1 

### Department of Transportation **Federal Aviation Administration**
**SUPPORTING STATEMENT Pilot Professional Development, OMB 2120**  **- XXXX** 
**INTRODUCTION This**  **information collection is**  **submitted to the Office of Management and Budget**  **(OMB) to request a**  **three -** **year approv al**  **clearance for the information collection entitled, Pilot**  **Professional Development, (OMB Control No. 21**  **20 -** **XXXX) .**  **Part A. Justification**  1. Circumstances that make collection of information necessary
. This project provides direct support for the Safety Strategic Goal in the Department of Transportation for fiscal years 2012
- 2016 (i.e., to bring a department
- wide focus on reducing transportation
- related fatalities and injuries and to address the most serious safety risks in aviation). This project also directl y supports the FAA’s strategic goal to provide the next level of safety . B y achieving the lowest possible accident rate and always improving safety, all users of our aviation sy stem can arrive safe ly at their destinations. This rulemaking is promulgated under the authority described in 49 U.S.C. 106(f), which vests final authority

in the Administrator for carrying out all functions, powers, and duties of the administration relating to the promulgation of regulations and rules, and 44701(a)(5), which requires the Administrator to promulgate regulations and minimum standards for other practices, methods, and procedures necessary for safety in air commerce and national security. This rulemaking is al so promulgated under the specific authority found in the Airline Safety and Federal Aviation Administration Extension Act of 2010 (Public L aw 111
- 216) which directed the FAA to convene an aviation rulemaking committee (ARC) and conduct rulemaking based on the ARC recommendations regarding mentoring, professional development and leadership and command training for pilots serving in part 121 operations and to include in leadership and command training, instruction on compliance with flightcrew member duties under 14 CFR 121.542
. The information collection is required for the full implementation of the regulations promulgated under this authority
. As further described in response to question 12 herein, the FAA expects respondents to modify

training program s and training courseware to comply with the proposed rule requirements , if issued in a final rule
.2

2. How, by

whom, and for what purpose is the information used. This request for clearance reflects requirements necessary under 14 CFR part 121 to ensure safety- of
- flight by making certain that adequate training is obtained and maintained by those who operate under this part of the regulation. The FAA would review th e respondents’ training programs and training courseware through routine certification, inspection and surveillance of certificate holders using part 121 pilot training and qualification programs to ensure compliance and adherence to regulations and, where necessary, to take enforcement action. 3. Extent of automated information collection. In accordance with the Government Paperwork Elimination Act (GPEA), the FAA encourages the use of automation and electronic media for the gathering, storage, present ation, review, and transmission of all requests, records, reports, tests, or statements required by this proposed rule with the provision that such automation or electronic media has adequate provision for security (i.e., that such submissions may not be altered after review and approval/ acceptance b y the FAA) and that the sy stems or applications are compatible with the sy stems or applications used by the FAA. The amendments to part 121 in this proposed rule do not affect the current methods of reporting , gathering, storing, presenting , review ing, and transmitting all requests, records, reports, tests, or statem ents required b y part 121. This recordkeeping includes different types of media such as electronic and paper records (e.g., courseware, training records, and manuals).
4. Efforts to identify

duplication. We have reviewed other FAA public
- use reports and find no duplication. Also, the FAA knows of no other agency

collecting the same information. The information sought is particular to the training and qualification requirements for certificate holders who conduct pilot training and qualification in accordance with the provisions of 14 CFR part 121. The information necessary is available from that certificate holder onl y, and is not available from any other source. 5. Efforts to minimize the burden on small businesses **.** The FAA believes that the collection of information associated with this proposed rule would not have a significant impact on small businesses or other small entities
. The material published in conjunction with this proposed rule is informative and explanatory with regards to the revised training requirements . Further, an existing certificate holder or an applicant for a certif icate can be guided through the administrative requirements by the local FAA principal operations inspector assigned to that air carrier and, if necessary , by representatives of the Washington headquarters staff. As stated in the Regulatory Flexibility

A ct anal ys is published with the NPRM, the FAA expects only minimal new training documentation, reporting, and record
- keeping compliance requirements. These burdens affect all certificate holders and are not unique to small entities.3

6. Impact of less frequent collection of information **.** As discussed above, the FAA would review the respondents’ training programs and training courseware through routine certification, inspection and surveillance of certificate holders using part 121 pilot training and qualification programs to ensure compliance and adherence to regulations
. If a new applicant seeking to use a part 121 pilot training and qualification program is not able to produce the documents for approval to show compliance with the requirements of the proposed rule, the FAA would not be able to issue the applicant an air carrier certificate. Similarly, if existing certificate holder s do not continue to provide this information for review and make it available for inspection upon request of the FAA, the FAA would not be able to determine if the certificate holder continues to administer the program according to the approval
. Current regulations already provide that the information required b y this proposed rule be maintained in training programs and manuals. These current regulati ons are:

 § 121.135 Manual contents  § 121.403 Training Program Curriculum  § 121.405 Training Program and Revision: Initial and Final Approval 7
. Special circumstances. There are no special circumstances associated with this collection
. The information collection requirements related to the proposed rule provisions , including those responsive to the mandate in § 206 of Public L aw 111
- 216, are consistent with 5 CFR 1320.5(d)(2)(i)
- (viii)
. 8. Compliance with 5 CFR 13 20.8 : This proposal was published in the Federal Register on XX/XX/XX, vol. X , no. X , pages XX
XX , and encouraged public comment to be made. All comments received would be reviewed and evaluated as potential reasoning to modify the proposal prior to publication of a final rule
. 9. Pay ments or gifts to respondents. There are no monetary

considerations for this collection of information
. 10. Assurance of confidentiali ty : The respondents have been given no assurance of confidentiality
. 11. Justification for collection of sensitive information : There are no questions of a sensitive nature. 12. Estimate of burden hours for information requested : These proposed amendments to part 121 set out prerequisites and levy requirements that must be met by certificate holders using part 121 pilot training and qualification programs and b y those individuals who serve in given capacities for those certificate holders. The e stimates for hours4

and costs are broken down by development and approval of new and revised training curriculums followed b y pilot training recordkeeping. The FAA anticipates that certificate holders would incur costs for the following groups of provisions:

 Operati ons familiarization for new
- hire pilots (§ 121.432(d) ) ;  Leadership and command and m entoring ground training for pilots currently serving as pilot in command ( PI C ) (§ 121.429) ;  Upgrade training curriculum requirements (§§ 121.420 and 12 1.426) ;  Recurrent PIC leadership and command and mentoring ground training (§ § 121.409(b) and 121.427) ;  Part 121, Appendix H; and  Approval of Qualification Standards Document for certificate holders using an Advanced Qualification Program (AQP) (§ 121.909 )
. The FAA estimated the costs associated with the development and approval of new and revised training curriculums and the recordkeeping for leadership and command and mentoring training for current PI Cs as a one
- time cost. For recordkeeping costs associ ated with recurrent PI C leadership and command and mentoring training and operations familiarization for new hire pilots , the FAA used the date on which compliance with the provision is required as the estimated date on which paperwork costs would start to accrue . Compliance is required 2 years after the effective date ( 60 day s after the final rule is published in the Federal Regi ster)
. Developm ent and a

pproval of new and revised training curriculums For the development and approval of new and revised training curriculums, the FAA estimated the paperwork costs for these provisions by multiplying the hourl y rate of the person responsible by the number of estimated hours to develop and submit the new or revised training curriculum. (In all cases we assum e that a ground instructor would develop and submit the new or revised training curriculum and that the ground instructor fully burdened wage is $ 44 per hour. 1 ) W e then multiplied these costs by the number of certificate holders affected b y the provision. Leadership and command and m entoring ground training for pilots currently serving as PIC (§ 121.429) and recurrent PIC leadership and command and mentoring training (§ § 121.409(b) and 121.427) Proposed § 121.429 would require one time development of a training course for leadership and command and mentoring for current PI Cs. This course must be submitted to the FAA for approval.

1 Training instructor hourly wage rate of $31 multiplied by 1.42 to account for costs of employer provided benefits. Wage based on 2013 B ureau of Labor Statistics (B LS ) Occupational Employment Statistics for Air Transportation Industry
. (http://www.bls.gov/oes/current/naics4_481100.htm): Training and De velopment Specialists (13

- 1151)
. Wage multiplier from BLS, Employer costs for Employee compensation

- June 2013 , Table 5 , Private Industry
. ( http://www.bls.gov/news.release/pdf/ecec.pdf )5

Proposed revisions to §§ 121.409(b) and 121.427 would require one time revision to the certificate holder ’s approved recurrent PIC training curriculum. This revised curriculum must be submitted to the FAA for approval. The FAA estimates a total of 40 hours of ground instructor time for development and submission of both the curriculum for current PI Cs and the revision to the recurrent PIC training curriculum. Assuming 81 affected certificate holder s, the FAA estimates that these proposed provisions would result in a one
- time total cost of $ 142,560 for all affected certificate holder s. Upgrade training curriculum requirements (§§ 121.420 and 121.426) Proposed §§ 121.420 and 121.426 would require one time revision to the certificate holder ’s approved second in command (SI C) to PIC upgrade training curriculum. This revised curriculum must be submitted to the FAA for approval. The FAA estimates a total of 80 hours of ground instructor time for development and submission of the revised SIC to PI C upgrade training curriculum. Assuming 81 affected certificate holder s, the FAA estimates that these proposed provisions would result in a one
- time cost of $ 285,120 for all affected certificate holder s. Part 121 Appendix H requirements The p roposed revision to part 121 appendix H would require one time revision to the certificate holder ’s approved training program to remove the pilot experience prerequisites for using a level C full flight simulator during training and checking. This revised training program must be submitted to the FAA for approval. The FAA expects that the program updates to refl ect this change are minimal and are subsumed in the paperwork costs for the collective amendments made to the training provisions in this proposed rule. The FAA estimates there are no costs for this proposed provision. Approval of Qualification Standards Document for c ertificate h older s using an AQP (§ 121.909) Although the proposed rule does not make any changes to § 121.909, when the new subpart s N and O training requirements become effective, certificate holder s that use AQP would have to review their training programs to make sure they address the new subpart s N and O requirements . It is possible that certificate holders may make a one
- time revis ion to their Qualifications Standards Document required b y § 121.909 during this process to address the revised subpart s N and O requirements. This is a cost that only

applies to certificate holder s that use AQP for pilot training because they are the onl y ones who must meet the § 121.909 requirements. Therefore, this pro vision does not apply to certificate holder s who only train their pilots under a training program in accordance with subparts N and O of part 121
.6

For each of the 25 certificate holder s with an approved AQP, the FAA estimates 3 hours of ground instructor time for development and submission of the revised Q ualification Standards Document
. The FAA estimates that th is proposed provision would result in one
- time cost of $ 3,300 across all certificate holder s who train their pilot s under AQP. Recordkeeping For the pilot training recordkeeping, the FAA estimated the paperwork costs for these provisions by first multiplying the number of required entries by the estimated number of pilots affected. Second, we multiplied the total number of entries by .001 hours (the time required to make each entry). Lastl y, we multiplied the total time to make all entries b y the hourl y rate of the person responsible for making the entries. In all cases, the FAA assumes that the person making the entries is a clerical employee with an estimated fully burdened wage of $ 26 per hour. 2 Leadership and command and m entoring ground training for pilots currently serving as PIC (§ 121.429) A record showing compliance with this requirement for current PI Cs would need to be retained in accordance with § 121.683(a)(1). This would be a one
- time burden. The FAA assumes that this cost would be incurred in the year prior to the compliance date and estimates that during that year 37,527 pilots would be affected and would require one record. The FAA estimates 38 hours of clerical time for entry of these records. The FAA estimates that th is proposed provision would add a one - time cost of $ 988 for all affected certificate holder s. R ecurrent PIC leadership and command and mentoring ground training (§ 121.427) A record showing compliance with this requirement for current PI Cs would need to be retained in accordance with § 121.683(a)(1). This would be an addition to the current recordkeeping burden approved under OMB Control Number 2120
- 0008. P IC s are required to complete the recurrent training every 3 years . Over the first three years after the compliance date of the rule, the FAA estimates that 35,61 1 pilots would complete recurrent training. 3 Each of the estimated 35, 61 1 pilots affected would require one record
. The FAA estimates 36 hours of clerical time for entry of these records.
2 The clerk hourly wage rate of $18 multiplied by 1.42 to account for costs of employer provided benefits. Wage based on 2013 BLS Occupational Employment Statistics for Air Transportation I ndustry
. (http://www.bls.gov/oes/current/naics4_481100.htm): Information and Record Clerks (43

- 4000)
. Wage multiplier from BLS, Employer costs for Employee compensation

- June 2013 , Table 5, Private Industry
. ( http://www.bls.gov/news.release/pdf/ecec.pdf )
3 The number of pilots affected by recurrent training is lower than the number affected by one

- time training of current pilots because of retirements and loss of medical certificate. The new replacement p ilots would take the training during upgrade training.7

The FAA estimates that th is proposed provision would result in costs of $ 936 over 3 years for all affected certificate holder s. Operati ons familiarization for new

- hire pilots (§ 121.432(d) ) Section 121.432(d) proposes a new qualification requirement for new
- hire pilots to complete operations familiarization consisting of 2 operating cycles . A record showing compliance with this requirement for each new
- hire pilot would need to be retained in accordance with § 121.683(a)(1). This would be an addition to the current recordkeeping burden approved under OMB Control Number 2120
- 0008. The FAA estimates all affected certificate holder s would have a total of 8,231 new - hire pilots over the first three ye ars that the rule is in effect
. Each of the estimated 8,231 pilots affected would require one record. The FAA estimates 9 hours of clerical time for entry of these records. The FAA estimates that these proposed provisions would result in costs of $ 234 across 3 ye ars for all affected certificate holder s. **Summary of Estimated Paperwork Costs Proposed Rule Requirement**  **Number of**  **Records Number** 

**of Hours Wage**  **Number of Certificate**  **Holders Total Cost**  **Development and Approval of new and revised training curriculums**  L eadership and command and mentoring ground training for pilots currently serving as PIC (§ 121.429) and recurrent PIC leadership and command and mentoring training (§§ 121.409(b) and 121.427) N/A 40 $ 44 * 81 $ 142,560 Upgrade training curriculum (§§ 121.420 and 121.426) N/A 80 $ 44 * 81 $ 285,120 Part 121 Appendix H N/A 0 81 $
- Approval of Qualification Standards Document (§ 121.909) N/A 3 $ 44 * 25 $ 3,300 **Recordkeeping** L eadership and command and mentoring ground training for pilots currently serving as PIC (§ 121.429) 37,527 38 $ 26** N/A $ 988 Recurrent PIC leadership and command and me ntoring ground training (§121.427) 35,61 1 36 $ 26** N/A $ 936 Operations familiarization for new
- hire pilots (§ 121.432(d)) 8,231 9 $ 26** N/A $ 234 **Total** 206 $ 433,138 * Fully burdened hourly

wage for ground instructor
. ** Fully burdened h ourly wage for clerical employee. 13. Estimate of total annual costs to respondents **.**8

There are no additional costs not already included in item 12. 14. Estimate of cost to the Federal government. The recordkeeping requirements for the public respondents imposed by this proposed rule would not add costs to the Federal Government. The proposed rule reporting requirements do not require the Federal Government to:
• Create any special data entry or information collection sy stems,
• Update any current data entry or information collection sy st ems, or
• Hire additional staff to review or inspect the additional paperwork the proposed rule adds. 15. Explanation of program changes or adjustments. This is a new collection therefore , it is a program change. 16. Publication of results of data collection. There is no plan for tabulation or publication. 17. Approval for not displaying the expiration date of OMB approval. No such approval is being sought. This information collection does not involve the use of a standard form to submit information to the FAA . This information collection requires certificate holders to update training programs and courseware. Certificate holders would be required to maintai n these documents for display and inspection upon request of the FAA.
18. Exceptions to certification statement. The FAA certifies compliance with all provisions of the Paperwork Reduction Act. There are no exceptions.