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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 approval clearance for the information collection entitled, Pilot 

Professional Development, (OMB Control No. 2120-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 directly supports the FAA’s strategic goal to provide the next level of safety. 

By achieving the lowest possible accident rate and always improving safety, all users of our 

aviation system can arrive safely 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 also promulgated under the specific authority found in the Airline Safety and 

Federal Aviation Administration Extension Act of 2010 (Public Law 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 programs and training courseware to comply with the proposed 

rule requirements, if issued in a final rule.
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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 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 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, presentation, 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 by the FAA) 

and that the systems or applications are compatible with the systems 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, reviewing, and transmitting all requests, records, reports, tests, or 

statements required by 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 only, 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 certificate 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 Act analysis 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. 
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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 holders 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 by this proposed rule be 

maintained in training programs and manuals. These current regulations 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 Law 111-216, are consistent with 5 CFR 1320.5(d)(2)(i)-(viii).

8. Compliance with 5 CFR 1320.8: 

This proposal was published in the Federal Register on XX/XX/XX, vol. X, no. X, pages XXXX, 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. Payments or gifts to respondents. 

There are no monetary considerations for this collection of information.

10. Assurance of confidentiality: 

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 by those 

individuals who serve in given capacities for those certificate holders. The estimates for hours 
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and costs are broken down by development and approval of new and revised training curriculums 

followed by pilot training recordkeeping. 

The FAA anticipates that certificate holders would incur costs for the following groups of 

provisions:

 Operations familiarization for new-hire pilots (§ 121.432(d));

 Leadership and command and mentoring ground training for pilots currently serving as 

pilot in command (PIC) (§ 121.429);

 Upgrade training curriculum requirements (§§ 121.420 and 121.426);

 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 PICs as a one-time cost. For recordkeeping costs associated with recurrent PIC

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 days after the final rule is published in the Federal Register). 

Development and approval 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 hourly 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 assume 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) We 

then multiplied these costs by the number of certificate holders affected by the provision. 

Leadership 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)

Proposed § 121.429 would require one time development of a training course for leadership and 

command and mentoring for current PICs. 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 Bureau of Labor Statistics (BLS) Occupational Employment Statistics for Air Transportation 

Industry. (http://www.bls.gov/oes/current/naics4_481100.htm): Training and Development 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)
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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 PICs and the revision to the recurrent PIC training curriculum. 

Assuming 81 affected certificate holders, the FAA estimates that these proposed provisions 

would result in a one-time total cost of $142,560 for all affected certificate holders.

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 (SIC) 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 PIC upgrade training curriculum.

Assuming 81 affected certificate holders, the FAA estimates that these proposed provisions 

would result in a one-time cost of $285,120 for all affected certificate holders.

Part 121 Appendix H requirements

The proposed 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 reflect 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 certificate holders using an AQP (§ 121.909)

Although the proposed rule does not make any changes to § 121.909, when the new subparts N 

and O training requirements become effective, certificate holders that use AQP would have to 

review their training programs to make sure they address the new subparts N and O 

requirements. It is possible that certificate holders may make a one-time revision to their 

Qualifications Standards Document required by § 121.909 during this process to address the 

revised subparts N and O requirements.

This is a cost that only applies to certificate holders that use AQP for pilot training because they

are the only ones who must meet the § 121.909 requirements. Therefore, this provision does not 

apply to certificate holders who only train their pilots under a training program in accordance 

with subparts N and O of part 121.
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For each of the 25 certificate holders with an approved AQP, the FAA estimates 3 hours of 

ground instructor time for development and submission of the revised Qualification Standards 

Document.

The FAA estimates that this proposed provision would result in one-time cost of $3,300 across 

all certificate holders who train their pilots 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). Lastly, we multiplied the total time to make all entries by the hourly 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 mentoring ground training for pilots currently serving as PIC 

(§ 121.429)

A record showing compliance with this requirement for current PICs 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 this proposed provision would add a one-time cost of $ 988 for all 

affected certificate holders.

Recurrent PIC leadership and command and mentoring ground training (§121.427)

A record showing compliance with this requirement for current PICs 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. 

PICs 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 35,611 pilots would complete recurrent 

training.3Each of the estimated 35,611 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 Industry.

(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)

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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 pilots would take the 

training during upgrade training.
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The FAA estimates that this proposed provision would result in costs of $ 936 over 3 years for 

all affected certificate holders.

Operations 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 holders would have a total of 8,231 new-hire pilots

over the first three years 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 years 

for all affected certificate holders.

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

Leadership 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

Leadership 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 

mentoring ground training (§121.427) 35,611 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 hourly wage for clerical employee.

13. Estimate of total annual costs to respondents. 
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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 systems, 

• Update any current data entry or information collection systems, 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 

maintain 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.