Supporting Statement A
Aviation Maintenance Technician Schools
OMB 2120-0040
Summary of Changes:
The estimated burden in this collection has increased due to the following:
The number of respondents to this collection has been updated based on the current number of part 147 AMTS certificate holders; 208 AMTS currently vs. 182 at previous approval.
Wage rates for industry stakeholders are updated to reflect newer data and reflect an increase in wages.
Wage rates for FAA personnel are updated to reflect 2025 rates and reflect an increase in wages.
1. Circumstances that make the collection of information necessary.
49 U.S.C. 44701, General requirements, provides the general authority of the Administrator to prescribe regulations and minimum standards in the interest of safety for inspecting, servicing, and overhauling aircraft, engines, propellers, and appliances, including for other practices, methods, and procedures necessary for safety in air commerce.
49 U.S.C. 44702, Issuance of certificates, provides the authority of the Administrator to issue air agency certificates.
49 U.S.C. 44707, Examining and rating air agencies, empowers the Administrator of the Federal Aviation Administration (FAA) to examine and rate air agencies.
Section 135 of the Aircraft Certification, Safety, and Accountability Act (the Act), in Pub. L. 116-260, the Consolidated Appropriations Act, 2021 (134 Stat. 1182). Section 135, Promoting Aviation Regulations for Technical Training, provides the requirements and terms of 14 CFR part 147.
14 CFR part 147, Aviation Maintenance Technician Schools, implements the provisions of the sections of the Act referenced above by prescribing the requirements for issuing aviation maintenance technician school (AMTS) certificates and associated ratings and the general operating rules for the holders of those certificates and ratings. Specifically, part 147 imposes information collection burden on the public in the following sections:
Section 147.5, Application requirements. Applicants for a part 147 air agency certificate must complete an application form and provide the FAA with evidence of meeting all of the requirements of part 147. Application is made using FAA Form 8310-6, Aviation Maintenance Technician School Certificate and Ratings Application. Application requirements include:
Section 147.5 (b)(1) through (b)(3) requirements for descriptions of the facilities, equipment, and materials used at each location, basis of curriculum, and instructor requirements;
Section 147.5 (b)(4) requirement to submit any additional information necessary to demonstrate compliance with the requirements of part 147, which include:
Section 147.17, Training requirements, requires the school to establish a curriculum aligned with the mechanic airman certification standards that meets the passing rate requirements and ensures students are prepared to take the requisite tests for a mechanic certificate and rating(s);
Section 147.19, Instructor requirements, requires the school to have instructors who are either FAA-certificated mechanics, or are otherwise specifically qualified;
Section 147.23, Quality control system, requires the school to either be accredited within the meaning of 20 U.S.C. §1001(a)(5), or have a quality control (QC) system approved by the FAA.
Section 147.15, Training provided at another location. The AMTS must notify the FAA of locations that the school will conduct training, in addition to the school’s primary location.
Section 147.17, Training requirements. The AMTS must establish, maintain, and utilize a curriculum designed to continually align with mechanic airman certification standards as appropriate for the ratings held.
Section 147.21, Certificate of completion. The AMTS must issue documentation that shows when a student graduated from the curriculum required by § 147.17.
Section 147.23, Quality control system. An AMTS must either be accredited within the meaning of 20 U.S.C. 1001(a)(5) or have a quality control system approved by the FAA that provides for certain procedures listed in paragraph (b) of the section.
Section 147.31, Early testing. An AMTS may issue an authenticated document when a student satisfactorily completes only the General course content of a school’s curriculum.
2. How, by whom, and for what purpose the information is to be used.
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 to allow 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:
Verify that the AMTS operates in accordance with their certificate and operations specifications, as required by § 147.3,
Determine if the AMTS provides appropriate training as required by part 147, and
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.
3. Extent of automated information collection.
AMTS applicants initiate the part 147 certification process through FAA Form 8310-6, Aviation Maintenance Technician School Certificate and Ratings Application. AMTS certificate holders and/or applicants may submit the information described in this collection, including FAA Form 8310-6, either electronically via e-mail or through a paper submission. Required application attachments may also be submitted electronically or using paper submissions, depending on the applicant’s capabilities. A certificated AMTS typically uses paper and/or electronic submissions at their discretion.
FAA Form 8310-6 is available in electronic format from www.faa.gov/forms, and may be filled and signed electronically, as well as downloaded and printed, and filled and signed with pen-and-ink.
The results of the information collection will not be made available to the public over the internet.
4. Efforts to identify duplication.
We have reviewed the other FAA public use reports and find no duplication. We know of no other agency collecting information about part 147 or AMTS.
5. Methods used to minimize burden to small businesses.
The reporting and recordkeeping requirements described in this collection are the minimum necessary to ensure effective compliance with part 147. Most AMTS would be considered a small business/entity and most reporting requirements would not vary based on a schools size. Burden could vary in the following areas related to a schools size:
Section 147.15, Training provided at another location. Adding training locations, in addition to the school primary location, is optional. However, all additional locations must be listed in the schools operations specifications, thus resulting in a reporting burden proportional to the number of additional locations being requested.
Section 147.17, Training requirements. The AMTS must establish, maintain, and utilize a curriculum designed to continually align with mechanic airman certification standards as appropriate for the ratings held. Some schools may choose to implement additional curriculum content and/or school-specific requirements that are not necessarily required by the mechanic airman certification standards. These additions may be proportional to the size of the school and/or number of additional locations, and may cause additional burden, albeit, not required by the FAA.
Section 147.21, Certificate of completion. The AMTS must issue documentation that shows when a student graduated from the part 147. Schools with less graduates would have a proportionally smaller documentation requirement than schools with more graduates.
Section 147.23, Quality control system. An AMTS, regardless of its size, has the option to either be accredited or to have a quality control system approved by the FAA. Schools who choose to implement a quality control system in lieu of accreditation may encounter a reporting burden that is proportional to the size of their school. For example, schools with larger student populations may require more reportable procedures or other burden related to recordkeeping or graduation documentation.
Section 147.31, Early testing. An AMTS may issue an authenticated document when a student satisfactorily completes only the General course content of a school’s curriculum. Schools are not required to issue the documentation; however, if not issued, the school’s students cannot exercise the early testing provision of § 65.77(c).
6. Impact of no, or less frequent, collection.
If the information described in this collection is not collected, the FAA would not be able to ensure that applicants or certificate holders meet the requirements of 14 CFR part 147, which enables the FAA to issue an air agency certificate, and to verify continued compliance with part 147 after issuance. Part 147 ensures that graduates from AMTS certificated under part 147 have the knowledge and skills necessary to be prepared to test for a mechanic certificate under part 65. If certificate holders did not meet part 147 requirements, then mechanic applicants may be testing for a mechanic certificate when they do not have the appropriate knowledge and skills.
The reporting information is only collected during application and if/when the certificate holder changes certain information that is required to be in the school’s FAA-issued operations specifications, as an AMTS is required to operate in compliance with their operations specifications, pursuant to § 147.3. If the information is collected less frequently, the FAA would not be able to ensure that applicants or certificate holders meet the requirements of part 147 initially and when certain changes occur, relevant to the school’s operations specifications.
Part 147 requires an AMTS to either be accredited by pursuant to 20 U.S.C. 1001(a)(5) or establish and maintain a quality control system. Should an AMTS comply with this provision by accreditation, the FAA must collect such information to ensure continual accreditation. Should an AMTS choose to establish and maintain a quality control system, the QC system must provide procedures for recordkeeping. However, the FAA does not impose specific recordkeeping methods or practices for such a quality control system. While an AMTS is free to define recordkeeping procedures that work for the AMTS, the applicant/certificate holder must describe its recordkeeping procedures in the quality control system. If a school did not describe its recordkeeping procedures, the school would not be maintaining evidence that graduates of the school completed the curriculum requirements and were thereby eligible to test for a mechanic certificate under part 65.
7. Special circumstances.
There are no special circumstances related to this information collection.
The information collection is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2)(i)-(viii).
8. Information on the PRA Federal Register Notice and public comments.
A 60-day Federal Register Notice was published in the Federal Register on April 22, 2025 (90 FR 16913). Comments were due by June 23, 2025. No comments were received.
On February 3, 2025, FAA requested feedback from the Aviation Technical Education Council (ATEC) on the information collected as described in this IC. ATEC responded on February 5, 2025, stating that they had no comments or recommendations from the Council or its members.
9. Payments or gifts to respondents.
No gifts or payments are provided to respondents.
10. Assurance of confidentiality.
Respondents are not given an assurance of confidentiality.
11. Justification for collection of sensitive information.
This information collection does not collect information of a sensitive nature.
12. Estimates of the hour burden of the collection of information.
Part 147 regulations result in a total estimated annual burden to respondents of 21,902 hours and $1,324,119. The FAA estimates that 713 responses are made annually resulting in an average time per response of 29 hours.
Burden Summary |
147.5 |
147.15 |
147.17 |
147.21 |
147.23 Accred |
147.23 |
147.31 |
Total |
|
QC Sys |
Records |
||||||||
# of Respondents |
15 |
25 |
80 |
208 |
195 |
20 |
20 |
150 |
218 |
Responses per respondent |
1 |
1 |
1 |
1 |
1 |
2 |
2 |
1 |
-- |
Total # of Responses |
15 |
25 |
80 |
208 |
195 |
40 |
150 |
713 |
|
Time per Response (hours) |
14 |
10 |
43 |
24 |
0.1 |
75 |
160 |
24 |
29* |
Hour Burden (hours) |
210 |
250 |
3430 |
4992 |
19.5 |
3,000 |
6400 |
3600 |
21,902 |
9400 |
|||||||||
Cost Burden ($) |
17,522 |
18,173 |
226,469 |
327,092 |
1,569 |
223,059 |
273,876 |
236,359 |
1,324,119 |
*Total Time per Response burden was obtained by dividing the total Hour Burden by the Total # of Responses (i.e., 21,901/753).
Application (§147.5) Reporting Burden
Under § 147.5, Application requirements, an AMTS applicant must make application to the FAA, on FAA Form 8310-6. See attachment, “Form 8310-6 Details of IC,” for details on the specific data collected on the form. Additionally, an applicant must provide the following descriptions for inclusion in the AMTS operations specifications:
Under § 147.5(b)(1), a school must describe its facilities, including the physical address of the applicant’s primary location for operation of the school and any additional fixed training locations, and the equipment and materials to be used at each location;
Under § 147.5(b)(2), a school must describe the manner in which the school’s curriculum will ensure the student has the knowledge and skills necessary for attaining a mechanic certificate and associated ratings under subpart D of part 65. When the school revises the description, it must provide the changed information to the FAA for inclusion in the AMTS operations specifications;
Under § 147.5(b)(3), a school must describe the manner in which the school will ensure it provides the necessary qualified instructors to meet the requirements of § 147.19.
Under § 147.5(b)(4), a school must provide any additional information necessary to demonstrate compliance with the requirements of part 147.
Following certification, if the certificated AMTS makes changes to the descriptions it provided during certification, the school must provide those descriptions to the FAA to update the AMTS operations specifications.1 During application, there are additional attachments that would need to be submitted to the FAA, as required by § 147.5(b)(4) (e.g., accreditation documentation or quality control system information); however, the burden estimates for those items, to include burden at initial application, are calculated under the applicable regulatory requirement in the additional tables below. The FAA estimates 10 initial applicants and 5 existing certificate holders will submit this information to the FAA annually.
The FAA estimates that the time to complete the form plus additional time to gather the applicable application attachments will take each applicant approximately 14 hours.
The FAA estimates the respondent burden related to the new § 147.5 requirements to be 210 hours and $17,524.
147.5 |
147.5 Initial/Revise
application |
147.5(b)(1) Facilities, Equipment, Materials |
147.5(b)(2) Curriculum basis |
147.5 (b)(3) Instructor requirements |
Total |
# of Respondents |
15 |
15 |
|||
Responses per respondent |
1 |
1 |
1 |
1 |
-- |
Total # of Responses |
15 |
15 |
|||
Time per Response |
1 |
6 |
6 |
1 |
14 |
Hour Burden (hours) |
15 |
90 |
90 |
15 |
210 |
Cost/Hour |
83.44 |
83.44 |
83.44 |
83.44 |
-- |
Cost Burden ($) |
1,252 |
7,510 |
7,510 |
1,252 |
17,522 |
Training provided at another location (§147.15) Reporting Burden
In addition to a school’s primary location, an AMTS has the option of providing training at fixed locations other than the school’s primary location. Schools must notify the FAA in order to have the additional location provided in the operations specifications. The option to add additional training locations is a new provision implemented by the interim final rule. The FAA estimates that annually, there are 25 instances where respondents notify the FAA of adding one or more additional training location.
The FAA estimates the new § 147.15 provision will result in an annual burden to schools of 250 hours and an annual cost of $18,173.
§ 147.15 Training at Another Location |
Director |
Admin |
Totals |
# of Respondents (annually) |
25 |
25 |
|
Responses per respondent (annually) |
1 |
-- |
|
Total # of Responses (Annually) |
25 |
25 |
|
Time per Response (hours) |
8 |
2 |
10 |
Hour Burden (hours) |
200 |
50 |
250 |
Cost/Hour ($) |
83.44 |
29.69 |
-- |
Cost Burden ($) |
16,688 |
1,485 |
18,173 |
Training requirements (§ 147.17) Reporting Burden
AMTS must establish, utilize, and maintain a curriculum that is designed to continually align with the Mechanic Airman Certification Standards (ACS). The school must develop an initial curriculum during the certification process. The FAA estimates 10 initial certification projects occur each year. After certification, the school must revise the curriculum to ensure it continually aligns with the Mechanic ACS. The FAA expects the ACS to be revised once every 3 years. There are currently 208 certificated AMTS, therefore, on an annual basis, there will be approximately 70 curriculum revisions (208 AMTS divided by 3 years).
The FAA estimates the new § 147.17 provision will result in an annual burden to schools of 3,430 hours and an annual cost of $226,469.
147.17 |
Initial Curriculum |
Curriculum Revision |
Total Burden |
||||
Job Classification |
Director |
Instructor |
Admin |
Director |
Instructor |
Admin |
|
# of Respondents (annually) |
10 |
70 |
80 |
||||
Responses per respondent (annually) |
1 |
1 |
1 |
||||
Total # of Responses (Annually) |
10 |
70 |
80 |
||||
Time per Response (hours) |
90 |
75 |
24 |
16 |
4 |
2 |
42.875 |
Hour Burden (hours) |
900 |
750 |
240 |
1,120 |
280 |
140 |
3430 |
Cost/Hour ($) |
83.44 |
45.28 |
29.69 |
83.44 |
45.28 |
29.69 |
-- |
Cost Burden ($) |
75,096 |
33,960 |
7,126 |
93,453 |
12,678 |
4,157 |
226,469 |
Graduation/Completion Documentation (§ 147.21) (Reporting Burden)
Under § 147.21, each AMTS must provide an authenticated document to each graduating student. There are currently 208 certificated AMTS.
The FAA estimates that each school spends 24 hours issuing graduation certificates, each year. This results in a total respondent burden of 4,992 hours and $327,092.
New 147.21 Graduation Documentation |
Graduation Documentation |
Total Burden
|
|
Job Classification |
Director |
Admin |
|
# of Respondents (annually) |
208 |
208 |
|
Responses per respondent (annually) |
1 |
-- |
|
Total # of Responses (Annually) |
208 |
208 |
|
Time per Response (hours) |
16 |
8 |
24 |
Hour Burden (hours) |
3328 |
1664 |
4992 |
Cost/Hour ($) |
83.44 |
29.69 |
-- |
Cost Burden ($) |
277,688 |
49,404 |
327,092 |
QC System – Accreditation (§ 147.23)
Under the new part § 147.23 quality control (QC) system requirements, AMTS who are accredited by an accrediting agency recognized by the Department of Education, have no additional quality control system requirements imposed by the FAA, other than being able to demonstrate the school is appropriately accredited.
There are currently 208 certificate AMTS, 191 of which meet 147.23 by way of being accredited by a Department of Education-recognized accrediting agency. The FAA estimates that over the next 3 years, 195 AMTS will submit evidence of accreditation at initial certification and annually after certification resulting in a burden of 19.5 hours and $1,627.
147.23 - QC System |
Accreditation Evidence |
Job Classification |
Director |
# of Respondents (annually) |
195 |
Responses per respondent (annually) |
1 |
Total # of Responses (annually) |
195 |
Time per Response (hours) |
0.1 (approx.5 minutes) |
Reporting Burden (hours) |
19.5 |
Cost/Hour ($) |
83.44 |
Reporting Cost Burden ($) |
1,627 |
QC System – FAA Approved QC System (§147.23) – Reporting & Recordkeeping
Under the new part § 147.23 quality control (QC) system requirements, AMTS who are not accredited as described in § 147.23 must obtain FAA approval of the AMTS QC system. The QC system must include procedures on recordkeeping, among other requirements. Thus, the requirements of new part § 147.23 impose both a reporting burden and a recordkeeping burden on the small number of AMTS applicants who are not accredited institutions.
There are currently 208 certificate AMTS, 17 of which meet 147.23 by way of an FAA-approved QC system. Therefore, over the next 3 years, FAA estimates 20 AMTS will submit either an initial or revised QC system to the FAA. Overall burden (reporting and recordkeeping) on these respondents is 470 hours and $22,942 annually.
FAA-Approved QC System Reporting Burden
The FAA estimates that annually, 1 AMTS must develop a QC system for FAA approval, and that once per year the AMTS will revise its QC system procedures, resulting in 2 responses per year.
The FAA estimates the reporting burden to respondents in obtaining and maintaining a FAA-approved QC system is 3000 hours and $223,059 annually.
FAA-Approved QC System- Reporting |
Initial/Revised QC System |
Total Burden |
||
Job Classification |
Director |
Instructor |
Admin |
|
# of Respondents (annually) |
20 |
20 |
||
Responses per respondent (annually) |
2 |
2 |
||
Total # of Responses (annually) |
40 |
40 |
||
Time per Response (hours) |
60 |
8 |
7 |
75 |
Reporting Burden (hours) |
2,400 |
320 |
280 |
3000 |
Cost/Hour ($) |
83.44 |
45.28 |
29.69 |
-- |
Reporting Cost Burden ($) |
200,256 |
14,490 |
8,313 |
223,059 |
FAA-Approved QC System Recordkeeping Burden
The FAA estimates that one AMTS will have recordkeeping burden related to its FAA-approved QC system, annually.
The FAA estimates the recordkeeping burden to respondents for recordkeeping requirements prescribed by the FAA-Approved QC system is 6400 hours and $273,876.
FAA-Approved QC System - Recordkeeping |
School Records |
Student Records |
Total Burden |
|
Job classification |
Director |
Instructor |
Admin |
|
# of Respondents (annually) |
20 |
20 |
40 |
|
Responses per respondent (annually) |
1 |
1 |
1 |
|
Total # of Responses (Annually) |
20 |
20 |
40 |
|
Time per Response (hours) |
20 |
200 |
100 |
320 |
Hour Burden (hours) |
400 |
4000 |
2000 |
6400 |
Cost/Hour ($) |
83.44 |
45.28 |
29.69 |
-- |
Cost Burden ($) |
33,376 |
181,120 |
59,380 |
273,876 |
Early testing (§ 147.31) Reporting Burden
The FAA estimates that 150 of the 208 currently certificated AMTS will use the option to issue documentation to students showing completion of the General curriculum, as permitted by § 147.31. Similar to graduation certificates issued under § 147.21, the FAA estimates each school will spend 24 hours annually issuing the required documentation, resulting in a burden of 3616 hours and $236,359.
Section 147.31, Early testing certificate |
Issue completion document for General curriculum |
Total Burden |
|
Job classification |
Director |
Admin |
|
# of Respondents (annually) |
150 |
150 |
|
Responses per respondent (annually) |
1 |
1 |
|
Total # of Responses (Annually) |
150 |
150 |
|
Time per Response (hours) |
16 |
8 |
24 |
Hour Burden (hours) |
2400 |
1216 |
3616 |
Cost/Hour ($) |
83.44 |
29.69 |
-- |
Cost Burden ($) |
200,256 |
36,103 |
236,359 |
AMTS Labor Cost Estimates
Businesses affected by this rule would be classified using the 2020 North American Industry Classification System under NAICS code2 611500 “Technical and Trade Schools”.3 This U.S. industry comprises establishments primarily engaged in offering job or career vocational or technical courses. The major occupation codes for AMTS directors, instructors, and administrative assistant under the 611500 NAICS code are 11-9033, 25-1194, and 43-6014, respectively. The FAA believes that these occupation codes are the appropriate codes to estimate the salaries of AMTS employees. The U.S. Bureau of Labor Statistics (BLS) lists an annual mean wage for each of these occupation codes.
AMTS Base Salaries |
|||
Job Category |
Occupation Code |
Annual Mean Wage |
Source: Bureau of Labor Statistics, Occupational Employment and Wage Statistics. |
Director |
11-9033 |
$122,010 |
https://www.bls.gov/oes/2023/may/oes119033.htm |
Instructor |
25-1194 |
$65,500 |
https://www.bls.gov/oes/2022/may/oes251194.htm |
Administrative Assistant |
43-6014 |
$43,410 |
https://www.bls.gov/oes/2022/may/oes436014.htm |
The FAA starts with the base salaries for the director, instructor, and administrative assistant. The FAA then applies the appropriate multipliers for overhead (this includes health benefits, vacation, sick time, etc.). For private positions, we add a benefit overhead of 42.25%, which is based on the percent of total compensation for transportation employees.4
AMTS Salaries including Overhead |
|||
Job Category |
Director |
Instructor |
Administrative Assistant |
Annual Base salary |
$122,010 |
$65,500 |
$43,410 |
Overhead benefit multiplier |
1.4225 |
1.4225 |
1.4225 |
Salary including overhead |
$173,559 |
$94,174 |
$61,751 |
Hourly Wage |
$83.44 |
$45.28 |
$29.69 |
13. Estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There are no additional startup costs not already covered in question 12.
14. Estimates of annualized costs to the Federal government.
The estimated annual burden on the FAA is 2,356 hours and $237,378.
FAA Burden |
§ 147.5 App |
§
147.15 |
§ 147.17 Training/ Curriculum |
§147.23
|
§ 147.23 FAA-App QC |
§ 147.25 Pass Rate |
Total FAA Burden |
# of Respondents (annually) |
15 |
25 |
80 |
188 |
20 |
1 |
-- |
Responses per respondent (annually) |
1 |
1 |
1 |
1 |
1 |
4 |
-- |
Total # of responses (annually) |
15 |
25 |
80 |
182 |
20 |
4 |
332 |
Time per Response (hours) |
8 |
4 |
16 |
2 |
16 |
40 |
-- |
Hour Burden (hours) |
120 |
100 |
1280 |
364 |
320 |
160 |
2356 |
Cost/Hour ($) |
103.04 |
103.04 |
103.04 |
103.04 |
103.04 |
69.39 |
-- |
Cost Burden ($) |
12,365 |
10,304 |
117,053 |
37,507 |
32,973 |
11,102 |
237,378 |
Application requirements (§ 147.5)
The FAA estimates that it reviews 15 initial and amended applications annually, spending an average of 8 hours per review. Under § 147.5, an FAA inspector must:
Review each applicant’s application form, FAA Form 8310-6, whether submitted for initial certification or for amendment of a certificate;
Review and enter the required descriptions for facilities, equipment, materials, curriculum basis, and instructor requirements into the AMTS operations specifications;
Review the attachments to the application to ensure the applicant demonstrates compliance with part 147 requirements.
Training provided at another location (§ 147.15)
Under § 147.15, the FAA estimates that it will receive 25 requests each year for additional training locations and spend 4 hours reviewing each request. Upon AMTS notification of an additional training location, the FAA must determine the location meets part 147 requirements, and then an FAA inspector must enter the AMTS additional training locations into AMTS operations specifications.
Training requirements (§ 147.17)
Under § 147.17, the FAA estimates that each certificated AMTS would revise its curriculum every 3 years to align with the revision schedule of the Mechanic ACS. The FAA must review the AMTS curriculum during certification to ensure it aligns with the Mechanic ACS as required by 147.17(a), at an estimated 16 hours per review. These reviews are conducted by an FAA inspector.
Quality control system (§ 147.23)
Under § 147.23, the FAA must review each AMTS accreditation status and must review and approve each non-accredited school’s quality control system. The FAA estimates it takes an FAA inspector 2 hours annually to review a school’s accreditation status and 16 hours to review and approve an AMTS QC system.
Minimum passage rate (§ 147.25)
Under § 147.25, the FAA expects that 4 times per year it will produce a report on the minimum passage rate for each school. Time spent developing each report is estimated at 40 hours per report. The FAA must collect test results from the FAA mechanic written, oral, and practical tests, and then produce a report on those test results. The FAA must review each schools pass rate indicated on the report to ensure each schools compliance with the pass rate metric described in § 147.25. The collection and reporting are conducted by an FAA statistician.
FAA Labor Cost Estimates
The FAA obtained the salary rates for FAA employees from the 2020 Core Compensation Plan Pay Bands (Excluding Locality Pay), effective January 12, 2025. The pay bands for principal inspectors and statisticians are shown in the table below. The FAA uses the mid-range salary for each of these positions.
FAA Base Salaries |
||
Job Category |
Pay Band |
Annual Mean Wage |
Principal inspector |
J |
$120,558 |
Statistician |
H |
$81,184 |
Source: Core Compensation Plan Pay Bands, effective January 12, 2025.5 |
||
The FAA starts with the base salaries for FAA principal inspectors and statisticians. Next, the FAA multiplies the base salaries by a locality multiplier. For instance, for the principal inspector and the statistician, the FAA assumes the affected position is in Washington, D.C. Therefore, the FAA uses the multiplier of 1.3048.6 The FAA then applies the appropriate multipliers for overhead (this includes health benefits, vacation, sick time, etc.). For federal positions, the standard is 36.25%.7
FAA Salaries including Overhead |
||
Job Category |
Principal Inspector |
Statistician |
Pay band |
J |
H |
Annual Base salary |
$120,558 |
$81,184 |
Locality pay multiplier |
1.3048 |
1.3048 |
Salary adjusted by locality pay |
$157,304 |
$105,929 |
Overhead benefit multiplier |
1.3625 |
1.3625 |
Salary including overhead |
$214,327 |
$144,328 |
Hourly wage rate |
$103.04 |
$69.39 |
15. Reasons for any program changes or adjustments.
The estimated burden in this collection has increased due to the following:
The number of respondents to this collection has been updated based on the current number of part 147 AMTS certificate holders; 208 AMTS currently vs. 182 at previous approval.
Wage rates for industry stakeholders are updated to reflect newer data and reflect an increase in wages.
Wage rates for FAA personnel are updated to reflect 2025 rates and reflect an increase in wages.
16. For collections of information whose results will be published, outline plans for tabulation and publication.
No information collected from respondents is published.
The FAA collection of data related to minimum pass rates of each AMTS will be published quarterly on www.faa.gov.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.
The FAA is not seeking approval to not display the date of expiration of this information collection.
18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
There are no exceptions to the certification statement for this information collection.
1 Section 147.3 states that no person may operate an AMTS without, or in violation of, the issued AMTS certificate and the operations specifications. The FAA provides an AMTS with operations specifications based on their application and any subsequent amendments. Therefore, the AMTS must provide any changes to the FAA to update an AMTS’s operations specifications and ensure compliance with § 147.3.
2 The NAICS code is the standard used by Federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.
3 U.S. Bureau of Labor Statistics, NAICS 611500 - Technical and Trade Schools https://www.bls.gov/oes/2023/may/naics4_611500.htm
4 Percent of total compensation = 29.7%. Source: https://www.bls.gov/news.release/pdf/ecec.pdf.
6https://employees.faa.gov/org/staffoffices/ahr/program_policies/policy_guidance/hr_policies/hrpm/comp/comp_ref/media/locality_pay_percentages.pdf
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Hall, Barbara L (FAA) |
| File Modified | 0000-00-00 |
| File Created | 2025-06-24 |