The regulations establishing the rules of practice before the Board under the SCA provide that "[t]he Board has jurisdiction to hear and decide in its discretion appeals concerning questions of law and fact from final decisions of the Administrator of the Wage and Hour Division or authorized representative . . . arising under the Service Contract Act . . . [including] (1) [w]age determinations under the Service Contract Act . . . ." 29 C.F.R. § 8.1(b) (1996). The Board has plenary authority, therefore, to review all questions raised by final decisions of the Administrator, constrained only by the requirement in 29 C.F.R. § 8.9(b) that findings of fact may not be reversed when they are supported by a preponderance of the evidence. Given the broad authority granted to the Board under 29 C.F.R. § 8.1(b), the Board has the power to determine its own jurisdiction as well as that of the Administrator. Marshall v. Able Contractors, Inc., 573 F.2d 1055 (9th Cir. 1978) (agency should make initial determination of its own jurisdiction). We also agree with Emery that if the pilots and first officers providing services under this contract are exempt, the Department of Labor has no authority to issue a wage determination covering them. Hi-Craft Clothing Co. v. NLRB, 660 F.2d 910, 918 (3d Cir. 1981) (agency has no authority to act when lack of coverage is clear). In addition, no purpose would be served and it would be administratively inefficient not to decide this issue in the context of this proceeding, when both the contracting agency and the contractor assert that the exemption applies to employees providing services under this contract.

   We agree with the Administrator, however, that the Wage and Hour Division should make the initial determination, after gathering appropriate information, on whether the professional exemption applies to these particular employees. The Administrator should have an opportunity to develop a full record for Board review on this issue and to address the questions about the applicability of the exemption raised in the Administrator's brief, e.g. whether all pilots and first officers are paid on a "salary basis," whether the duties of all these employees can be characterized as "work requiring knowledge of an advanced type in a field of science or learning customarily acquired by a prolonged course of specialized instruction and study," 29 C.F.R. § 541.3(a)(1), and whether there is any basis for distinguishing these employees from the employee whom the Fifth Circuit found exempt in Paul v. Petroleum Equipment Tools Co., 708 F.2d 168, 173-74 (5th Cir. 1983). If the Administrator decides that the exemption does apply, the Board would not be required to expend valuable resources reviewing the methodology of the wage determination itself.

   Accordingly, this matter is remanded to the Wage and Hour Division for further action consistent with this decision.

   SO ORDERED.

       DAVID A. O'BRIEN
       Chair

       KARL J. SANDSTROM
       Member

       JOYCE D. MILLER
       Alternate Member