The respondents to this collection are
current part 147 certificated AMTSs and applicants for a part 147
air agency certificate. Responding to the collection is required to
obtain and/or retain a benefit. The collection includes both
reporting and recordkeeping requirements. • Certain part 147
requirements involve reporting to the FAA at the time of
application for an FAA air agency certificate. Other reporting
requirements occur occasionally after certification, for example,
when the certificate holder’s operations change. Schools must issue
graduation and/or completion documentation based on the graduation
or curriculum completion schedule of the school. • AMTS who are not
accredited by an accrediting agency recognized by the Department of
Education have recordkeeping requirements related to an
FAA-approved QC system. The information collected is provided to
the certificate holder/applicant’s appropriate FAA Flight Standards
office in order for the FAA to determine compliance with the part
147 requirements for obtaining and/or retaining an FAA air agency
certificate. For part 147 applicants, when all part 147
requirements have been met, an FAA air agency certificate with the
appropriate ratings is issued. For certificated part 147
certificate holders, the FAA uses the information collected to (1)
verify that the AMTS operates in accordance with their certificate
and operations specifications, as required by § 147.3, (2)
determine if the AMTS provides appropriate training as required by
part 147, and (3) ensure that AMTS graduates receive appropriate
documentation showing the graduate is eligible to take the FAA
tests required to obtain a mechanic certificate, pursuant to part
65.
The following program changes
were made: • The current information collection request for 14 CFR
part 147 is revised as a result of a congressional mandate in
Public Law 116-260, effective December 27, 2020. The law mandates
publication of a 14 CFR part 147 interim final rule which results
in removed, changed, and new burdens from that reported in the last
IC. • The interim final rule reorganized and renamed provisions of
part 147 to the extent that new information collection instruments
cannot accurately be compared directly to previous information
collection instruments. Overall, the FAA estimates there is an
hours reduction, and a cost savings as a result of the new
regulation when compared to the previous IC request. • The FAA
estimates that only one AMTS will have FAA mandated recordkeeping
costs, compared to all schools under the previous approval. This is
the largest impact on overall paperwork burden reduction estimates
for respondents. • Reporting requirements have increased primarily
due to new provisions in part 147 such as additional training
locations (§ 147.15) and early testing (§ 147.31), and the
curriculum revision requirements of § 147.17. The collection
instrument, FAA Form 8310-6, Aviation Maintenance Technician School
Certificate and Ratings Application, is revised to reflect the new
and changed requirements under 14 CFR part 147. The burden
associated with this application is reflected in § 147.5 burden
estimates. • Both initial applications and applications for an
amended certificate are made on FAA Form 8310-6. • See attachment
“Part 147 Form 8310-6 Details of IC” for details on the specific
data collected on the form. • The estimated time spent completing
this form has been revised from 40-80 hours to 15-80 hours. This
estimate is based on the time it would take an applicant to
complete the form and all required application attachments, to
include curriculum development if applicable, that may be required
to be submitted with the form. Required attachments can vary
greatly depending on whether it is an initial application or an
application for an amended certificate, and depend on the
complexity of the applicant’s operations.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.