2120-Air Ambulance and Commercial Helicopter Operations NPRM
2120-Air Ambulance and Commercial Helicopter Operations NPRM.doc
Air Ambulance and Commercial Helicopter Operations; Safety Initiatives and Miscellaneous Amendments
OMB: 2120-0756
Air Ambulance and Commercial Helicopter Operations; Safety Initiatives and Miscellaneous Amendments
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statue and regulation mandating or authorizing the collection of information. (Annotate the CFR parts/sections affected).
The FAA’s authority to issue rules on aviation safety is found in Title 49 of the United States Code. This rulemaking is promulgated under the authority described in 49 U.S.C. 44701(a)(4), which requires the Administrator to promulgate regulations in the interest of safety for the maximum hours or periods of service of airmen and other employees of air carriers, and 49 U.S.C. 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.
The provisions of the proposed rule that would require information collection are --
Require certificate holders performing helicopter air ambulance operators to implement pre-flight risk-analysis programs (§135.615)
Require air ambulance operators with 10 or more helicopters to have an operations control center to communicate with pilots, advise pilots of weather conditions, and provide flight-following services (§135.617)
Require additional VFR flight planning (§135.613)
Require that medical personnel on board helicopter air ambulance flights receive a supplemental safety briefing (§135.619)
Require operators of all aircraft operated under part 135 to prepare a load manifest and permit operators to transmit copies to their principal bases of operations in lieu of preparing duplicate copies (§135.63)
Require air ambulance operators that are required to have an operations control center to perform drug and alcohol testing on their operations control specialists (§§120.105 and 120.215)
While not specifically proposed in the regulatory amendments, the FAA is also seeking comments on whether to require the installation of a light-weight aircraft recording system (LARS) in order to provide critical information to investigators in the event of an accident. In addition, the agency is asking whether certificate holders would also use those systems to improve daily operations.
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.
Require certificate holders performing helicopter air ambulance operators to implement pre-flight risk-analysis programs (§135.615)
The FAA would require certificate holders to establish pre-flight risk-management procedures. The FAA would require that certificate holders outline these procedures in their operations manuals. The purpose is to enhance safety.
Require air ambulance operators with 10 or more helicopters to have an operations control center to communicate with pilots, advise pilots of weather conditions, and provide flight-following services (§135.617)
Under this requirement, operations control specialists would work with pilots to compete a pre-flight risk analysis worksheet, which would be signed by the operations control specialist and the pilot in command. The format and manner of completing the worksheet would be established in the certificate holder’s operations manuals.
In addition, the FAA would require that operations control specialists be trained under an FAA-approved training program. Records of that training would be maintained for 90 days.
Occupational control specialists would also be subject to the certificate holder’s drug and alcohol testing program, records of which would be maintained in accordance with the certificate holder’s FAA-approved program.
The FAA would use this information to ensure that individuals involved in safety-related functions receive appropriate training and testing.
The FAA is proposing as part of a pilot’s pre-flight risk analysis, that a pilot evaluate and document terrain and obstacles. The FAA would require that certificate holders outline these procedures in their operations manuals. The purpose of requiring this documentation is to enhance safety.
A proposal under consideration is to require the installation of a light-weight aircraft recording system (LARS) to provide event data to aid investigators after an accident. Currently, because most helicopter air ambulances are not equipped with flight data recording devices, investigators must piece together information pertaining to an accident from a variety of sources. LARS could provide precise technical data regarding the flight, such as heading, altitude, and attitude that may otherwise be unavailable. The FAA asks for comments on whether LARS will provide data that is valuable in an accident investigation.
The FAA also invites comments on whether operators that are required to install LARS for accident investigation would also use those systems to improve daily operations, including whether operators would be more likely to participate in an FAA-approved Flight Operations Quality Assurance (FOQA) program if required to equip helicopters with LARS.
Require that medical personnel on board helicopter air ambulance flights receive safety training in lieu of currently required pre-flight briefings (§135.619)
The FAA is proposing to provide certificate holders with the option of providing FAA-approved safety training every 2 years to medical personnel on board helicopter air ambulance flights in lieu of currently required pre-flight briefings. If a certificate holder chooses to provide this training, it would be required to document the training provided to each medical personnel, and maintain a record of that training for 24 calendar months plus 60 days following the individual’s completion of training. The FAA would use this information to monitor this safety training.
Amend existing collection 2120-0039 by expanding the applicability from multiengine aircraft to all aircraft. The new rule would require operators of all aircraft operated under part 135 to prepare a load manifest and permit electronic transmission of copies (§135.63)
Currently, §135.63 requires the preparation of a load manifest detailing information such as aircraft weight, center of gravity, crewmember identification, and other aircraft information before a flight involving a multiengine aircraft. The load manifest must be prepared in duplicate, and one copy must be carried on board the aircraft to its destination. Section 135.63 currently does not prescribe any specific action for the copy of the load manifest not carried on board the aircraft.
Recently, single-engine passenger carrying aircraft have increased in size and capacity and, therefore their use in on-demand operations has increased. The FAA finds that all operators carrying passengers for hire must generate a manifest, regardless of the type of aircraft operated. In the event of an emergency, the operator must be able to account for aircraft occupants and, in the case of a fatal or serious accident, contact next of kin. Additionally, the FAA believes that, in the event of an accident, load manifest information pertaining to the aircraft’s weight and balance would be useful in determining whether the aircraft was loaded within the aircraft’s center-of-gravity limits and maximum allowable takeoff weight. Therefore a copy of the load manifest should be available if the copy on the aircraft is destroyed.
In addition, the FAA is proposing to eliminate the requirement that the load manifest be prepared in duplicate for certificate holders who elect to electronically transmit the information contained in the load manifest to their operations base before take off. A certificate holder electing this option would be permitted to transmit the information by facsimile, e-mail, online form, or other electronic means and the information must be received by the certificate holder’s base of operations or other approved location before take off. This would ensure that the load manifest information is available in the event that the copy carried on board the aircraft is destroyed. If a certificate holder does not elect to transmit load manifest information electronically, it would be required to prepare the load manifest in duplicate. Additionally, the proposed rule would require the pilot in command to arrange for a copy of the load manifest to be sent to the certificate holder, retained in a suitable place at the takeoff location, or retained in another location approved by the FAA.
The FAA notes that the proposed regulation would not alter the requirement that a copy of the load manifest must be carried on board the aircraft to its final destination, although that copy may be in an electronic format. In addition, the proposal would not change the required content of the load manifest.
Require air ambulance operators that are required to have an operations control center to perform drug and alcohol testing on their operations control specialists (§§120.105 and 120.215)
Because the functions of operations control specialists are safety-sensitive, the FAA would require those individuals to be subject to drug and alcohol testing.
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, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden. [Effective 03/22/01, your response must SPECIFICALLY reference the Government Paperwork Elimination Act (GPEA), which addresses electronic filing and recordkeeping, and what you are doing to adhere to it. You must explain how you will provide a fully electronic reporting option by October 2003, or an explanation of why this is not practicable.]
Require certificate holders performing helicopter air ambulance operators to implement pre-flight risk-analysis programs (§135.615)
The FAA would require that certificate holders outline these procedures in their operations manuals. In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic recordkeeping.
Require air ambulance operators with 10 or more helicopters to have an operations control center to communicate with pilots, advise pilots of weather conditions, and provide flight-following services (§135.617)
The FAA would require that certificate holders outline these procedures in their operations manuals. In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic recordkeeping.
In addition, the FAA would require that operations control specialists be trained and tested under an FAA-approved training program and the records of that training and testing be maintained for 90 days. In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic recordkeeping.
Occupational control specialists would also be subject to the certificate holder’s drug and alcohol testing program. In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic recordkeeping.
The FAA would require that certificate holders outline these procedures in their operations manuals. In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic submission.
Should the FAA adopt a requirement to require the installation of a light-weight aircraft recording system (LARS) in order to provide critical information to investigators in the event of an accident and require certificate holders also to use those systems to improve daily operations, the amendments would support the Government Paperwork Elimination Act (GPEA). In accordance with the Government Paperwork Elimination Act (GPEA), data from these devices would be collected, downloaded, and stored electronically.
Require that medical personnel on board helicopter air ambulance flights receive safety training in lieu of currently required pre-flight briefings (§135.619)
In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic recordkeeping.
Require operators of all aircraft operated under part 135 to prepare a load manifest and permit operators to transmit copies to their principal bases of operations in lieu of preparing duplicate copies (§135.63)
In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic recordkeeping.
Require air ambulance operators that are required to have an operations control center to perform drug and alcohol testing on their operations control specialists (§§120.105 and 120.215)
In accordance with the Government Paperwork Elimination Act (GPEA), the FAA would permit electronic recordkeeping.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in Item 2 above.
We have reviewed other FAA public-use reports and find no duplication. Also, the FAA knows of no other agency collecting the same information.
If the collection of information has a significant impact on a substantial number of small businesses or other small entities (Item 5 of the Paperwork Reduction Act submission form), describe the methods used to minimize burden.
While other requirements in the proposed rule would have an impact on small businesses, the information collection aspects of the NPRM would not have a significant impact.
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.
Without these information collections, the FAA would not have a means of approving certificate holders’ risk-assessment programs. In addition, the FAA and other government entities would not have access to training records and flight data information in the event of an accident or incident.
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5(d)(2).
The collections are not inconsistent with 5 CFR 1320.5 (d)(2).
Describe efforts to consult 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. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d) soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
The FAA published a Notice of Proposed Rulemaking (NPRM) in the Federal Register on October 12, 2010 (75 FR 62640). The comment period closes on January 10, 2011.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
There would be no monetary considerations for this collection of information.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The respondents would not be given assurance of confidentiality.
Provide additional justification for any questions of sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.
There would be no questions of a sensitive nature.
Provide estimates of hour burden of the collection of information.
To aid in readability, this section will make references to the full economic evaluation.
Require certificate holders performing helicopter air ambulance operators to implement pre-flight risk-analysis programs (§135.615): This proposal would require that certificate holders outline procedures for conducting pre-flight risk-analysis programs in their operations manuals.
The following estimate corresponds to section A.1.d. of the economic evaluation.
Cost to helicopter air ambulance operators to develop a pre-flight risk analysis program
Air ambulance operators = 73
Time needed to develop risk analysis program = 60 hours
Salary of helicopter pilot = $48 per hour
Cost: 73 X 60 X $48 = $210,240
Time: 73 X 60 = 4,380 hours
Subsequent years: Per-year costs
Cost: $0
Time: 0 hours
Total over 10 years
Cost: $210,240
Time: 4,380 hours
Average per year
Cost: $210,240 / 10 = $21,024
Time: 4,380 hours / 10 = 438 hours
Cost for pilots to perform a pre-flight risk analysis before each flight
Air ambulance Helicopters = 989
Operations per year per aircraft = 367
Time needed for risk analysis = 10/60 hour
Salary of helicopter pilot = $48 per hour
First-year cost
Cost: 989 X 367 X (10/60) X $48 = $2,903,704
Time: 989 X 367 X (10/60) = 60,494 hours
Subsequent years: Per-year costs
Cost: 989 X 367 X (10/60) X $48 = $2,903,704
Time: 989 X 367 X (10/60) = 60,494 hours
Total over 10 years
Cost: $2,903,704 X 10 = $29,037,040
Time: 60,494 hours X 10 = 604,940 hours
Average per year
Cost: $29,037,040 / 10 = $2,903,704
Time: 604,940 hours / 10 = 60,494 hours
Require air ambulance operators with 10 or more helicopters to have an operations control center to communicate with pilots, advise pilots of weather conditions, and provide flight-following services (§135.617): This proposal would require certificate holders to train and test operations control specialists and retain records on those employees.
The following estimate corresponds to section A.1.b. of the economic evaluation.
Cost of Maintaining Records for the Operations Control Specialists’ Training and Examinations
Operations control specialists = 288
Time needed for a clerical person to maintain records of the training and examinations = 5/60 hour
Salary of clerical person = $26 per hour
Cost: 288 X (5/60) X $26 = $624
Time: 288 X (5/60) = 24 hours
Subsequent years: Per-year costs
Cost: 288 X (5/60) X $26 = $624
Time: 288 X (5/60) = 24 hours
Total over 10 years
Cost: $624 X 10 = $6,240
Time: 24 hours X 10 = 240 hours
Average per year
Cost: $6,240 / 10 = $624
Time: 240 hours / 10 = 24 hours
Require additional VFR flight planning (§135.613): This proposal would require helicopter air ambulance pilots to perform pre-flight planning. Certificate holders would need to outline procedures for pre-flight planning in their operations manuals.
The following estimate corresponds to section A.1.c. of the economic evaluation.
Cost to helicopter air ambulance operators to establish procedures to evaluate, analyze, and use additional VFR flight planning in their operations manuals
Air ambulance helicopters = 989
Operations per year per aircraft = 367
Time needed for the flight planning = 5/60 hour
Salary of helicopter pilot = $48 per hours
First-year cost
Cost: 989 X 367 X (5/60) X $48 = $1,451,852
Time: 989 X 367 X (5/60) = 30,247 hours
Subsequent years: Per-year costs
Cost: 989 X 367 X (5/60) X $48 = $1,451,852
Time: 989 X 367 X (5/60) = 30,247 hours
Total over 10 years
Cost: $1,451,852 X 10 = $14,518,520
Time: 30,247 hours X 10 = 302,470 hours
Average per year
Cost: $14,518,520 / 10 = $1,451,852
Time: 302,470 hours / 10 = 30,247 hours
Light-weight aircraft recording system (LARS) on helicopter air ambulances: The FAA is seeking comment on whether to require that certificate holders install LARS on their helicopter air ambulances and outline procedures for evaluating and using LARS data in their operations manuals.
The following estimate corresponds to section A.2.b. of the economic evaluation.
One-time cost to helicopter air ambulance operators to install LARS
Helicopter air ambulances = 989
Unit cost to equip with LARS= $6,450
First-year cost
Cost: 989/3 X $6,450 = $2,126,350
Subsequent 2 years: Per-year costs
Cost= 989/3 X $6,450 = $2,126,350
Total over 10 years
Cost= $2,126,250 X 3 = $6,379,050
Average per year
Cost= $6,349,050 / 10 = $637,905
Cost for LARS software
Helicopter air ambulances = 989
Cost for LARS software= $750
First-year cost
Cost= 989/3 X $750 = $247,250
Second-year cost
Cost= 989 X (2/3) X $750 = $494,500
Subsequent years: Per-year costs
Cost= 989 X $750 = $741,750
Total over 10 years
Cost= $247,250 + $494,500 + $741,750 X 8 = $6,675,750
Average per year
Cost= $6,675,750/10= $667,575
Cost to helicopter air ambulance operators to establish procedures to evaluate, analyze, and use LARS data in their operations manuals
Air ambulance operators = 73
Time needed for chief pilot = 2 hours
Time needed for a clerical person = 6 hours
Salary of chief pilot = $53 per hour
Salary of clerical person = $26
First-year cost
Cost: [73 X 2 X $53] + [73 X 6 X $26] = $19,126
Time: [73 X 2] + [73 X 6] = 584 hours
Subsequent years: Per-year costs
Cost: $0
Time: 0 hours
Total over 10 years
Cost: $19,126
Time: 584 hours
Average per year
Time: 584 hours / 10 = 58.4 hours
Require that medical personnel on board helicopter air ambulance flights either receive a supplemental safety briefing or safety training in lieu of a pre-flight briefing (§135.619): Certificate holders choosing the option to provide safety training would be required to retain training records on those employees.
The following estimate corresponds to section A.1.e. of the economic evaluation.
Cost to certificate holder for documenting the training provided to medical personnel
Medical personnel = 10,965
Time needed for a clerical person to document the training = 5/60 hour
Salary of Clerical Person = $26 per hour
First-year cost
Cost: 10,965 X (5/60) X $26 = $23,758
Time: 10,965 X (5/60) = 914 hours
Subsequent years: Per-year costs
Cost: 10,965 X (5/60) X $26 = $23,758
Time: 10,965 X (5/60) = 914 hours
Total over 10 years
Cost: $23,758 X 10 = $237,580
Time: 914 hours X 10 = 9,140 hours
Average per year
Cost: $237,580 / 10 = $23,758
Time: 9,140 hours / 10 = 914 hours
Require preparation of a load manifest by operators of all aircraft (not limited to multiengine aircraft) operated under part 135 (§135.63): This would amend existing OMB Control Number 2120-0039 by expanding the applicability from multiengine aircraft to all aircraft. The following, therefore, addresses single-engine aircraft only.
The following estimate corresponds to section C.2. of the economic evaluation.
Air ambulance aircraft (single-engine) = 108
Commercial aircraft (single-engine) = 3,752
Average number of takeoffs daily = 3
Technical time per takeoff= 5/60 hour
Salary of single-engine pilot= $38 per hour
First-year cost
Cost = [(108) X (3) X (365) X (5/60) X ($38)] + [(3,752) X (3) X (365) X (5/60) X ($38)] = $13,384,550
Time = [(108) X (3) X (365) X (5/60)] + [(3,752) X (3) X (365) X (5/60)] = 352,225 hours
Subsequent years: Per-year costs
Cost = [(108) X (3) X (365) X (5/60) X ($38)] + [(3,752) X (3) X (365) X (5/60) X ($38)] = $13,384,550
Time = [(108) X (3) X (365) X (5/60)] + [(3,752) X (3) X (365) X (5/60)] = 352,225 hours
Total over 10 years
Cost = $13,384,550 X 10 = $133,845,500
Time = 352,225 hours X 10 = 3,522,250 hours
Average per year
Cost = $133,845,500 / 10 = $13,384,550
Time = 3,522,250 hours / 10 = 352,225 hours
Require air ambulance operators that are required to have an operations control center to perform drug and alcohol testing on their operations control specialists (§§120.105 and 120.215)
The FAA believes that, because certificate holders currently administer and maintain records for drug and alcohol testing for other employees (approved under OMB Control Number 2120-0535), the cost for a clerical person to maintain these records would be negligible.
Summary of all Burden Hours and Costs:
Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
Per the analysis in question 12 above, the average annual cost for the LARS equipment and software over the next ten years will total $1,305,480. The FAA notes that no proposed requirement is being set out in the NPRM for LARS. Rather the agency is asking for comments on whether LARS will provide data that is valuable in an accident investigation. (See item 2 above.)
-
Average cost per year
LARS equipment
$637,905
LARS software
$667,575
TOTAL
$1,305,480
Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, and other expenses that would not have been incurred without this collection of information.
There would be no cost to the Federal government.
Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
These would be new collections, therefore this constitutes a program change.
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 plan for tabulation or publication.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
No such approval would be sought.
Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.
There would be no exceptions.
| File Type | application/msword |
| File Title | Air Ambulance and Commercial Helicopter Operations; Safety Initiatives and Miscellaneous Amendments |
| Author | Taylor CTR Dahl |
| Last Modified By | Taylor CTR Dahl |
| File Modified | 2010-10-15 |
| File Created | 2010-10-15 |
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