified By | Dahl, Taylor CTR (FAA) |
| File Modified | 2015-08-26 |
| File Created | 2015-05-20 |