2120-0039 2021 (1)

Supporting Statement

OMB-2120-0039

Part 135- Operating Requirements: Commuter and on-Demand Operations and Rules

Governing Persons on Board such Aircraft

Summary of Changes:

• The costs to the Federal Government section was amended. All of the responsibility for oversight associated with the regulations below is part of an Aviation Safety Inspector’s normal job functions. No additional costs are accrued due to this collection of information.

• The wage rates for employees was updated according to current numbers.

• The numbers of operators, flight attendants, and pilots was updated to July 2021 numbers.

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

Title 49 USC, Section 44702 empowers the Secretary of Transportation to issue air carrier certificates and to establish minimum safety standards for the operation of the air carrier to whom such certificates are issued. Under the authority of Title 49 USC, Section 44701, Title 14 Code of Federal Regulations (14 CFR) part 135 prescribes the terms, conditions, and limitations as are necessary to ensure safety in air transportation.

This collection of information supports the Department of Transportation’s strategic goal of safety.

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.

Each operator which seeks to obtain, or is in possession of, an air carrier or FAA operating certificate is mandated to comply with the requirements of 14 CFR part 135 in order to maintain data which is used to determine if the carrier is operating in accordance with minimum safety standards. Air carrier and commercial operator certification is completed in accordance with 14 CFR part 119. Part 135 contains operations and maintenance requirements. This collection involves a large amount of information. Therefore, it is collected as necessary. The information collected is to assure compliance with the regulations. The burden associated with 14 CFR part 135 is associated with reporting, recordkeeping and disclosure. The individual burdens are described in detail in Question 12. The burdens ensure compliance with 14 CFR part 135. The information reported, disclosed, or recorded is received by FAA inspectors to ensure compliance with the regulations. Information collected is not disseminated to the public.

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.

The burden associated with 14 CFR part 135 is associated with reporting and recordkeeping. The FAA has encouraged the use of automation by the air carriers and commercial operators to reduce their burden. The FAA has deployed a Web based Operations Safety System (WebOPSS) which facilitates issuance of operators’ operations specifications (https://webopss.faa.gov). This system also facilitates reporting requirements by its report features. This system allows operators to electronically submit and electronically sign the operations specifications. FAA ensures the consistent application of FAA regulations and policy through the use of standard template forms for operations specifications. Operators have the option of using the electronic operations specifications system to input their operator-specific information into draft operations specifications and electronically transmit them for FAA review and approval if the certificate holder meets all requirements. Currently 1,219 operators with part 135 operating authority have elected and are equipped to use the electronic operations specifications system. Electronic operations specification management complies with the Government Paperwork Elimination Act.

Operations specifications are issued to approve of new authorizations/limitations or new aircraft. In addition to operations specifications, changes to manuals, procedures, minimum equipment lists, briefing cards or other documents are required. The required maintenance and inspection programs are authorized to be kept and maintained electronically or in paper form. Certain relief is provided from carrying maintenance manuals onboard the aircraft.

All reporting provisions and approval processes can be accomplished electronically, including operations and maintenance manuals, crewmember and aircraft dispatcher records, maintenance records, and minimum equipment lists; however, certain documents such as passenger briefing cards must currently be available in paper form for safety reasons.

The FAA continues to work with operators to develop procedures to allow expedited changes to operations specifications, such as adding aircraft that are substantially similar to aircraft currently approved for operation.

Email facilitates communications between the operator and the FAA. The results of the information collection will not be made available to the public over the internet. There are no plans to make this information available as much of it is proprietary to each carrier.

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 our other FAA public-use reports and find no duplication. Also, we know of no other agency collecting information from air carriers and commercial operators prescribing the terms, conditions, and limitations of their operating certificate.

This information, required by 14 CFR part 135, is to ensure safety in air transportation.

Further the information collected is only available from the applicant applying for an operating certificate and from certificate holders operating under part 135. The applicant/operator must prescribe his/her own data based on the operation. The information is not available from any other source.

However, if a certificate holder also conducts fractional ownership programs under part

91, Subpart K of the regulations, the proposed rule for those operations authorizes the operator to use certain records required by part 135 to satisfy the equivalent requirements and recordkeeping provisions of a fractional ownership program. The paperwork reduction provisions are further discussed and applied in the fractional ownership proposed rule and paperwork reduction package for that rule.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

All applicants are provided guidance for the certification and administrative processes by the Certificate Holding District Office. FAA guidance documents (guidance for FAA inspectors for approving programs) are available to the public through the internet. This information and availability greatly assists in the preparation of required documents. Use of email facilitates communications between the approving inspectors and the applicants. WebOPSS facilitates issuance of authorizations. Operations specifications outlining authorizations and limitations are issued specific to an operator’s operation. For other reporting or recordkeeping burdens listed, the smaller operators have burdens in proportion to the size of their operation. For example, single pilot operations are not required to prepare an operations manual or training program which significantly reduces the burden. The number of records and required reports are proportional to the number of pilots and aircraft used by the operator. Further, in several cases, such as for passenger briefings or aircraft checklists, commercially produced products are available from the aircraft manufacturer.

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.

The frequency of information collection is dependent on the applicant’s business plan and application for new kinds of operation or types of aircraft. The frequency of information collection, for the most part, is determined by the business activity of the operator. There may be safety implications for some forms of information.

The FAA ensures compliance with the regulations by collecting this information. If the FAA did not collect this information then the ability to ensure carriers were compliant would be much more difficult. It would impact safety in a negative manner.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document; requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

This collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5 (d) (2) (i)-(viii), with the exception that some records are maintained longer than three years. Qualification records for crewmembers are maintained for as long as the person is employed by the operator. With respect to maintenance recording/recordkeeping requirements, section 135.439 specifies maintenance record and retention requirements and states the records must be transferred with the aircraft at the time it is sold. This means that there are certain aircraft maintenance records that stay with the aircraft for the life of the aircraft and are transferred from owner to owner.

8. Provide information on the PRA Federal Register Notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

A Federal Register Notice published on August 10, 2021 (86 FR 43718), solicited public comment. No comments were received.

FAA stakeholders have frequent interaction with the FAA through industry meetings, groups, and their local FAA office during which they may offer feedback.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

There are no monetary considerations for this collection of information.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

Respondents have been 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. The statement should:

There are 1,903 part 135 operators. The specific 14 CFR part 135 reporting requirements are prescribed by the following regulatory sections. This report lists the numbers of affected air carriers and commercial operators and bases cost figures on updated salary estimates. The number of air carriers and commercial operators changes daily as a result of mergers or by the surrendering of certificates. The numbers of air carriers and commercial operators used in this report represent June 2021, the most recent available.

The following costs are based on the paperwork burden being done by an Operations Manager or equivalent staffer earning approximately $25.24 an hour¹. A 31.4 percent multiplier was then applied to account for fringe benefits which brings the salary to the salary to $33.17.² To account for overhead, a multiplier of 17 percent was applied.³ Therefore, the estimated hourly salary for a Technical Analyst is $38.81.

The average Flight Operations Manager earns approximately $30.11 an hour.⁴ A 31.4 percent multiplier was then applied to account for fringe benefits which brings the hourly pay to $39.56.⁵ To account for overhead, a multiplier of 17 percent was applied.⁶ Therefore, the estimated hourly salary for a Flight Operations Manager is $46.29.

An Administrative Assistant earns approximately $16.19 an hour⁷. A 31.4 percent multiplier was then applied to account for fringe benefits which brings the salary to $21.27.⁸ To account for overhead, a multiplier of 17 percent was applied.⁹ Therefore, the estimated hourly salary for an Administrative Assistant is $24.88.

The average Maintenance Manager earns approximately $30.38 an hour.¹⁰ A 31.4 percent multiplier was then applied to account for fringe benefits which brings the hourly pay to $39.92.¹¹ To account for overhead, a multiplier of 17 percent was applied.¹² Therefore, the estimated hourly salary for a Maintenance Manager is $46.71.

Pilot = Note: There is a wide range in salaries that reflects the diversity of the part 135 industry. Data received for pilot salaries was from a Pilot Compensation Survey done published in the June 2020 issue of Professional Pilot Magazine.¹³ The Pilot salaries below are the averages of First Officer and Captain pay across varying aircraft. The salary survey provided numbers based on types of turbojet airplanes, rotorcraft, turboprops, fractional ownership operations, but did not consider lower salaries of pilots for single engine or multiengine reciprocating powered airplanes that make up a large segment of the industry (4000 reciprocating powered airplanes). An average salary was estimated based on the pilot in command/ second in command turboprop, turbojet, fractional ownership, and helicopter average salaries and an estimate of airplane pilot salaries = $44.00 per hour; Flight Attendant = $24.00 per hour.

The average Pilot earns approximately $44.00 an hour. A 31.4 percent multiplier was then applied to account for fringe benefits which brings the hourly pay to $57.82.¹⁴ To account for overhead, a multiplier of 17 percent was applied.¹⁵ Therefore, the estimated hourly salary for a Maintenance Manager is $67.03.

The average Flight Attendant earns approximately $24.00 an hour. A 31.4 percent multiplier was then applied to account for fringe benefits which brings the hourly pay to $31.54.¹⁶ To account for overhead, a multiplier of 17 percent was applied.¹⁷ Therefore, the estimated hourly salary for a Maintenance Manager is $36.90.

§135.2, Compliance Schedule for Transition to Part 121. This was a one-time event associated with the transition of part 135 operators with aircraft of 10 or more seats that are operated in scheduled service, to comply with part 121 requirements. This action was completed by March 20, 1997.

§135.3, Rules applicable to operations subject to this part. Required a one-time application burden for a transition plan. This plan was to be submitted by March 19, 1996, and detail plans for compliance with the training requirement by March 19, 1997.

This section also has a voluntary provision for operators to comply with the training requirements of subparts N and O of part 121 instead of the training requirements of subparts E, G, and H of part 135.

§135.19, Emergency operations. Requires a person who exercises emergency authority to deviate from a rule of part 135 to send a report of the aircraft operation, description of the deviation and reasons for it. This report must be sent to the FAA Flight Standards

Office charged with the overall inspection of the certificate holder.

Estimated number of reports a year 100 responses

Estimated technical time x .5

Total estimated technical time 50.0 hrs.

Estimated cost for technical time (pilot) x$67.03 per hour

Total estimated burden of technical time $3,352

Total hour burden: 50 hrs

Total cost burden: $3,352

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	100
# of Responses per respondent	1
Time per Response	.5 Hours
Total # of responses	100
Total burden (hours)	50 Hours

§135.21 Manual requirements

§135.21 (a) requires each certificate holder, except those who use only one pilot, to prepare and keep current a manual for the use of flight, ground, and maintenance personnel. The original preparation of a manual is part of certification and covered in part 119 (119.35) under OMB clearance number 2120-0593, Certification: Air Carriers and Commercial Operators—FAR Part 119. Certificate holders of a limited size operation are authorized deviations from all or part of the manual.

§135.21 (b) requires each certificate holder to maintain at least one copy of the manual at its principal base of operations. No burden is associated with this section.

§135.21 (c) states that the manual most not be contrary to applicable Federal regulations, foreign regulations applicable to the certificate holder’s operations in foreign countries, or the certificate holder’s operating certificate or operations specifications. No burden is associated with this section.

§135.21 (d) requires that the manual, or appropriate portions of the manual (and changes

and additions) be made available to maintenance, ground personnel, flight crewmembers,

and representatives of the Administrator. This one-time or incidental activity does not lend itself to a burden calculation.

§135.21 (e) requires each employee to keep his/her manual up-to-date with changes furnished to them. No burden is associated with this section.

135.21 (f) and (g) require parts of the manual to be available for use by ground or flight personnel and the information in the manuals to be displayed clearly and be retrievable in the English language.

Certificate holders of a limited size operation are authorized deviations from all or part of the manual. Additionally, §135.23 contains guidance as to the content of the manual.

Numerous procedures are listed that require inclusion in the manual. Manual guidance is required appropriate to the size and authorizations applicable to an individual operator. A single pilot operator is not required to have a manual. There are approximately 1903 operators of which 25 operators are single pilot operations and not required to have a manual.

Estimated number of operators required to have a manual 1,878

Estimated revisions per year x 5

Total estimated number of manual revision responses 9,390

Estimate 2 technical hrs. per revision x 2

Total estimated technical time 18,780

Cost of technical time (Flt ops Mgr/Maint mgr averages) x $46.50

Total estimated burden for technical time $873,270

Estimated number of revisions 9,390

Estimate .5 admin hrs per revision x .5

Total estimated admin asst. time 4,695

Cost of admin asst. time x $24.88

Total estimated burden for admin time $116,812

Total hour burden 23,475

Total cost burden: $990,082

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		1878
# of Responses per respondent		5
Time per Response		2.5 Hours
Total # of responses		9,390
Total burden (hours)		23,475 Hours

§135.25, Aircraft requirements.

135.25 (d)(4) requires the operator to file a copy of an aircraft lease or charter agreement with the FAA Aircraft Registry. This requirement only applies to foreign registered aircraft.

Estimated number of agreements annually 3

Approximately .2 hours of admin time x.2

Total estimated admin time .6

Cost of admin time x$24.88

Total estimated burden for admin time $14.93

Total hour burden: .6

Total cost burden: $14.93

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	3
# of Responses per respondent	1
Time per Response	.2 Hours
Total # of responses	3
Total burden (hours)	.6 Hours

§135.63 Recordkeeping requirements.

(a) Each certificate holder shall keep the following records:

Current list of aircraft used or available for use. It is estimated that one half of all operators will update aircraft records each year. It is estimated that these operators will update records 2 times per year.

Estimated number of revisions 1,903

One half of operators x .5

Records per year x 2

Total Revisions 1,904

Approximately 1 hours of technical time per revision 1904 hours

Cost of technical time (Flt ops/Maint. Mgr average) x $ 46.50

Total estimated burden cost $88,536

Total estimated burden hours 1904

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		952
# of Responses per respondent		2
Time per Response		.5 Hours
Total # of responses		1904
Total burden (hours)		1904 Hours

Requires individual records of each pilot be maintained. This includes information on certificates, ratings, experience, duties, medical information, results of tests, flight time, training and action concerning release from employment.

PILOTS:

Estimated number of pilots (pilot in command and second in command) 25,365

Average number of entries annually per pilot (other than flight and duty)

x 4

Total estimated number of entries 101,460

Approximately .1 hour of admin time per entry x .1

Total estimated admin time 10,146

Cost of admin time x $24.88

Total estimated cost burden for admin time $252,432

Pilot Records

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		25,365
# of Responses per respondent		4
Time per Response		.1 Hour
Total # of responses		101,460
Total burden (hours)		10,146 Hours

Flight and duty for pilots:

Estimated number of pilots 25,365

Average number of entries annually per pilot x 200

Total estimated number of entries 5,073,000

Approximately .1 hour of admin time x .1

Total estimated admin time 507,300 hrs

Cost of admin time (admin) x $24.88

Total estimated cost burden for admin time $12,621,624

Total Hour Burden for Pilot Entry: 517,446 Hours

Total Monetary Burden for Pilot Entry. $12,874,056

Pilot Flight and Duty

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		25,365
# of Responses per respondent		200
Time per Response		.1 Hour
Total # of responses		5,073,000
Total burden (hours)		507,300 Hours

Requires individual records for each flight attendant showing compliance with duty and rest requirements.

Estimated number of flight attendants 656

Average number of flight attendant personnel records x3

Total estimated number of records 1968

Approximately .1 hour of admin time per record .1

Total estimated admin time 196.8

Cost of admin time x$24.88

Total estimated cost burden for admin time $4,896

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		656
# of Responses per respondent		3
Time per Response		.1 Hour
Total # of responses		1968
Total burden (hours)		197 Hours

Flight and duty for flight attendants:

Estimated number of flight attendants 656

Average number of entries annually per attendant x 200

Total estimated number of entries responses 131,200

Approximately .1 hour admin time per entry x .1

Total admin time 13,120

Cost of admin time x$24.88

Total estimated cost burden for admin time $326,425

Total Hour Burden for Flight Attendant Entry: 13,317 Hours

Total Monetary Burden for Flight Attendant Entry. $331,321

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		656
# of Responses per respondent		200
Time per Response		.1 Hour
Total # of responses		131,200
Total burden (hours)		13,120 Hours

Requires for multiengine aircraft, the preparation of a load manifest for each flight.

Approximately 7700 multiengine aircraft make an average of 2 takeoffs daily making the paper burden for technical time approximately .1 hour per takeoff.

Approximate number of multiengine aircraft 7,700

Average number of takeoffs daily x2

15,400

Estimated number of annual takeoffs x365

Estimated total takeoffs annually 5,621,000

Approximately .1 hour technical time per takeoff x .1

Total estimated technical time 562,100

Cost of technical time (pilot) x$67.03

Total estimated burden for technical time $37,677,563

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		7700
# of Responses per respondent		730
Time per Response		.1 Hour
Total # of responses		5,621,000
Total burden (hours)		562,100 Hours

TOTAL BURDEN: 1,094,767 Hours and $50,971,476

§135.64 Retention of contracts and amendments: Commercial operators who conduct intrastate operations for compensation or hire.

It is estimated:

15 contracts annually x 50 operators = 750 contracts:

670 (written contracts) x .5 hour technical time

80 (oral contracts) x .5 hour admin time (memo)

Total estimated number of written contracts 670

Approximately .5 hours technical time x .5

Total estimated technical time 335

Cost for technical time (General Mgr) x$38.81

Total estimated burden of technical time $13,001

Total estimated number of oral contracts 80

Approximately .5 hour admin time x.5

Total estimated admin time 40

Cost for admin time x$24.88

Total estimated burden of admin time $995

Written Contracts

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		670
# of Responses per respondent		1
Time per Response		.5 Hours
Total # of responses		670
Total burden (hours)		335 Hours

Oral Contract

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		80
# of Responses per respondent		1
Time per Response		.5 Hours
Total # of responses		80
Total burden (hours)		40 Hours

§135.65 Reporting mechanical irregularities. Pilots are required to record each mechanical irregularity that comes to the pilot’s attention during flight.

Estimated number of operators 1,903

Estimated 75 irregularities per year per operator x75

Total number of irregularities 142,725 responses

Approximately .25 hours of technical time per entry x .25

Total estimated technical time 35,681

Cost of technical time (Pilot) x $67.03

Total estimated cost burden of technical time $2,391,714

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1903
# of Responses per respondent	75
Time per Response	.25 Hours
Total # of responses	142,725
Total burden (hours)	35,681 Hours

§135.79 Flight locating requirements. Each certificate holder must have procedures for locating each flight for which a flight plan is not filed. This procedure is part of the manual requirement of 135.21. Flight plans are cleared by OMB 2120-0026, Domestic and International Flight Plans. The flight locating information shall be prepared for each flight that is not on a FAA flight plan, and shall be retained until completion of the flight.

Approximate number of newly certificated operators per year 60

Approximate 25% will apply for separate flight locating procedures x .25

Total estimated number of applicants 15

Estimate .5 hours technical time x .5

Total estimated technical time 7.5

Cost of technical time (Flt Ops Mgr) x$46.29

Total estimated cost burden of technical time $347

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		15
# of Responses per respondent		1
Time per Response		.5 Hours
Total # of responses		15
Total burden (hours)		7.5 Hours

§135.83 Operating information required: Requires each operator to provide cockpit checklists. Most companies will use checklists provided by the aircraft manufacturer.

Some will develop their own checklists based on manufacturer’s procedures. It is estimated that 20% of the companies will develop their own checklists (average of 2 aircraft types per company).

Number of part 135 operators (1903) x 20% x 2 checklists per co. 760

Estimate 2 hours technical time x 2

Total estimated technical time 1520 hr

Cost of technical time (Flt Ops Mgr) x$46.29

Total estimated cost burden of technical time $70,360

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		380
# of Responses per respondent		2
Time per Response		2 Hours
Total # of responses		760
Total burden (hours)		1520 Hours

§ 135.117, Briefing of passengers before flight. This section requires an oral safety briefing supplemented by a printed briefing card. Many companies will use briefing cards provided by the aircraft manufacturer. Others will develop their own customized briefing cards. Cards must be available at each aircraft seat and an oral briefing must be given for each flight, unless the passengers have been previously briefed on another leg.

Part 91, Subpart K, Section 91.1035 requires oral briefings and briefing cards. This section requires additional information be provided. Figures reflect the differences in requirements. Figures are adjusted to account for passengers that were previously briefed on another leg, and for the use of recorded briefings. It is estimated that 10% of the companies will develop their own printed briefing cards (average 2 aircraft types per operator)

Number of part 135 operators (1903) x 10% x 2 cards per co. 380

Estimate 2 hours technical time x 2

Total estimated technical time 760 hr

Cost of technical time (Flt Ops Mgr) x$46.29

Total estimated cost burden of technical time $35,180

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents			190
# of Responses per respondent			2
Time per Response			2 Hours
Total # of responses			380
Total burden (hours)			760 Hours

Oral briefings:

Est. number of briefings per year (adjusted for recorded/ previous briefings) 1,100,000

Estimate average time per briefing x 2 minutes

Total estimated hours 36,667

Cost of technical time (pilot) x 67.03

Total estimated technical burden for oral briefings $2,457,789

The total burden for 135.117 = 37,427 hours and $2,492,969 cost.

Oral Briefings

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents			1,100,000
# of Responses per respondent			1
Time per Response			2 minutes
Total # of responses			1,100,000
Total burden (hours)			36,667 Hours

§135.129, Exit row seating. Each new entrant operator with airplanes of 20-30 seats would be required to submit an exit row seating program for approval. This program requires information on passenger information cards available at each exit seat.

Estimated number of new applicants annually (required to submit program) 20

Estimate 2 hours of technical time x 2

Total technical time 40

Cost of technical time (Flt Ops Mgr) x$46.29

Total estimated burden of technical time $1,852

Estimate 2 hours of admin time per applicants 40

Cost of admin time x$24.88

Total estimated burden of admin time $995

Totals for new applicants 80 hours and $2,847 cost of burden

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		20
# of Responses per respondent		1
Time per Response		4 Hours
Total # of responses		20
Total burden (hours)		80 Hours

Revisions to programs of 20-30 seat airplanes

Estimated number of revisions 20 responses

Estimate 1 hour technical time x 1

Total estimate technical time 20

Cost of technical time (Flt Ops Mgr) $46.29

Total estimated burden of technical time $926

Estimated number of revisions 20 responses

Estimate 1 hour of admin time x 1

Total estimated admin time 20

Cost of admin time x$24.88

Total estimated burden of admin time $498

Totals for revisions to programs 40 hours and $1,424 cost of burden

Total burden for 135.129 = 120 hours and $4,271.

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		20
# of Responses per respondent		1
Time per Response		2 Hours
Total # of responses		20
Total burden (hours)		40 Hours

§135.179, Inoperable instruments and equipment. Requires an approved minimum equipment list to authorize operation with certain instruments and equipment inoperative.

It is estimated that there are 60 new applicants per year, each with one aircraft requiring a minimum equipment list. In addition, approximately 200 operators will add/change aircraft in their fleets requiring a new minimum equipment list. Approximately 500 operators per year will add equipment requiring a revision to an existing minimum equipment list.

Initial:

Approximate number of new minimum equipment lists annually 260

Estimate 20 hours of technical time per list x 20

Total estimated technical time 5,200

Cost of technical time (Flt Ops Mgr/ Maint Mgr average) x$46.50

Total estimated burden of technical time $241,800

Estimated 3 hours of admin time per list 780

Cost of admin time x$24.88

Total estimated burden of admin time $19,406

Total initial costs: 5,980 hours and $261,206 cost of burden

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		260
# of Responses per respondent		1
Time per Response		23 Hours
Total # of responses		260
Total burden (hours)		5,980 Hours

Revisions:

Approximate number of revisions annually 350

Estimate 1 hour of technical time per revision x 5

Total estimated technical time 1750

Cost of technical time x$46.50

Total estimated burden of technical time $81,375

Estimated .5 hours of admin time per revision 175 hrs

Cost of admin time x$24.88

Total estimated burden of admin time $4,354

Total revision costs: 1,925 hours and $85,729 cost of burden

Total burden for 135.179 = 7,905 hours and $346,935 cost.

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		350
# of Responses per respondent		1
Time per Response		5.5
Total # of responses		350
Total burden (hours)		1,925 Hours

§ 135.227, Icing limitations. Requires a deicing program or checking procedures which are contained in the operator’s manual. New entrants would be required to submit a program or manual procedures. Approximately 1/4th of these operators would submit a full program; the other 3/4th would submit manual procedures for pre-takeoff checks, or not operate in icing conditions.

Costs are computed for program development and program revisions only. If an operator elects manual procedures, those costs are contained in part 119 for initial certification. Revisions to the manual are covered in 135.21 above.

Estimated number of new entrant operators electing to have a deicing program 15

Approximately 20 hours technical time per program x20

Total estimated technical time 300

Cost of technical time (Flt Ops Mgr/ Maint Mgr average) x$46.50

Total estimated burden for technical time $13,950

Approximately 5 hours of admin time per new program 15 x 5 75 hrs

Cost of admin time x$24.88

Total estimated burden for admin time $1,866

New Program

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		15
# of Responses per respondent		1
Time per Response		25 Hours
Total # of responses		15
Total burden (hours)		375 Hours

Estimated number of program revisions per year 50

Approximately 2 hours of technical time per program revision x 2

Total estimated technical time 100

Cost of technical time x$46.50

Total estimated burden for technical time $4,650

Approximately 1 hour of admin time per program revision 50 hrs

Cost of admin time x$24.88

Total estimated burden for admin time $1,244

Total burden for deicing program option (new and program revisions)

525 hours and $21,710

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		50
# of Responses per respondent		1
Time per Response		3 Hours
Total # of responses		50
Total burden (hours)		150 Hours

§135.273(c), Duty period limitations and rest time requirements. This paragraph establishes an alternate provision for flight attendant flight and duty limits. If the operator does not use the flight crewmember limits, it can establish written procedures for flight attendants that are approved by the Administrator and referenced in operations specifications.

It is estimated that all companies use the flight and duty time requirements specified above in the recordkeeping section (same as the flight crewmembers (pilots)). No cost is associated with this burden.

§ 135.325, Training program and revision. Each applicant for a certificate, other than a single pilot operator, must submit an outline of the proposed curriculum for a training program that meets the minimum standards in the regulation. This outline varies depending on the size and complexity of the operations.

A single pilot operator has no training program requirements. A small operator with 2 or 3 pilots and/or 2 or 3 aircraft, or aircraft of the same type, would require approximately 80 to 100 hours to prepare such a curriculum outline. A large operator with, for example 30 to 40 pilots and a variety of aircraft might require 600 to 800 hours. The contents of the curriculum are determined in accordance with section 135.327 and will vary dependent on numbers and types of aircraft and kinds of operations authorized. Paragraph (b) (2) of 135.327 requires a list of all training aids that the operator will use.

The operator applies for initial approval; and after evaluation of the effectiveness of the program, the operator would be issued final approval, with or without revision to the outline as required by the FAA. Burden for the original preparation (for initial approval) of a training program is part of the initial certification process covered in Part 119 (119.35) under OMB clearance number #2120-0593, Certification: Air Carriers and Commercial Operators—FAR Part 119.

The operator may also make revision to the curriculum based on changes in its operation, such as addition of another type of aircraft or a change in procedures or authorizations.

There are 1903 part 135 operators. 104 of these are single pilot operations that do not require a training program. Therefore, 1,799 operators require a training program; complexity of the program will vary based on size of the operator. It is expected that one half of new applicants (approximately 30) will require a training program approval.

Assuming each operator holding a training program would submit one revision annually, estimated revisions would total 1,799 taking 15 hours of technical time and 5 hours admin time per revision:

Estimated number of training program revisions: 1799

Estimate 15 hours of technical time x 15

Total estimated technical time 26,985

Cost of technical time (Flt. Ops Mgr) x$46.29

Total estimated burden of technical time $1,249,136

Total estimated admin time of 5 hours per revision x 1799 revisions 8,995

Cost of admin time x$24.88

Total estimated burden of admin time $223,795

Total training program revision requirements 35,980 hours and $1,472,931 cost of burden

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		1,799
# of Responses per respondent		1
Time per Response		20 Hours
Total # of responses		1,799
Total burden (hours)		35,980 Hours

Development of an SIC Professional Development Program and submission to the FAA for approval (revising an existing 119 certificate) will take an operator approximately 40 hours to develop and submit for approval. We estimate that approximately 20 operators will submit a newly developed training program for approval annually.

35 hours (technical) x 20 responses/operators = 700 hours

700 hours x $46.29 per hour = $32,403 cost

5 hours (admin time) x 20 operators = 100 hours

100 hours x $24.88 = $2,488 cost

700 hours + 100 hours = 800 total hours

$32,403 + $2,488 = $34,891 total cost

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		20
# of Responses per respondent		1
Time per Response		40 Hours
Total # of responses		20
Total burden (hours)		800 Hours

Adjusted total burden annually for 135.325

35,980 current annual revision hours + 800 hours (new SIC program) = 36,780 total hours
$1,472,931 + $34,891 (new SIC program) = $1,507,822 total cost

We estimate that the remaining 50 operators (of the total of 70) will request a “revised” SIC training program for the authorization of logging SIC time. This additional burden will be:

15 hours (technical time) x 50 operators = 750 hours

750 hours x $46.29 = $34,718 cost

5 hours (admin time) x 50 = 250 hours

250 hours x $24.88 = $6,220 cost

750 hours + 250 hours = 1000 total revision hours

$34,718 + $6,220 = $40,938 total revision cost

SIC Revision

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		50
# of Responses per respondent		1
Time per Response		20 Hours
Total # of responses		50
Total burden (hours)		1000 Hours

Total Burden for 135.325 revisions

35,980 (current annual hours) + 1,800 hours (SIC training program) = 37,780 hours

$1,472,931 + $34,891 + $40,938 = $1,548,760 total cost

§ 135.415, Mechanical reliability reports—This requires the operator to report occurrences or detection of each failure, malfunction, or defect in an aircraft.

Estimated number of aircraft 8,219

Average number of reports per aircraft annually x 1

Total number of reports 8,219 responses

Estimate 1 technical hour per report x 1

Total technical hours 8,219

Cost of technical time (Maint Mgr) x$46.71

Total estimated burden of technical time $383,909

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		8,219
# of Responses per respondent		1
Time per Response		1 Hour
Total # of responses		8,219
Total burden (hours)		8,219 Hours

§ 135.417, Mechanical interruption summary report. An operator shall mail or deliver a monthly summary report of the following occurrences that happen to multiengine aircraft: each interruption to a flight, unscheduled change of aircraft en route, or unscheduled stop or diversion from a route, caused by known or suspected mechanical difficulties or malfunctions that are not required to be reported under 135.415.

Estimated number of operators with multiengine aircraft 1,500

Estimate 12 reports annually per operator x12

Total estimated number of reports 18,000

Estimate 1 hour technical time 18,000

Cost of technical time (Maint. Mgr) x$46.71

Total estimated burden of technical time $840,780

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1,500
# of Responses per respondent	12
Time per Response	1 Hour
Total # of responses	18,000
Total burden (hours)	18,000 Hours

§ 135.419, Approved aircraft inspection program. Certificate holders are required to have an approved aircraft inspection program. The program is part of their operations specifications. This section says that the Administrator may amend the certificate holder’s operations specifications and it says that the certificate holder may apply for any amendment to an approved program. The application for amendment must include the proposed changes to the aircraft inspection program. After the inspection program or amendments are approved, they become a part of the manual required by section 135.21.

The burden for the initial preparation of the inspection program and the subsequent amendments are covered by OMB 2120-0028, Operations Specifications.

Estimated number of amendments to program 50

Estimate 1 hour technical time x 1

Total estimated technical time 50

Cost of technical time (Maint. Mgr) x$46.71

Total estimated burden of technical time $2,336

Estimate number of amendments to program 50

Estimate .5 hours admin time x .5

Total estimated admin time 25

Cost of admin time x$24.88

Total estimated burden of admin time $622

Totals: Time 75 hours and $2,958

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	50
# of Responses per respondent	1
Time per Response	1.5 Hours
Total # of responses	50
Total burden (hours)	75 Hours

§135.421, Additional maintenance requirements. Certificate holders operating aircraft of nine seats or less must comply with either a manufacturer’s recommended maintenance program or one approved by the FAA for aircraft engines, propellers, rotors, or items of emergency equipment. Operators covered by this section tend to elect the manufacturer’s maintenance program. Therefore, no reporting burden is anticipated. If an operator of single engine aircraft desires to use this aircraft in passenger carrying instrument operations, it must incorporate into its maintenance program either the manufacturer’s recommended engine trend monitoring program or an FAA approved engine trend monitoring program. In addition, written maintenance instructions are required to maintain the additional equipment required for this authorization. Most single engine programs are limited to turbine powered aircraft. A program and instructions would be the same for all same type aircraft in an operator’s fleet.

Estimated number of new single engine IFR trend monitoring programs 20

Estimate 20 hours technical time for program and instructions x20

Total estimated technical time 400

Cost of technical time (Maint. Mgr) x$46.71

Total estimated burden of technical time $18,684

Estimate 5 hours of admin time 100 hrs

Cost of admin time x$24.88

Total estimated burden of admin time $2,488

Total: 500 hours and $21,172

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		20
# of Responses per respondent		1
Time per Response		25
Total # of responses		20
Total burden (hours)		500 Hours

§ 135.427, Manual requirements. Certificate holders operating aircraft of 10 or more seats must provide in their manual, adequate maintenance and inspection programs for the airworthiness of all these aircraft and inform personnel of their responsibilities.

Maintenance, preventative maintenance, alteration procedures, inspection methods, and procedures to release aircraft for service must be included. The manual will also contain a maintenance organization and list of persons with whom it has arranged for the performance for any required inspection. The burden for this initial requirement is included under section 119.35 and burden for revisions are addressed under 135.21.

§135.429, Required inspection personnel. Certificate holders are required to determine that each person with whom it arranges to perform its required inspections maintain a current listing of persons who have been trained, qualified, and authorized to conduct required inspections. These persons must be identified by name, occupational title, and the inspections they are authorized to perform.

§135.431, Continuing analysis and surveillance. Certificate holders are required to establish and maintain a system for the continuing analysis and surveillance of the performance and effectiveness of its inspection program and the program covering other maintenance, preventive maintenance, and alterations and for the correction of any deficiency of those programs, regardless of whether those programs are carried out by the certificate holder or by another person.

Estimated number of operators maintaining a system 100

Estimate 70 hours of technical time x 70

Total estimated technical time 7,000

Cost of technical time (Maint. Mgr) x$46.71

Total estimated burden of technical time $326,970

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		100
# of Responses per respondent		1
Time per Response		70 Hours
Total # of responses		100
Total burden (hours)		7,000 Hours

§135.439, Maintenance record requirement. Certificate holders are required to keep certain maintenance records using the system specified in the manual by section 135.427.

The records must contain information necessary for the issuance of an airworthiness release. The records must contain information regarding total time in service of the airframe, engine, and propeller; the current status of life-limited parts of each airframe, engine, propeller, rotor and appliance; the items installed on the aircraft which are required to be overhauled on a specified time basis. The records must contain the current inspection status of the aircraft, the current status of applicable airworthiness directives, and a list of current major alterations to each airframe, engine, propeller, rotor, and appliance. Each certificate holder shall retain the records for a certain specified time and make them available for inspection by the Administrator or any representative of the National Transportation Safety Board (NTSB).

Estimated number of aircraft involved in recordkeeping system 200

Estimate 60 hours of technical time x60

Total estimated technical time 12,000

Cost of technical time (Maint. Mgr) x$46.71

Total estimated burden of technical time $560,520

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		200
# of Responses per respondent		1
Time per Response		60 Hours
Total # of responses		200
Total burden (hours)		12,000

§135.443, Airworthiness release or aircraft log entry. Certificate holders are required to prepare or cause the person with whom the certificate holder arranges for the performance of the maintenance, preventive maintenance, or alterations to prepare an airworthiness release or an appropriate entry in the aircraft log. The airworthiness release or log entry must be prepared in accordance with the procedure set forth in the certificate holder’s manual and be signed by an authorized certificated mechanic or repairman.

Estimated number of aircraft requiring airworthiness release or

aircraft log entry daily 200

Estimate 1 daily entry per aircraft x365

Total estimated number of entries annually 73,000

Estimate 1 hour technical time 73,000

Cost of technical time (Maint. Mgr) x46.71

Total estimated burden of technical time $3,409,830

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		200
# of Responses per respondent		365
Time per Response		1 Hour
Total # of responses		73,000
Total burden (hours)		73,000 Hours

SUMMARY

FAR Section	Technical	Admin	Total Hours	Technical	Admin	Total Cost	Responses	Total	Total Cost
		REPORTING
135.25	0	1	1	-	$15	$15	3		$13
135.129	60	60	120	$2,778	$1,493	$4,271	40		$4,651
135.179	6950	955	7905	$323,175	$23,760	$346,935	610		$192,740
135.415	8219	0	8219	$383,909	0	$383,909	8,219		$665,315
135.417	18000	0	18000	$840,780	0	$840,780	18,000		$993,420
135.419	50	25	75	$2,336	$ 622	$2,958	50		$3,286
TOTAL			34,320			$1,578,868	26,922		$1,859,425
		RECORDKEEPING
135.2	-	-	-	-	-		-		-
135.3	-	-	-	-	-		-		-
135.19	50	0	50	$3,352	-	$3,352	100		$2,694
135.21	-	-	-	-	-		-		-
135.21(b), (f), (g)	18,780	4,695	23,475	$873,270	$116,812	$990,082	9,390		$1,642,829
135.63	564,004	530,763	1,094,767	$37,766,099	$13,205,377	$50,971,476	10,930,532		$41,436,961
135.64	335	40	375	$13,001	$ 995	$13,996	750		$18,887
135.65	35,681	0	35,681	$2,391,714	0	$2,391,714	142,725		$2,023,142
135.79	7.50	0	7.50	$347	0	$347	15		$424
135.83	1520	0	1520	$70,360	0	$70,360	760		$45,313
135.227	400	125	525	$18,600	$3,110	$21,710	65		$24,703
135.273 (c)	-	-	-	-	-	-	-		0
135.325	28,435	9,345	37,780	$1,316,257	$232,503	$1,548,760	1,869		$1,898,270
135.421	400	100	500	$18,684	$2,488	$21,172	20		$24,178
135.427	-	-	-	-	-	-	-		0
135.429	-	-	-	-	-	-	-		0
135.431	7000	0	7000	$326,970	0	$326,970	100		$386,330
135.439	12000	0	12000	$560,520	0	$560,520	200		$662,280
135.443	73000	0	73000	$3,409,830	0	$3,409,830	73,000		$4,028,870
TOTAL			1,286,681			$60,330,289	11,159,526		$52,194,881
		THIRD-PARTY DISCLOSURE
135.117	37,427		37,427	$ 2,492,969	0	$2,492,969	1,100,380		$2,020,564
TOTAL	810,569	545,934	1,358,428	$50,814,951	$13,587,175	$64,401,126	12,286,828		$56,074,870

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information.

The burden is shown in question 12. There are no additional costs.

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 no additional costs associated with this collection as the data gathered above is associated with normal job functions that an Aviation Safety Inspector would perform. Therefore, the costs would already be included in the salary that they receive.

15. Explain the reasons for any program changes or adjustments.

The wage tables used to calculate the burden were updated to better reflect the wages paid today.

The burden for 135.153 was removed as that regulation is no longer in effect.

The number of current Part 135 operators was updated to reflect the current number of operators in July 2021. The number of pilots and flight attendants was also updated to reflect July 2021 numbers.

The costs to the Federal Government section was amended. All of the responsibility for oversight associated with the regulations below is part of an Aviation Safety Inspector’s normal job functions. No additional costs are accrued due to this collection of information.

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.

There is no publication plan.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.

The FAA is not seeking this.

18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions in Item 19 OMB Form 83-I.

.

1 https://www.payscale.com/research/US/Job=Sr._Operations_Manager/Salary

2 https://www.bls.gov/news.release/ecec.nr0.htm

3 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.

4 https://www.payscale.com/research/US/Job=Flight_Operations_Manager/Salary

5 https://www.bls.gov/news.release/ecec.nr0.htm

6 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005

7 https://www.payscale.com/research/US/Job=Administrative_Assistant/Hourly_Rate

8 https://www.bls.gov/news.release/ecec.nr0.htm

9 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.

10 https://www.payscale.com/research/US/Job=Aircraft_Maintenance_Manager/Salary

11 https://www.bls.gov/news.release/ecec.nr0.htm

12 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.

13 https://issuu.com/propilot/docs/june_2020

14 https://www.bls.gov/news.release/ecec.nr0.htm

15 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.

16 https://www.bls.gov/news.release/ecec.nr0.htm

17 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.