Supporting Statement A
Certification: Mechanics, Repairman, Parachute Riggers
OMB 2120-0022
Summary of Change:
The FAA is revising this collection to reflect changes to FAA Form 8610-3, Airman Certificate and/or Rating Application – Repairman, to align with proposed rulemaking Modernization of Special Airworthiness Certification (MOSAIC), Docket No. FAA-2023-13771. The specific changes to this form include:
Revised the name of the “repairman certificate (light-sport aircraft)” to “repairman certificate (light-sport)” and removed use of “LSA” acronym,
Replaced the term “Class” with “Aircraft Category”,
Listed the following aircraft categories, with an associated checkbox for each: airplane, rotorcraft, glider, lighter-than-air, powered-lift, powered parachute, and weight-shift control aircraft.
The burden estimates related to FAA acceptance of light-sport repairman training courses have been revised. These burden changes are not a result of the MOSAIC rulemaking and are not new. However, previous estimates were incorrectly based on the number of light-sport repairman applicants, which is inaccurate because the training courses themselves do not result in PRA-related burden on applicants; training course burden estimates have been revised to reflect the burden on training course providers for development of training courses and for issuing the required training course completion certificate.
Training courses no longer have a 2-year expiration date. Therefore, the burden associated with renewing training courses every two years has been removed from estimates previously approved.
The estimated burden to the Federal government was increased for this IC because the previous estimates did not include Federal burden related to the FAA review of light-sport repairman training courses.
The supplemental document “Part 65 Forms-Details of IC” has been revised to reflect the specific changes made to each page of 8610-3 under this revision. Changes to the form do not result in new impacts on the collection, its justification, or burden estimates.
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
Title 49, United States Code, Sections 44702 and 44703, empower the Administrator of the Federal Aviation Administration 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 supporting statement.
Public Law (PL) 112-153, Pilot’s Bill of Rights Act (PBR or “the Act”), as amended by PL 115-254 in the “Fairness for Pilots Act” (an expansion of the PBR within the FAA Reauthorization Act of 2018).
Title 14, Code of Federal Regulations, part 65 (14 CFR part 65) prescribes, among other things, rules governing the issuance of certificates and associated rating for mechanic, repairman, and parachute riggers certificates, and issuance and renewal of mechanic certificate inspection authorizations (including inspection authorization course acceptance):
Subpart A – General,
65.11, Application and issue.
65.19, Retesting after Failure.
Subpart D – Mechanics, § 65.75 through § 65.95
Mechanics – § 65.75 - § 65.89
Inspection Authorization – § 65.91 through § 65.95
Section 65.93 prescribes several methods by which a mechanic with an IA can comply with the biennial renewal requirement.
Paragraph (a)(4) of this section specifies that, mechanics with an IA can complete a refresher course(s), acceptable to the Administrator, of not less than 8 hours of instruction for each year of the two-year renewal requirement.
Subpart E – Repairmen, § 65.101 through § 65.107
Repairmen (Air Carrier and Repair Station) – § 65.101 through § 65.103
Experimental Aircraft Builder Repairman – § 65.104 through § 65.105
Light Sport Repairman – § 65.107 and 65.109
Light Sport Repairman Training Course Providers (§ 65.109(e)).
Subpart F – Parachute Riggers
This collection of information supports the Department of Transportation’s strategic goal for Safety: Reduce Transportation-Related Fatalities and Serious Injuries Across the Transportation System.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
14 CFR part 65 prescribes, among other things, rules governing the issuance of certificates and associated ratings for mechanics, repairmen, parachute riggers, and the issuance and renewal of inspection authorizations.
The information is collected on forms submitted by applicants for mechanic, repairman, or parachute rigger certificates, or applicants for an initial or renewed inspection authorization. The information is used for evaluation by the FAA and is necessary for determining eligibility for issuance of a certificate, rating, or authorization.
In addition to the required application for a certificate or authorization, applicants are required to provide the FAA evidence of training or experience related to the certificate, rating, authorization, or certificate privileges sought, to include the following:
Mechanic applicants must provide evidence of meeting one of the experience requirements of § 65.77.
Inspection authorization renewal applicants must provide evidence of their renewal activity.
Parachute rigger applicants must provide evidence of packing a minimum number of parachutes, and in some cases experience.
Repairman applicants employed by a repair station or air carrier must provide their employer recommendation and evidence of training or experience.
Amateur aircraft builder repairmen must show evidence they are the primary builder of the aircraft for which privileges are sought.
Applicants for a light-sport repairman (certificate must complete an FAA-accepted training course and provide completion documentation.
Training course providers of light-sport repairman training courses must submit their training course to the FAA for acceptance. Additionally, the training course provider must issue a completion certificate to students who complete an FAA-accepted light-sport repairman training course.
Mechanic and parachute rigger applicants who fail a required certification test, and who test within 30 days of that test failure, must present a signed statement certifying that the applicant has received additional instruction in each of the subjects failed. Certificated parachute riggers must maintain records of the packing, maintenance, and alteration of parachutes performed or supervised by the parachute rigger.
AIRMEN APPLICATION INFORMATION COLLECTION
14 CFR § 65.11 requires that applications for a certificate or rating under this part be made on a form and in a manner prescribed by the FAA Administrator. The instruments (forms) described below are submitted by the applicant, to the FAA, by way of the local Flight Standards Office. The airman application forms included in this collection are:
FAA Form 8610-1, Mechanic’s Application for Inspection Authorization
FAA Form 8610-2, Airman Certificate and/or Rating Application – Mechanic and Parachute Rigger
FAA Form 8610-3, Airman Certificate and/or Rating Application – Repairman
Use of the Airman Applicant Information Collected
The information collected on the airman application forms is, and has been, used by the FAA to determine eligibility for a mechanic, repairman, or parachute rigger certificate and/or rating, or a mechanic certificate inspection authorization. Application and certification are necessary to ensure qualifications of the applicant. The Pilots Bill of Rights2 (PBR) is a notification included in the supplemental information of FAA Forms 8610-1, 8610-2, and 8610-3. The PBR notifies all applicants that they are under investigation, which is precipitated by submission of the application, to determine whether the applicant meets the qualifications for the airman certificate, rating, or inspection authorization being requested.
Mechanics (Part 65, Subpart D) – Reporting requirement.
Applicants for a mechanic certificate or added rating are required to submit, FAA Form 8610-2, Airman Certificate and/or Rating Application – Mechanics and Parachute Riggers to the FAA. The FAA uses this information to determine if an applicant is eligible to begin the certification testing process.
FAA Form 8610-2 is attached.
Refer to the attachment “Part 65 Forms-Details of IC”, for a summary of the information requested on the form, and the FAA business need for the information.
Documented Evidence of Experience (see § 65.77). In addition to the form fields, the applicant is directed by FAA personnel reviewing the application to provide documented evidence of the experience they have annotated on the form3. The FAA must ensure the applicant meets both the time and practical experience requirements of § 65.77, as applicable. Verifying an applicant’s experience is part of the investigation conducted by the FAA to determine if an applicant is eligible for the certificate or rating requested. See the following table for examples of typical evidence the applicant will be asked to provide, depending on how the applicant met 65.77 Experience requirements:
AMTS Applicants |
Civil Experience Applicants |
Military Experience Applicants |
Authenticated document showing graduation from an AMTS (e.g. certificate of completion, AMTS letter, etc.) |
A letter from the applicant’s employer or an FAA-certificated mechanic that certifies:
|
A letter from the applicant’s supervisor, maintenance/executive/classification officer, or an FAA-certificated mechanic that certifies:
|
Records showing completion of tasks or OJT, authenticated by the employer or an FAA- certificated mechanic. |
Military records of OJT records showing the type of work performed. |
|
A detailed statement from a Civil Aviation Authority (CAA) of the country in which the applicant gained the experience, including the make and model of aircraft and/or engine on which the applicant acquired the practical experience. |
A document issued by the U.S. military (e.g., DD Form 214, Certificate of Release or Discharge from Active Duty) which lists the MOS, AFSC, or NEC codes assigned to the applicant during their service. |
Submission of the form is done on an as-needed basis, when an applicant is making original application for a mechanic certificate or is requesting an added rating or other change to a previously issued mechanic certificate.
Examples of other changes include name, gender, and nationality changes, etc. which must be submitted to the FAA, on FAA form 8610-2.
Respondents are either individuals who have civil/military experience in maintaining aircraft or are students who have graduated from an Aviation Maintenance Technician School certificated by the FAA under 14 CFR part 147.
Responding to this collection is required in order to obtain and/or retain a benefit (i.e., a mechanic certificate and/or rating).
Information to applicants on 14 CFR requirements for becoming a mechanic and on the certification process can be found at: www.faa.gov/mechanics/become.
Parachute Riggers (Part 65, Subpart F) – Reporting and Recordkeeping requirements.
Reporting Requirement - Applicants for a parachute rigger certificate or added rating are required to submit FAA Form 8610-2, Airman Certificate and/or Rating Application – Mechanics and Parachute Riggers, to the FAA.
FAA Form 8610-2 is attached.
Refer to the attachment “Part 65 Forms-Details of IC”, for a summary of the information requested on the form, and the FAA business need for the information.
Evidence of Experience (see §§ 65.115 and 65.117, and 65.119). In addition to the form fields, the applicant is directed by FAA personnel reviewing the application to provide documented evidence of the experience they have annotated on the form4. The FAA must ensure the applicant has gained the required experience by packing a specified number of parachutes, applicable to each rating requested. Verifying an applicant’s experience is part of the investigation conducted by the FAA to determine if an applicant is eligible for the certificate or rating requested. See the following examples of typical evidence the applicant will be asked to provide, depending on parachute rigger certificate and ratings requested:
Submission of the form is done on an as-needed basis, when an applicant is making original application for a parachute rigger certificate or is requesting an added rating or other change to a previously issued parachute rigger certificate.
Examples of other changes include name, gender, and nationality changes, etc.
Respondents are individuals who have civil/military experience in maintaining and packing parachutes.
Recordkeeping requirement - Certificated parachute riggers must also keep records, as required by § 65.131. This is a mandatory requirement of the certificate holder.
A record is maintained by the parachute rigger that describes the parachute being packed, maintained, or altered. The record must include a description of the work done to the parachute, and the date and place where the work was performed.
The records must be kept for at least 2 years after the date each was made.
Parachute riggers must also attach a record to each parachute packed, to include the date and place of the packing, any defects found, and the riggers name and certificate number.
Responding to this collection (reporting and recordkeeping) is required in order to obtain and/or retain a benefit (i.e., a parachute rigger certificate and/or rating).
Section 65.19, Retesting after Failure – Reporting Requirement
Mechanic and parachute rigger applicants must pass FAA knowledge and practical tests, with a minimum passing grade of 70%, to be eligible for certificate issuance.
Applicants may retest 30 days after failing a test.
If an applicant desires to test prior to 30 days from the test failure, they must present a signed statement from an airman holding the certificate and rating sought by the applicant, certifying that the airman has given the applicant additional instruction in each of the subjects failed, and that the airman considers the applicant ready for retesting.
Responding to this collection is required in order to obtain and/or retain a benefit (i.e., do a retest of a failed FAA test, prior to 30 days from the test failure).
Inspection Authorization Application and Renewal (§ 65.91 through § 65.95) – Reporting requirement.
Individuals who hold, and have held, a FAA mechanic certificate for at least 3 years and meet other additional requirements, are eligible to apply for an Inspection Authorization (IA). Applicants for an IA are required to submit FAA form 8610-1, Mechanic’s Application for Inspection Authorization to the FAA.
FAA Form 8610-1 is attached. This is a reporting requirement.
Refer to the attachment “Part 65 Forms-Details of IC”, for a summary of the information requested on the form, and the FAA business need for the information.
Evidence of Renewal Basis (see § 65.93). In addition to the form fields, the applicant may be directed by FAA personnel reviewing the application to provide documented evidence of the experience they have annotated on the form5. The FAA must ensure the applicant is eligible to renew the IA and verifying an applicant’s renewal basis is part of the investigation conducted by the FAA to determine if an applicant is eligible for authorization. See the following examples of typical evidence the applicant will be asked to provide, depending on how the applicant met 65.77 Experience requirements:
The aircraft registration number (N#) on which the IA performed the requisite number of annual inspections, major repairs, major alterations, or progressive inspections; the course completion certificate provided by the refresher course training provider; the FAA-provided written results of an FAA oral test.
Initial submission of the form is done on an as-needed basis, when an applicant is making original application for an inspection authorization (IA).
The authorization must be renewed every 2 years (§65.93(a)). In March of each odd year (e.g. March 2021), current holders of an IA must make application for renewal using FAA Form 8610-1.
Respondents are individuals who hold and have held a FAA mechanic certificate for at least 3 years.
Responding to this collection is required in order to obtain and/or retain a benefit (i.e., an inspection authorization).
Repairmen (Subpart E) – Reporting requirements.
Applicants for a repairman certificate or added rating are required to submit FAA Form 8610-3, Airman Certificate and/or Rating Application – Repairman, to the FAA.
FAA Form 8610-3 is attached.
Refer to the attachment “Part 65 Forms-Details of IC”, for a summary of the information requested on the form, and the FAA business need for the information.
Evidence of Training or Experience. In addition to the form fields, the applicant is directed by FAA personnel reviewing the application to provide documented evidence of the training or experience they have annotated on the form. The FAA must ensure the applicant has obtained the required training or experience applicable to the repairman certificate and ratings requested. Verifying an applicant’s experience is part of the investigation conducted by the FAA to determine if an applicant is eligible for the certificate or rating requested. Refer to each type of repairman certificate below for a summary of the evidence of training or experience a repairman applicant will be asked to provide with the application.
Submission of the form is done on an as-needed basis when an applicant is making original application for a repairman certificate or is requesting an added rating or other change to a previously issued repairman certificate.
Examples of other changes include name, gender, and nationality changes, etc.
There are 3 types of repairman certificates available:
65.101 Repairmen are employed by an FAA certificated Air Carrier or Repair Station.
Respondents are individuals with training or experience in conducting specific maintenance tasks on behalf of the air carrier or repair station.
At the time of application for an original certificate, or added ratings, an applicant will be required to provide a letter of recommendation from their employer in accordance with § 65.101(a)(4) and provide evidence of either training or experience meeting § 65.101(a)(5). Evidence of training or experience may be in the form of training course completion certificates, records of work performed, or letters from employers certifying the type and time the applicant spent obtaining practical experience.
65.104 Repairmen are builders of an experimental aircraft.
Respondents are typically owners of the experimental aircraft for which they were the primary builder.
At the time of application an applicant will be required to provide evidence that they were the primary builder of the aircraft as required by § 65.106(a)(2)6. This can be evidenced by builder’s logs as described in AC 20-27.
65.107 Repairman maintain light-sport aircraft. There are two ratings available: Inspection Rating and Maintenance Rating.
Respondents for the Inspection Rating are aircraft owners. The respondent must attend a 16-hour training course acceptable to the FAA and may only exercise the privileges of the rating on the specific light-sport aircraft owned by the certificate holder. Applicants must present the training course completion certificate as evidence of completed training to the FAA at the time application is made.
Respondents for the Maintenance Rating are individuals who will perform maintenance and inspection on other owner’s light-sport aircraft. The respondent must complete a training course acceptable to the FAA, on maintaining the particular category of light-sport aircraft for which they intend to exercise the privileges of the rating. Applicants must present the training course completion certificate as evidence of completed training to the FAA at the time application is made.
Responding to this collection is required in order to obtain and/or retain a benefit (i.e., repairman applicants requesting a certificate and/or rating).
Respondents submit the FAA airmen application forms in this collection to local FAA Flight Standards offices, for review by the FAA, to determine the applicant’s eligibility. Applicants are also required to provide evidence of training or experience annotated on the application form. If all eligibility requirements are met, the FAA will either authorize a mechanic or parachute rigger applicant to begin the testing process, or will issues a temporary certificate to the applicant, as applicable. All applications, including a copy of the temporary airman certificate, are sent to the FAA’s Foundational Business, Airmen Certification Branch for record retention. The Airman Certification Branch:
Issues and mails a permanent airman certificate to the airman.
Maintains the information and safeguards it from improper access, modification, and destruction, consistent with FAA standards for confidentiality, privacy, and electronic information, and
Makes some information available to the public via a database accessed through www.faa.gov (https://www.faa.gov/licenses_certificates/airmen_certification/). The database provides limited information including the airman’s name, address, and any certificates and ratings issued by the FAA.
The maintenance and dissemination of the data is described in DOT/FAA System of Records Notice (SORN) 847, Aviation Records on Individuals.
REPAIRMAN CERTIFICATE (LIGHT-SPORT) TRAINING COURSES (§ 65.107(e)).7
In accordance with § 65.107(e), FAA-accepted Training Courses, a training course provider must submit a training course to the FAA for acceptance for that course to be used by a repairman applicant for eligibility to be issued a light-sport repairman certificate. After a student has completed the training and passed a course test, the training course provider must issue the student a course completion. The course completion certificate must contain the following information:
Name of the student
Name of the training provider
FAA course acceptance number
Rating applicable to the training course,
The category of aircraft the training was based on, and
The date of training completion.
The FAA has currently accepted 6 Inspection-rating training courses and 5 Maintenance-rating training courses.
After the effective date of the MOSAIC rulemaking, training courses for a Maintenance rating will no longer have minimum hourly requirements. Instead, training course providers must ensure that courses contain the elements of the Mechanic Airman Certification Standards8 that are applicable to the category of light-sport aircraft being trained.
The FAA expects that the MOSAIC rulemaking will result in training course providers developing additional courses to provide training for the additional aircraft categories eligible for a light-sport category airworthiness certificate. Additionally, some course providers may revise their existing training courses and submit the revised course for FAA-acceptance.
FAA Order 8000.84, Procedures to Accept Industry-Developed Training for Light-Sport Repairmen, describes what a training course provider submission to the FAA for light-sport training course acceptance and to demonstrate the training course provider can meet the requirements of § 65.109(e) 9. The submission must include:
A letter of request which includes identification of the person or company, location, telephone number, contact person, and the class of LSA the applicant wishes to teach,
the training course curriculum
A description of the facilities, equipment, and materials that will be used to teach the course,
The instructor qualifications of instructors that will be used to teach the course; and
A sample of the course completion certificate.
In guidance to training course providers, the FAA recommends that providers retain student course completion records for 3 years. As a result, FAA Order 8000.84 requests that course providers describe in their submission how they keep a record of a training attendee’s contact information, training completion, and credit awarded, for a period of 3 years.
Responding to this collection is voluntary, in the case of training course providers requesting FAA-Acceptance of a training course. Only FAA-accepted training courses can be used by light-sport repairman applicants towards certificate eligibility.
IA RENEWAL COURSE ACCEPTANCE INFORMATION COLLECTION
Section 65.93(a)(4) specifies that, mechanics with an IA can complete a refresher course(s) acceptable to the Administrator, of not less than 8 hours of instruction for each year of the two-year renewal requirement. Respondents who are requesting FAA acceptance of an IA renewal course are required to submit FAA Form 8610-6, Inspection Authorization Refresher Course Acceptance Request to the FAA.
FAA Form 8610-6 is attached. This is a reporting requirement.
Initial submission of the form is on an as-needed basis, when a course provider is requesting initial FAA acceptance of the IA renewal course.
Course acceptance must be renewed every 4 years, by re-submitting the form.
If significant changes are made to the course prior to the 4-year renewal, the course provider must re-submit the course for FAA acceptance using the form.
Respondents submit their completed and signed form to the FAA’s Inspection Authorization Refresher Course Coordinator (IA RCC), in the Flight Standards Aircraft Maintenance Division.
In guidance to training course providers, the FAA requests that providers retain student course completion records for 3 years.
The IA Refresher Course Acceptance forms are submitted to the FAA Flight Standards, Aircraft Maintenance Division (AFS-300), who has the administrative responsibilities for the IA refresher course program.
The purpose of the IC is to ensure that IA mechanics receive refresher training appropriate to their job responsibilities, thus qualifying those IA mechanics for renewal under § 65.93(a)(4). The information collection requires reporting to obtain the initial course acceptance including certain information about the course and the course provider.
The following information is collected on FAA Form 8310-6:
The course provider’s contact information.
A training course outline (TCO) showing the course curriculum subject areas to be presented, with references to any related technical or regulatory material.
The TCO includes the length of presentation times for each subject area presented in the course.
The course should contain one or more of the following subject areas: aircraft maintenance training topics, FAA regulations, policy that directly relates to the maintenance, inspection, repair, or alteration of aircraft products, systems, components, or accessories. Other acceptable topics might be human factors, Safety Management Systems as they relate to aircraft maintenance and could also contain curriculum subjects and course topics taught by 14 CFR part 147 Aviation Maintenance Technician Schools.
Course providers should also describe how they keep a record of a training attendee’s contact information, training completion, and credit awarded, for a period of 3 years.
This collection is required to obtain or retain a benefit (i.e., the ability to provide creditable IA refresher training for IA renewals). Respondents are persons or entities desiring to provide IA refresher courses that are creditable for IA renewal.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.
AIRMEN APPLICATION INFORMATION COLLECTION
FAA Form 8610-1 can be completed either via paper or via the Integrated Airman Certification and Rating Application (IACRA), a web application that facilitates the electronic submission of many information collections related to airman certification. IACRA is a secure web-based application that uses online validation and digital signatures to complete the airman certification documents. IACRA interfaces with multiple FAA databases such as knowledge testing and airman records for data validation and verification. It automatically ensures that applicants meet regulatory and policy requirements.
For IA renewal, the information collected via IACRA is the same as what is requested on the FAA Form, but the respondent enters the information into structured data fields, or by answering questions. The answers are used to fill out the form fields automatically. IACRA improves the airman certification process by checking for data errors that cause rejected applications. The certification processing time is reduced since the applicant, and inspector/examiner can complete the airman application online and can submit the completed application directly to the FAA’s airman records office electronically. The IACRA website references the OMB approval number for this IC. The website can be found here: https://iacra.faa.gov/IACRA/Default.aspx.
At this time, the IACRA automation does NOT support submission of the FAA Form 8610-2 (mechanic and parachute rigger certification), FAA Form 8610-3 (repairman certification), or the initial application for an inspection authorization made on FAA Form 8610-1. The FAA is working towards incorporating these applications into the IACRA automation to provide a fully electronic process. However, all mechanic applicants must register with IACRA during the application process because an FAA Tracking Number (FTN) must be established within the IACRA system before taking any FAA airman knowledge test. This ensures that applicant test results are retained with the correct applicant.
The FAA it is working to incorporate all part 65 applications into IACRA to support a fully electronic application process. This IC will be amended and OMB approval requested before such changes are implemented.
All forms are available in electronic format and can be downloaded off the FAA’s website, here: https://www.faa.gov/forms/. Forms are .pdf fillable and can be signed either electronically, or “pen-and-ink”. Forms may be submitted via email, regular mail, or in person.
REPAIRMAN CERTIFICATE (LIGHT-SPORT) TRAINING COURSES (§ 65.107(e)). 10
Requests for light-sport repairmen training course acceptance may be submitted to the FAA, directed to the attention of the Light-Sport Repairman Coordinator, at lsaawcc@faa.gov or through 9-AWA-AFS-300-MAINTENANCE@faa.gov. If the potential provider cannot submit the training course documents via email, they may arrange an alternate submission method by contacting the FAA’s Office of Safety Standards, Aircraft Maintenance Division, Airmen Section, here: 9-AWA-AFS-300-MAINTENANCE@FAA.GOV.
IA RENEWAL COURSE ACCEPTANCE INFORMATION COLLECTION
FAA Form 8610-6, Inspection Authorization Refresher Course Acceptance Request, is available in electronic format and can be downloaded from http://www.faa.gov/forms. The form is electronically fillable, signable, and fileable. The form and substantiating documents, as well as course acceptance notifications, are done via email. Only the courses found acceptable will be listed on the Master IA Refresher Course Database (Refer to question 16 for link to this list).
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.
We have reviewed other FAA public use reports and find no duplication. We know of no other entity collecting similar information for certification of mechanics, repairman, or parachute riggers, for issuing or renewing inspection authorizations or providing light-sport repairman or IA renewal course acceptance.
The information collected is only available from the applicants applying for an airman certificate, rating, or inspection authorization, or light-sport training or IA renewal course provider, under 14 CFR part 65. No similar information is available without the applicants providing it.
5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
The airman application information collection does not involve small businesses, only individuals who are required to complete an application form in order to obtain or retain a benefit.
The light-sport repairman training course and IA renewal course acceptance information collection is a function of the number of training courses that a course provider wants to offer. Small businesses or individuals compete in this field but typically offer a limited number of courses tailored to a specific region or type of course content and consequently have fewer submissions.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
AIRMEN APPLICATION INFORMATION COLLECTION
If the collection of this information were not conducted, the FAA would not be able to determine applicant eligibility and qualifications for issuance of a certificate, rating, or inspection authorization. Without this determination, the appropriate certification or inspection authorization could not be issued.
If parachute records were not required to be kept by parachute riggers, the user of the parachute could not determine the parachutes airworthiness prior to using the parachutes. This could result in an unairworthy and/or unsafe parachute being unintentionally used.
TRAINING COURSE ACCEPTANCE INFORMATION COLLECTION
If the course providers do not submit the information for light-sport repairman or IA training courses, the FAA would have no basis to determine if the courses offered by said applicants are acceptable to meet the light-sport repairman eligibility or the IA renewal requirements of part 65. The FAA estimates that approximately 74 percent of IA renewals are done using the refresher course method, therefore failure to provide the requested information would have a decidedly negative effect on the IA 2-year renewal process. The desired outcome of the IC is to ensure that IA mechanics are properly trained and current in their job knowledge to work in the aviation transportation industry.
If course providers do not submit light-sport repairman training courses to the FAA for acceptance, the FAA would have no basis to determine if the courses met the requirements to train light-sport repairman certificate applicants. The FAA must ensure that training course will provide applicants with the knowledge and skills to be eligible for a repairman certificate.
If the information collection was conducted less frequently the FAA would not be confident of a course’s acceptability as aviation technology evolves and regulations sometimes change.
7. Explain any special circumstances.
There are no special circumstances.
8. Provide information on the PRA Federal Register Notice that solicited public comments on the information collection prior to this submission.
Revisions to this collection related to the MOSAIC rulemaking were provided to the public in a Notice of Proposed Rulemaking (NPRM), published in the Federal Register on July 24, 2023 (88 FR 47650).
9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No payment or gifts are to be provided to the respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.
The information provided by the applicant on FAA Forms 8610-1 and 8610-2, and 8610-3 becomes part of the airman’s record and is contained in the Privacy Act system of records DOT/FAA 847, Aviation Records on Individuals (SORN 847). The use of that information is subject to the provisions of the Privacy Act and the Privacy Act systems of records, DOT/FAA 847 (SORN 847).
Light-sport repairman and IA renewal course providers are given no assurance of confidentiality.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.
There are no questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information.
Burden Summary
The total annual number of respondents to this collection is approximately 28,746 airmen applicants, certificate holders, and training course providers/applicants totaling approximately 332,791 responses.
The total annual time burden of this collection is approximately 37,332 hours and $2,316,187.
Total Part 65 IC |
Reporting |
Recordkeeping |
Total Part 65 |
# of Respondents |
28,744 |
6,900 |
-- |
# of Responses |
28,989 |
303, 800 |
332,789 |
Hour Burden |
10,807 |
26,334 |
37,141 |
Cost Burden |
735,959 |
1,549,988 |
2,285,947 |
The total estimated reporting and recordkeeping burden summaries are shown in the summary tables below. Additional information on burden calculations for each instrument are discussed following these summary tables.
Summary Table – Part 65 Reporting Burden |
||||||||||
Part 65 Reporting Burden |
IA Initial App & Renewal |
Application Mechanic and Parachute Rigger |
Repairmen |
Retest After Failure 65.19 |
Light-sport Repairman Training |
IA Refresher Course Accept |
Total |
|||
IA Initial |
IA Renew |
Subpart D |
Subpart F |
Subpart E |
||||||
Instrument |
FAA Form 8610-1 |
FAA Form 8610-2 |
FAA Form 8610-3 |
Courses |
Course Certs |
|||||
# of Respondents (annually) |
1855 |
10826 |
11000 |
360 |
3280 |
1136 |
2 |
250 |
35 |
28,744 |
Responses per respondent |
1 |
1 |
1 |
1 |
1 |
1 |
1 |
1 |
8 |
-- |
Total # of Responses |
1855 |
10826 |
11000 |
360 |
3280 |
1136 |
2
|
250 |
280 |
28,989 |
12681 |
11360 |
|||||||||
Time per Response (hours) |
.33 |
.33 |
.33 |
.33 |
.33 |
.167 |
90 |
.083 |
5 |
-- |
Hour Burden (hours) |
612 |
3573 |
3630 |
119 |
1083 |
190 |
180 |
21 |
1400 |
10,807 |
4185 |
3749 |
201 |
||||||||
Cost Burden ($) |
$270,100 |
$244,392 |
$46,017 |
$12,262 |
$11,988 |
$151,200 |
735,959 |
|||
Summary Table – Part 65 Recordkeeping Burden |
|||
Part 65 Recordkeeping Burden |
Parachute Rigger Records 65.131 |
IA Renewal Course Recordkeeping |
Total |
# of Respondents (annually) |
6800 |
100 |
6900 |
Responses per respondent |
35 |
658 |
-- |
Total # of Responses |
238,000 |
65,800 |
303,800 |
Time per Response (hours) |
.083 |
.1 |
-- |
Hour Burden (hours) |
19,754 |
6,580 |
26,334 |
Cost Burden ($) |
$839,348 |
$710,640 |
1,549,988 |
Reporting Burden - AIRMEN APPLICATION INFORMATION COLLECTION
Form 8610-1, Mechanic’s Application for Inspection Authorization
Annually approximately 185511 applications are made for a new issuance inspection authorization. Annually approximately 1082612 holders of an inspection authorization renew their authorization.
The FAA estimates an average of 20 minutes (.33 hours) is spent by each respondent completing the applications form.
Form 8610-1, Application for Inspection Authorization |
New IA applicants |
IA Renewals (21652/2) 13 |
Total |
# of Respondents (annually) |
1855 |
10,826 |
12,681 |
Responses per respondent (annually) |
1 |
1 |
1 |
Time per response (hours) |
0.33 hours (20 minutes) |
0.33 hours (20 minutes) |
-- |
Hour Burden |
612 |
3573 |
4185 |
Cost/hour ($/hour) |
64.54 |
64.54 |
-- |
Cost burden ($) |
39,498 |
230,601 |
270,100 |
Form 8610-2, Airman Certificate and/or Rating Application - Mechanic and Parachute Rigger
Annually approximately 1136014 individuals make application for an airmen (mechanic and parachute rigger) certificate, added rating, or other change, and spend an average time of 20 minutes (.33 hours) completing the application form.
Form 8610-2, Application for Mechanic and Parachute Rigger |
Mechanic Applicants |
Parachute Rigger Applicants |
Total |
# of Respondents (annually) |
11,000 |
360 |
11360 |
Responses per respondent (annually) |
1 |
1 |
1 |
Time per response (hours) |
0.33 (20 minutes) |
0.33 (20 minutes) |
-- |
Hour Burden |
3630 |
119 |
3749 |
Cost/hour ($/hour) |
64.54 |
42.49 |
-- |
Cost burden ($) |
234,280 |
5,056 |
244,392 |
Form 8610-3, Airman Certificate and/or Rating Application – Repairman
Annually, approximately 3280 individuals make application for a repairman certificate or added rating and spend an average time of 20 minutes (.33 hours) completing the application form.
The FAA estimates 265015 §65.101 repairman applicants annually.
The FAA estimates 43016 § 65.104 amateur-built repairman applicants annually.
The FAA estimates 2006 §65.107 light-sport repairman applicants annually.
Form 8610-3, Application for Repairman Certificate |
Repairman 65.101 |
Amateur Builder Repairman 65.104 |
Light Sport Repairmen 65.107 |
Total |
# of Respondents (annually) |
2650 |
430 |
200 |
3280 |
Responses per respondent (annually) |
1 |
1 |
1 |
1 |
Time per response (hours) |
0.33 (20 minutes) |
0.33 (20 minutes) |
0.33 (20 minutes) |
-- |
Hour Burden (hours) |
874 |
142 |
66 |
1082 |
Cost/hour ($/hour) |
42.49 |
42.49 |
42.49 |
-- |
Cost burden ($) |
37,179 |
6,034 |
2,804 |
46,017 |
Retesting After Failure (reference § 65.19).
Of the 11360 mechanic and parachute rigger applicants, the FAA estimates that approximately 10% of applicants fail a mechanic certification test and retest within 30 days, thereby needing a statement of retraining. Respondents spend an estimated 10 minutes in obtaining a statement of retraining.
Section 65.19, Retesting after Failure |
Annual retests within 30 days |
# of Respondents (annually) |
1136 |
Responses per respondent (annually) |
1 |
Time per response (hours) |
0.167 (10 minutes) |
Hour Burden |
190 |
Cost/hour ($/hour) |
64.54 |
Cost Burden |
12,263 |
Repairman Certificate (Light-Sport) Training Courses (reference § 65.107)
Repairman applicants must attend an FAA-accepted training course and provide the course completion certificate to the FAA at the time of application for a light-sport repairman certificate. The FAA currently has accepted 6 inspection courses and 5 maintenance courses, representing various aircraft categories. The FAA has not received any training course approval requests since 2003.
However, the FAA expects the MOSAIC rulemaking, new training course receives approximately 200 light-sport repairman applications annually. The FAA is estimating it will receive 1 inspection rating courses and 1 maintenance rating coursed, per year (on average) over the next 3 years. Additionally, the FAA estimates that training course providers will spend 90 hours preparing and submitting those courses to the FAA for acceptance.
Light-sport repairman training course providers must provide those students who will apply for an FAA repairman certificate (light-sport) a course completion certificate that includes specified information. The FAA estimates that approximately 200 repairman (light-sport) certificates are issued each year, and another 25% of training course attendees do not apply for a repairman certificate, resulting in 250 certificates issued annually. The FAA estimates that a training course provider spends approximately 5 minutes issuing each certificate.
The FAA used the wage rate estimates for IA training course providers and estimates that light-sport repairman training courses result in an annual burden to respondents of 370 hours and §39,360.
§ 65.107 |
Repairman (Light-sport) Training Courses |
|
Course Completion Certificates |
||
Inspection Rating |
Maintenance Rating |
Total |
|||
# of Respondents (annually) |
1 |
1 |
2 |
|
250 |
Responses per respondent (annually) |
1 |
1 |
1 |
|
1 |
# of Responses |
1 |
1 |
2 |
|
250 |
Time per response (hours) |
30 |
60 |
90 |
|
.083 hours (5 minutes) |
Hour Burden |
30 |
60 |
180 |
|
21 |
Cost/hour ($/hour) |
108 |
108 |
-- |
|
108 |
Cost Burden |
$ 3,240 |
$ 6,480 |
$ 9,720 |
|
$2,268 |
*Average response time based on the hour burden of all training divided by the # of respondents.
Record Keeping Burden - Parachute Rigger Recordkeeping (reference § 65.131)
The FAA estimates that 680017 parachute rigger certificate holders each make 35 recordkeeping entries per year and spend 5 minutes making each entry.
Parachute Rigger Records – § 65.131 |
Records |
# of Respondents (annually) |
6800 |
Responses per respondent (annually) |
35 |
Time per response (hours) |
0.83 (5 minutes) |
Hour Burden |
19,754 |
Cost/hour ($/hour) |
$42.49 |
Cost burden ($) |
$839,348 |
Reporting & Recordkeeping Burden - IA COURSE RENEWAL ACCEPTANCE (reference § 65.93)
The FAA estimates that 35 respondents request IA renewal course acceptance each year, and each year 100 respondents are maintaining IA renewal course records. The FAA estimates a total annual hour burden to respondents of 7,980 hours, and a total annual cost burden to respondents of $861,840.
The data in the table below reflects annual estimates of submittal (reporting) and recordkeeping burden, based on a four-year course acceptability expiration.
IA Refresher Course Provider Burden |
|||
§ 65.93(a)(4) burden |
Course Acceptance Submittals |
Course Record-Keeping |
Total |
# of Respondents Annually |
35 |
100 |
135 |
# Responses per Respondent Annually |
8 |
658 |
666 |
Time per Response (hour) |
5 |
0.1 |
-- |
Total # of Responses Annually |
280 |
65,800 |
66,080 |
Annual Burden (hours) |
1,400 |
6,580 |
7,980 |
Cost/Hour ($) |
$108 |
$108 |
$108 |
Annual Cost Burden ($) |
$151,200 |
$710,640 |
$861,840 |
Reporting Burden
The annual number of respondents for IA refresher courses is approximately 35, consisting of course providers and course provider applicants. The total estimated annual submission burden under § 65.93(a)(4) as described in this IC includes 35 respondents, submitting 280 responses averaging 5 hours per response @ $108/hr. for a burden of 1,400 hours, with an estimated cost of $151,200.
To estimate time spent responding to this IC, the FAA requested refresher course submission burden from eight current course providers. Five of these entities responded with time estimates and four with cost figures; they included one small (6 accepted courses), two medium (15 & 24 courses) and two large (51 & 60 courses) course providers. Their time and cost burdens were summed, averaged, and used in the burden estimates that follow.
There are three occasions that require course providers to make course acceptance submissions: the initial course acceptance, a change to course acceptance, and course renewal acceptances. Based on responses from the survey, the average time burden in each instance is as follows:
initial course acceptance - 2.6 hrs.
prepare a change to course acceptance – 1.1. hrs.
prepare a course renewal acceptance - .7 hrs.
These figures were summed and averaged to .85 hrs. per response. The FAA revised this to 5 hours per response for the sake of being conservative in the burden determination. Based on a four-year renewal cycle, the FAA expects to receive approximately 250 renewal acceptances, 10 change acceptances, and 20 initial acceptances annually.
Recordkeeping Burden
The total estimated annual recordkeeping burden for IA Refresher courses includes 100 respondents, recording 65,800 training events averaging .1 hour per entry @ $108/hr. for 6,580 hours, with an estimated cost of $710,640.
The FAA National Vital Information System (NVIS) database contained 22,230 mechanics with an active Inspection Authorization as of April 5, 2021.
A survey of six Flight Standards offices determined that approximately 74 percent of IA renewals use the refresher course method.
The FAA estimates that the average IA has taken four courses to meet the eight-hour annual training requirement. Seventy-four percent of 22,230 yields 16,450 IA’s taking refresher courses multiplied by four, equals an estimated 65,800 training events to record per year.
Labor Cost Analysis
The labor cost estimates used wage rates for aircraft mechanics and other installation, maintenance and repair workers, to determine a cost burden. For all wages, the FAA multiplied the hourly wage by 2 to account for a fringe benefit rate of 31%18 and an overhead rate of 69%19.
Aircraft Mechanics and holders of an Inspection Authorization
The wage rate of $32.27 per hour came from the Department of Labor, Bureau of Labor Statistics (BLS), May 2019, Aircraft Mechanics and Service Technicians #49-3011.20 This wage rate is used for initial mechanic applicants, as well as added rating and other change applications. Applicants for an Inspection authorization must hold a mechanic certificate.
Mechanic Labor Cost |
|||
Hourly wage |
31% Fringe Benefit17 |
69% Overhead18 |
Total |
$32.27 |
$10.00 |
$22.27 |
$64.54 |
Parachute Rigger and Repairmen.
The wage rate of $21.06 per hour came from the Department of Labor, Bureau of Labor Statistics (BLS), May 2019, Installation, Maintenance, and Repair Workers, All Other, #49-9099.21
Parachute Riggers and Repairmen Labor Cost |
|||
Hourly wage |
31% Fringe Benefit17 |
69% Overhead18 |
Total |
$21.06 |
$6.53 |
$14.90 |
$42.49 |
Light Sport Repairman and IA Renewal Course Providers.
The labor cost estimates used an hourly wage rate of $54 for light-sport repairman or IA refresher training course development and submission. The FAA multiplied the hourly wage by 2 to account for a fringe benefit rate of 30 percent22 and an overhead rate of 69 percent23.
Training Course Provider Labor Cost |
|||
Hourly wage |
31% Fringe Benefit17 |
69% Overhead18 |
Total |
$54 |
$16 |
$38 |
$108 |
13. Provide an estimate for 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. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
The FAA estimates the total additional agency burden per year is 21,978 hours, at an estimated cost of $1,575,900.
Costs to the Federal government are incurred in reviewing the applications for mechanics, inspection authorization, parachute riggers, repairmen, and for IA renewal course acceptance.
Agency Burden |
||||||||
|
IA Initial 65.91 |
IA Renew 65.93 |
Mechanic Subpart D |
Para Rigger Subpart F |
Repairman Subpart E |
Repairman (light-sport) Training Course Acceptance |
IA renewal course acceptance |
Total |
Instrument |
FAA Form 8610-1 |
FAA Form 8610-2 |
FAA Form 8610-3 |
|||||
# of Respondents (annually) |
1855 |
10826 |
11000 |
360 |
3280 |
4 |
35 |
27,360 |
Responses per respondent |
1 |
1 |
1 |
1 |
1 |
1 |
8 |
-- |
Total # of Responses |
1855 |
10826 |
11000 |
360 |
3280 |
4 |
280 |
27,605 |
Time per Response (hours) |
.75 |
.75 |
.75 |
.75 |
.75 |
40 |
5 |
-- |
Hour Burden (hours) |
1391 |
8119 |
8250 |
270 |
2460 |
160 |
1400 |
21,978 |
9438 |
8520 |
|||||||
Wages |
$70 |
$70 |
$70 |
$94 |
$94 |
-- |
||
Cost Burden ($) |
660,660 |
596,400 |
172,200 |
15,040 |
131,600 |
1,575,900 |
||
Agency Labor Cost Analysis
The salary base rate for this position is from the January 2022 General Schedule (GS) Locality Pay Tables.
Airman Application Review/Approval. The FAA estimates that an ASI spends approximately 1 hour reviewing and approving an airman application. Aviation Safety Inspectors in FAA Flight Standards offices who conduct airman applications reviews range from GS-9 to GS-14 positions. The FAA is using the salary base rate for a midpoint (Step 5) GS-13 to estimate labor costs, in the table “Rest of the United States”. Using these estimates, the fully burdened FAA aviation safety inspector (ASI) rate is $70.00.
Training Course Review and Acceptance. An Aviation Safety Inspector who works for FAA Flight Standards, Safety Standards conducts the light-sport repairman and IA Refresher training course acceptance reviews. The FAA estimates that the ASI spends approximately 40 hours (on average) conducting repairman training course reviews and 5 hours conducting IA refresher course reviews, including the time spend to accept or deny the course, as applicable. The FAA is using the salary base rate for a midpoint (Step 5) GS-14 to estimate labor costs, in the table “Washington-Baltimore-Arlington, DC-MD-VA-WV-PA”.
Using these estimates, the fully burdened FAA aviation safety inspector (ASI) rate is $94.00.
An employee benefit overhead of 36.25% has been applied to the base rate to provide the fully funded wage rate for each position24:
2022 GS |
Hourly wage |
Fringe/Overhead Benefit (36.25%) |
Total |
GS 13 Step 5 |
$51.25 |
$18.60 |
$70.00 |
GS 14 Step 5 |
$68.55 |
$24.90 |
$94.00 |
15. Explain the reasons for any program changes or adjustments.
The FAA is revising this collection to reflect changes to FAA Form 8610-3, Airman Certificate and/or Rating Application – Repairman, to align with proposed rulemaking Modernization of Special Airworthiness Certification (MOSAIC), Docket No. FAA-2023-137725. The specific changes to this form include:
Revised the name of the “repairman certificate (light-sport aircraft)” to “repairman certificate (light-sport)” and removed use of “LSA” acronym,
Replaced the term “Class” with “Aircraft Category”,
Listed the following aircraft categories, with an associated checkbox for each: airplane, rotorcraft, glider, lighter-than-air, powered-lift, powered parachute, and weight-shift control aircraft.
The burden estimates related to FAA acceptance of light-sport repairman training courses have been revised. These burden changes are not a result of the MOSAIC rulemaking and are not new. However, previous estimates were incorrectly based on the number of light-sport repairman applicants, which is inaccurate because the training courses themselves do not result in PRA-related burden on applicants; training course burden estimates have been revised to reflect the burden on training course providers for development of training courses and for issuing the required training course completion certificate.
Training courses no longer have a 2-year expiration date. Therefore, the burden associated with renewing training courses every two years has been removed from estimates previously approved.
The estimated burden to the Federal government was also increased because the previous IC did not include Federal burden related to the FAA review of light-sport repairman training courses.
The supplemental document “Part 65 Forms-Details of IC” has been revised to reflect the specific changes made to each page of 8610-3 under this revision. Changes to the form do not result in new impacts on the collection, its justification, or burden estimates.
16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
IA refresher courses that have been found acceptable to the FAA will be listed on the Master IA Refresher Course Database List at: https://faasafety.gov/WINGS/pub/IATrainingProviders/IaUnderMaint.aspx website under the maintenance tab for a period of four years, plus an additional two years if expired.
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.
We are not seeking approval to not display the expiration date.
18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
There are no exceptions.
1 The MOSAIC rulemaking NPRM is attached in ROCIS. At the time this supporting statement was prepared, the FAA is in an active rulemaking and cannot make the final rule regulations available until the publication of the final rule in the Federal Register. Publication of the MOSAIC final rule will be made in the Federal Register and posted in Docket No. FAA-2023-1377, available at: https://www.regulations.gov/.
2 See FAA Order 8900.2, Volume 14, Chapter 1, Section 3 for additional information on how the FAA complies with the requirements of the PBR.
3 Refer to FAA Order 8900.1, Volume 5, Chapter 5, Section 2.
4 Refer to FAA Order 8900.1, Volume 5, Chapter 5, Section 9.
5 Refer to FAA Order 8900.1, Volume 5, Chapter 5, Section 8.
6 Refer to FAA Order 8900.1, Volume 5, Chapter 5, Section 5.
7 This burden was previously captured under the reporting requirements of repairmen applicants. It is actually reporting burden of training course providers and as such is moved into a dedicated paragraph. The burden estimates have not changed, only how we present the information in this supporting statement has changed.
8 The Aviation Mechanic General, Airframe, and Powerplant Airman Certification Standards (FAA-S-ACS-1) can be found at https://www.faa.gov/training_testing/testing/acs.
9 Refer to FAA Order 8000.84, Procedures to Accept Industry-Developed Training for Light-Sport Repairmen. This order will be revised in conjunction with the MOSAIC rulemaking to only require training course providers to submit information that demonstrates the course providers compliance with § 65.109(e) Training Course Providers.
10 Refer to AC 65-32, Chapter 4, Training Course FAA-Acceptance, for information to training course providers submitting requests for FAA-acceptance of a light-sport repairman training course.
11 Respondent data source was obtained from a query of the FAA NPTRS Database for 2019 IA original issuances.
12 Respondent data source was an FAA Airman Records branch query of the number of March 2019 IA Renewals received by the FAA airman records office.
13 Inspection authorization renewals are required biennially. Therefore, the total number of IA renewals was divided by 2 to determine an estimated annual number of respondents.
14 Respondent data source for mechanic and parachute rigger applicants was the FAA’s 2019 Active Civil Airmen Statistics, Table 16, https://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/
15 Respondent data source for this renewal was the FAA’s 2019 Active Civil Airmen Statistics, Table 16, https://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/
16 Respondent data source was an FAA Airman Records branch query of the number of 2019 §65.104 amateur-built repairman applications received by the FAA airman records office.
17 Respondent data source for parachute rigger certificate holders was the FAA’s 2019 Active Civil Airmen Statistics, Table 1, https://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/
18 An employee fringe benefit of 31% is added (for benefits such as health benefits, vacation, sick time, etc.), based on the Civilian Workers wages, as reported in BLS release, Employer Costs for Employee Compensation-June 2019.
Source: U.S. DOL/BLS: https://www.bls.gov/news.release/ecec.nr0.htm
19 Source: U.S. Department of Health and Human Services, “Guidelines for Regulatory Impact Analysis” (2016), https://aspe.hhs.gov/system/files/pdf/242926/HHS_RIAGuidance.pdf. On page 30, HHS states, “As an interim default, while HHS conducts more research, analysts should assume overhead costs (including benefits) are equal to 100 percent of pretax wages….” To isolate the overhead rate, the Department subtracted the benefits rate of 69 percent from the recommended rate of 100 percent.
20 U.S. DOL/BLS: https://www.bls.gov/oes/current/oes493011.htm
21 U.S. DOL/BLS: https://www.bls.gov/oes/current/oes499099.htm
22 An employee fringe benefit of 30 percent is added (for benefits such as health benefits, vacation, sick time, etc.), based on the private industry wages, as reported in BLS release, Employer Costs for Employee Compensation-March 18, 2021.
Source: U.S. DOL/BLS: https://www.bls.gov/news.release/ecec.nr0.htm
23 Source: U.S. Department of Health and Human Services, “Guidelines for Regulatory Impact Analysis” (2016), https://aspe.hhs.gov/system/files/pdf/242926/HHS_RIAGuidance.pdf. On page 30, HHS states, “As an interim default, while HHS conducts more research, analysts should assume overhead costs (including benefits) are equal to 100 percent of pretax wages….” To isolate the overhead rate, the Department subtracted the benefits rate of 69 percent from the recommended rate of 100 percent.
24 OMB Memo dated March 11, 2008.
Source: https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/memoranda/2008/m08-13.pdf
25 The MOSAIC rulemaking NPRM is attached in ROCIS. At the time this supporting statement was prepared, the FAA is in an active rulemaking and cannot make the final rule regulations available until the publication of the final rule in the Federal Register. Publication of the MOSAIC final rule will be made in the Federal Register and posted in Docket No. FAA-2023-1377, available at: https://www.regulations.gov/.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Hall, Barbara L (FAA) |
| File Modified | 0000-00-00 |
| File Created | 2025-05-19 |