Updated supportingstatemen_A[1].wpd

Updated supportingstatemen_A[1].wpd

2007 Census of Law Enforcement Aviation Units

OMB: 1121-0318

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SUPPORTING STATEMENT


A. Justification


1. Necessity of Information Collection


The 2007 Census of Law Enforcement Aviation Units will be the first systematic, national-level data collection providing information about law enforcement aviation assets and functions. In general, these units provide valuable airborne support for traditional ground-based police operations. An additional role following the September 11, 2001, terrorist attacks is the provision of essential homeland security functions, such as providing critical facility checks of buildings, ports and harbors, public utilities, inland waterways, oil refineries, bridges and spans, water storage/reservoirs, National and/or State monuments, water treatment plants, irrigation facilities, airports, and natural resources. Aviation units are able to accomplish these critical facility checks with far greater efficiency than ground-based personnel, and can routinely incorporate such checks into their regular patrol and support operations. However, little is presently known about the location, available assets and range, personnel, operations, expenditures, and safety records of these units on a National level. It is important to know the location and nature of available assets that could be mobilized in the event of large-scale regional or National emergencies. This information is also critical to law enforcement policy development, planning, and budgeting at all levels of government.


Based on data from the 2003 BJS Law enforcement Management and Administrative Statistics (LEMAS) survey, it is estimated that about 250 law enforcement aviation units are in operation among State and local agencies in the United States. These units operate an estimated 1,000 aircraft, including about 600 helicopters and 450 fixed-wing aircraft. The 2007 Census of Law Enforcement Aviation Units will be a census of all agencies, sampled in the 2004 LEMAS survey, which reported having either a fixed-wing aircraft or helicopter. It will be the most comprehensive study conducted in this area to date. The data collection will include detailed items on the functions, personnel, equipment, record keeping, expenditures, and safety records of these units.


Beyond the initial list generated from LEMAS, lists from other available sources, including professional associations such as the Airborne Law Enforcement Association (ALEA) and the International Association of Chiefs of Police (IACP), as well as the National Directory of Law Enforcement Administrators being used to verify addresses and contact information for the Chief or Sheriff overseeing the law enforcement agency. Previous law enforcement data collections have revealed that the head of the agency typically must give approval before any information can be provided by the appropriate officers.


The statutory authority to collect these data is derived from Title 42 U.S.C. Section 3732 (Attachment 1), in which the Bureau of Justice Statistics (BJS) is directed to collect and analyze statistical information regarding the operation of the criminal justice system at the Federal, state, and local levels.



2. Uses of Information


One of the principal users of the aviation unit data will be state and local law enforcement officers. The data collected will assist police agencies in developing the most cost effective strategies for improving crime fighting and Homeland Security functions. A former Captain of the Los Angeles County Sheriff’s Department states that,


At a time when every budget dollar comes under close scrutiny, it is imperative that law enforcement executives and local government leaders are cognizant of the most effective use of tax dollars spent on public safety and Homeland Security. The value of airborne law enforcement and it’s impact on crime deterrence is often times lost on the uneducated who fail to realize the benefits of this force multiplier and look for easy ways to reduce budgetary expenditures without impacting programs of greater notoriety and perceptional value. A statistical summary of the use of law enforcement aviation will assist greatly in developing a comprehensive cost analysis wherein the budgetary value of airborne law enforcement can be accurately weighed against the cost of other projects that appear to be cost effective, but in comparison have very little impact on the overall crime rate or public safety.


The Chief Deputy of the Jefferson County, Texas Sheriff’s Department, likewise points out the utility of the data for assisting departments in determining cost effective “best practices,”


My department’s area of responsibility lies on the Texas Gulf Coast and is home to a large petrochemical industry, the largest military equipment transport port in the U. S., a strategic oil preserve, as well as being vulnerable to hurricane disaster. My area of responsibility includes managing a department budget of over $35 million, local, state, and federal grant funding, and among other areas also am a pilot and manage our three county air support unit. The information collected from this survey will greatly help me as well as other law enforcement aviation and finance managers nationwide obtain the most effective use of tax dollars spent on public safety and Homeland Security missions. Utilizing the information gained from this survey and applying best used practices is the most effective way to evaluate our use of airborne resources. It will further compile a pool of available resources never completely known before for response to national disaster and Homeland Security threats.

As an increasing number of law enforcement agencies nationwide begin to utilize police aviation units, the data will also be used to assist in the development of uniform safety and training standards for airborne law enforcement officers. A former commander from the Texas Department of Public Safety noted that, “Information is always an invaluable tool in the development of Safety Standards and Operational Guidelines.” He goes on to point out that having nationwide data on the safety and training regulations for airborne law enforcement will be a “significant catalyst for increased flight safety and operational efficiency.” Similarly, Captain Don Roby of the Baltimore County Police Department notes that the data will be useful because,


Many of these units are operating military excess aircraft as "non-certificated" public aircraft, and we need to track these aircraft to ensure that they being operated safely and in compliance with existing federal law. We also need to target these units for additional training to encourage a culture of safety and to enhance their operation at all levels.


The data will also be used to gain a better understanding of the capacity of state and local law enforcement aviation units to provide valuable Homeland Security and disaster relief functions. The data will also provide State, Local, and Federal agencies with basic information regarding the resources that are available if assistance is required in a particular region of the country. The Chair of the Aviation Committee of the International Association of Chiefs of Police states that


For many years, one of the most fundamental deficiencies in police aviation has been a comprehensive list of agencies operating aircraft, the number and type of aircraft they fly, number and level of experience of their personnel, etc. Obtaining this data will allow us to do the following:


-Gain an understanding of the level of investment in aviation resources by state and local governments.

-Gain an understanding of geographic coverage nationwide. This might lead to identifying areas in

the country where efforts should be made to develop aviation programs.

-Possibly facilitate the development of a national

response plan for disasters.

-Identify training and equipment needs.

-Allow for direct contact of agency heads to facilitate information exchange.



Captain Roby, also explains the utility of the data collection for nationwide improvements to state and local law enforcement’s Homeland Security function


Homeland Security has become a vital mission for law enforcement. A comprehensive list of resources (Aircraft type, equipment, availability, etc...) does not exist. In order to properly plan for a response to Homeland Security threats, we need to have a tool to ascertain what is available to respond to National Security events.


The above information will serve not only the law enforcement community, but all levels of government and the citizens of this country. Aviation is a vital tool in the suppression of crime, the response to emerging events and a deterrent to terrorism. As an industry (law enforcement), we need access to this information to properly plan and respond to our mission, which is to protect and serve the public.


Federal Agencies such as FEMA and the Department of Homeland Security have also expressed an interest in this data. In order to best plan responses to Homeland Security threats or natural disasters, it is useful to these agencies to have concrete knowledge of the resources and personnel that can be mobilized for assistance. Furthermore, if state and local aviation units are performing functions such as critical facility checks, having this knowledge would allow Federal resources to be put to other uses.



3. Efforts to Minimize Burden


BJS has attempted to minimize the complexity of questions and ensured that terminology conforms to current standard practices in law enforcement aviation. The majority of the items on the questionnaire require dichotomous ‘yes/no’ type responses. Where detail or continuous numerical items are requested, BJS has attempted to conform with required record keeping by other Federal agencies. For example, aviation units are required by the Federal Aviation Administration (FAA) to maintain records on the flight hours accumulated by existing aircraft. BJS has phrased questions pertaining to the aircraft operated by aviation units in such a way that no additional burden is created, other than entering the numbers already on record per the FAA record keeping requirement.


It is estimated that data collection will take one hour per respondent. The data collection agent will provide for the respondent to submit data through the mail or by fax. Personal telephone interviews will be conducted for nonrespondents.


4. Efforts to Identify Duplication


There will be no duplication of effort based on the nature and scope of this census. The information sought is not attainable from any other data source. BJS has consulted with National Law Enforcement Associations and the Department of Homeland Security to ensure that this information has not been previously collected.


5. Minimizing Burden on Small Businesses


Not applicable. No information will be gathered from small businesses.


6. Consequences of Not Conducting Collection


This data collection will be the only source of national data on law enforcement aviation units. There are no other sources for these data.


7. Special circumstances that would increase respondent burden


There are no special circumstances that would require a respondent to report more than once, report in less than 30 days, retain records over three years, or in any other foreseeable way increase the respondents burden to provide the requested information.



8. Public Comments and Consultations


BJS has consulted with the Airborne Law Enforcement Association (ALEA), the International Association of Chiefs of Police (IACP) Aviation Committee, the National Institute of Justice (NIJ) Office of Science and Technology, the Federal Emergency Management Agency (FEMA), as well as various members of the criminal justice and law enforcement community, regarding the content, data availability, and the clarity of instructions. Consultants included the following points-of-contact as well as others within their organizations and within their memberships, if applicable (this list is not intended to be exhaustive):


  1. Stephen J. Ingley

Executive Director

Airborne Law Enforcement Association

411 Aviation Way Ste 200

Frederick, MD 21701


  1. Michael K. O’Shea

Program Manager

National Institute of Justice Office of Science and Technology

810 Seventh St., NW

Washington, DC 20531


(3) David Tollett

International Association of Chiefs of Police

Aviation Committee

515 North Washington Street

Alexandria, VA 22314


(4) Jim DiGiovanna

ALEA Education Program Manager

c/o Airborne Law Enforcement Association

411 Aviation Way Ste 200

Frederick, MD 21701


(5) Chief Donald L. Shinnamon, Sr.

Director, City of Holly Hill Public Safety

1065 Ridgewood Ave.

Holly Hill, FL 32117


(6) Robert Farmer

Director, Program Analysis & Evaluation Division

DHS-FEMA








9. Provision of Payments or Gifts to Respondents


Not applicable. The data collection agent will not provide any payment or gift of any type to respondents. Respondents participate in the survey on a voluntary basis.


10. Assurance of Confidentiality


Respondents will be informed that survey participation is voluntary. The data collected are in the public domain and not subject to confidentiality guarantees. All data, except names of individual respondents, will be made available for public use.


11. Justification for Sensitive Questions


There are no questions of a sensitive nature included in the data collection.


12. Estimate of Respondent Burden


The average time required for each agency is one hour. This estimate is based on experience garnered from previous law enforcement surveys, and pre-testing conducted with three aviation units. The total respondent burden is estimated at 250 hours. Respondents will be asked to respond once.


The survey form, in most cases, will be filled out by one person per respondent, equivalent to the GS-15 / 01 level ($110,363 per year). The cost to the respondent would be about $53.06 per form. For all respondents combined, the approximate cost would be $13,265.


13. Estimate of Respondents’ Cost Burden


This information collection will require only information that is already generated and maintained by the respondents. There is no additional cost to respondents other than the cost of filling out the survey form.


14. Cost to Federal Government

The total cost to the Federal government for this survey is estimated at $283,043, all to be borne by the Bureau of Justice Statistics. Office costs are based on 6 months full-time work of a GS-11 / 01 Statistician salary ($58,206 per year) and benefits (33 percent of salary) and indirect costs (20% of salary) of the Bureau of Justice Statistics.


Office Costs (BJS)

Salaries $29,103

Benefits (33%) 9,619

Travel 2,000

Equipment and supplies 1,500

Consultants and contracts 0

Other costs 0

Indirect costs (20%) 5,821

Subtotal 48,043

Collection costs (U.S. Census Bureau) 235,000

Total cost to government $283,043


15. Reasons for Change in Burden


The change in burden estimate of 250 hours is entirely due to the fact that this is a new collection.


16. Publication Plans and Schedule


Information collected from law enforcement aviation units will be reported in a Bureau of Justice Statistics bulletin. The data will then be made available to the public through the National Archive of Criminal Justice Data (NACJD), operated by the Inter-university Consortium for Political and Social Research (ICPSR).


The projected schedule for data collection, publication and data release is as follows:


Preparation and pretesting Months 1 - 3

Data collection Months 3 - 8

Data processing/analysis Months 8 - 12

Publication release Month 13

Data release to public Month 13



17. Display of Expiration Date


The expiration date will be shown on the survey form.



18. Exceptions to the Certification Statement


There are no exceptions identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.


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