PRA - FAA - 2120-0768 - Emergency Clearance (LAANC) - Update - 101917

Department of Transportation
Federal Aviation Administration

SUPPORTING STATEMENT
Waivers and ATC Authorization in Controlled Airspace under Part 107
2120-0768
INTRODUCTION
This information collection is submitted to the Office of Management and Budget (OMB) to
request an emergency approval of a new collection instrument under Information Collection
2120-0768, “ATC Authorization in Controlled Airspace under Part 107.” The emergency
request will allow Federal Aviation Administration (FAA) to leverage automated means of
collecting and processing airspace and operational authorizations (authorizations) under 14 CFR
Part 107 via Low Altitude Authorization and Notification Capability (LAANC) process.
Part A. Justification
1. Circumstances that make collection of information necessary.
In 2012, Congress passed the FAA Modernization and Reform Act of 2012 (Public Law 112-95).
Section 333 of Public Law 112-95 directed the Secretary to determine which types of unmanned
aircraft systems (UAS), as a result of their size, weight, speed, operational capability, proximity
to airports and populated areas, and operation within visual line of sight do not create a hazard to
users of the national airspace system (NAS) or the public or pose a threat to national security.
Based on such determinations, the statute required the FAA to establish requirements for the safe
operation of these systems in the NAS, prior to completion of the UAS comprehensive plan and
rulemakings required by section 332 of Public Law 112-95.
Based on its consideration of the comments submitted in response to the notice of proposed
rulemaking entitled Operation and Certification of Small Unmanned Aircraft Systems (80 FR
9543, February 23, 2015), and its experience with the certification, exemption, and Certificate of
Waiver or Authorization process, the FAA issued the Operation and Certification of Small
Unmanned Aircraft Systems final rule to enable certain small UAS operations to commence
upon adoption of this rule and accommodate technologies as they evolve and mature (81 FR
42063, June 28, 2016).
The final rule contains section 107.41, which states that:
§ 107.41 Operation in certain airspace.
“No person may operate a small unmanned aircraft in Class B, Class C, or Class D airspace or
within the lateral boundaries of the surface area of Class E airspace designated for an airport
unless that person has prior authorization from Air Traffic Control (ATC).”
The FAA established the ATC Authorization in Controlled Airspace and Waivers under 14 CFR
Part 107 to allow an operator to request FAA authorization for a small unmanned aircraft to
operate in Class B, C, D, and the lateral boundaries of the surface area of Class E airspace
designated for an airport.

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Current Collection Instrument – Web Portal/Drone Zone; Airspace Authorizations and Waivers,
and Operational Authorizations.
Information regarding the current collection instrument is provided as background information
only to support the emergency request for the new information collection instrument. Changes
to the web portal made to enhance customer experience and to refine data elements so that the
FAA may provide a better service to the public and its rebranding as DroneZone were approved
by OMB as a non-substantive change to this collection on September 27, 2017
The FAA previously established an information collection and web portal to facilitate the
collection of information in furtherance of requests for authorizations under part 107. The entity
applying for an authorization will submit information through the web portal to the FAA
regarding the operation to be conducted. Information will include contact information for the
operator, the date and time of the operation, as well as its anticipated duration, and the airspace
for which the request is submitted.
New Collection Instrument - Low Altitude Authorization and Notification Capability (LAANC);
Part 107 Airspace Authorizations
A recent FAA study (Part 107 Post-Implementation Analysis) showed that the current 60-90 day
turnaround time for airspace authorizations is increasing the number of non-compliant UAS
operations. Non-compliant operations have resulted in nearly 250 Mandatory Occurrence
Reports (MORs) involving a manned aircraft and a UAS every month. The majority of the time
these reports are extremely hazardous situations, such as a near mid-air collision or a UAS
operation at unsafe altitudes. Most these reports occurred in class B, C, D, and surface E
airspace, which are the safety critical areas around the Nation’s most congested airports.
Therefore the FAA has developed an automated process that leverages external providers of
UAS services (UAS Service Suppliers). The capability, known as Low Altitude Authorization
and Notification Capability (LAANC) will reduce the turnaround time for providing
authorizations and/ or coordination. The automated LAANC capability uses data provided by
external providers of authorization services known as UAS service suppliers (USS). 1 USS, use
FAA provided UAS Facility Maps (UASFM) to determine whether a 14 CFR Part 107
operations can be authorized in controlled airspace. The USS collects data from the requestor of
the authorization and provides a subset of that data through data exchange with the FAA. The
data provided to the FAA for Part 107 operations include aircraft operator name; telephone
number of the operator for operational coordination if necessary; regulation for which the
operator is operating under; requested date and time operations will commence and conclude
under the authorization; duration of the operation, requested altitude applicable to the
authorization; description of proposed operation in center/radius or polygon format; identifiers
and versions of applicable UASFM(s). In addition, the operator provides registration number
optionally. Records provided by LAANC to the FAA are necessary to ensure the safe operation
of the NAS, hence the reason for pursuing an emergency PRA. Data elements requested by the
FAA are the minimal information required for ATC to know where and when an operation is
occurring and contact an operator in the event of either an emergency or if additional
coordination needs to take place and are consistent with the data collected from UAS operators
who submit authorization requests via the FAA Drone Zone web portal.

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USS support for notification processes will be deployed at a later date.

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The FAA has provided a letter from its Office of General Counsel further explaining the need for
the Emergency request.
2. How, by whom, and for what purpose is the information used.
Operators can use LAANC for authorizations that don’t require a waiver; under daylight
conditions; and where facility map data has been established by the local ATC. In this method,
an operator accesses one of many available USS to plan and implement a Part 107 flight in
controlled airspace. Using LAANC, as governed by a set of operating rules, and using the
UASFM, the USS’s are able to automatically provide authorizations under Part 107. ATC
facilities create gridded maps (UASFM) that provide maximum allowable altitudes for safe
operation in controlled airspace. UASFM’s are then managed (updated and new ones released)
on a 56 day cycle. When an operator requests authorization within airspace within the UASFM,
the USS will access the UASFM and provide airspace authorizations to the operators using the
data contained in the map. The authorization information is provided to the FAA via data
exchange, where it is stored and displayed to local ATC facilities. If an authorization request
cannot be automatically approved using UASFMs because the request exceeds the altitude
threshold, operators may request through the LAANC system that local ATC consider altitudes
higher than the stated UASFM map altitude and under the 400 foot maximum height.
If the FAA did not collect this information, the FAA would not be able to grant certificates of
authorization for the above mentioned activities, in accordance with 14 CFR § 107. Additionally,
the FAA would be unable to control and maintain the consistently high level of civil aviation
safety the agency is compelled to guarantee pursuant to its statutory obligations. 2
3. Extent of automated information collection.
The FAA proposes to collect authorization information under Part 107 via data exchange with
LAANC USS. USS provide an electronic method for operators to enter specific information
about a requested authorization. The USS, using UASFM provide a Part 107 authorization to the
operator and the resulting approved authorization and other information is sent via an application
program interface (API) to the FAA as an electronic record, which is stored in an FAA data
repository.
LAANC provides a more efficient and consistent method of providing authorizations for
Part 107 operations. In addition, the electronic process ensures consistency in the input of
information, which further enables the process for responding to the requests in a consistent,
efficient manner.
4. Efforts to identify duplication.
The information collection specific to ATC Authorizations under the final small UAS rule is
unique to each operator and not applicable to the operator community at large at this time. Each
request is reviewed based on its individual operating needs and capabilities, which could be in
various combinations of each, thus creating a unique information profile for every operator
requesting access to controlled airspace. Duplicate records for the same authorization request
could exist if an operator chooses to use the DroneZone portal and LAANC for the same
operation.
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See, e.g., 49 U.S.C. §§ 40103 and 44701; Pub. L. 112-95 § 333.

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5. Efforts to minimize the burden on small businesses.
An automated approach to information collection is deliberate and driven by the highly dynamic
and short term nature of operations conducted by this community of operators. As described
above, the information collection is automated to ensure the collection process as efficient and
least burdensome as possible for operators who conduct flight of short duration that are not
complex.
Operators choosing to use LAANC will access authorization services through an external
USS. USS will manage and maintain accounts operators who wish to access authorization
services under 14 CFR Part 107. The information the USS will collect for these purpose is the
minimal information determined by the FAA to be required to decide to approve/deny the
operation. In the event the operator wants to fly above the approved altitudes they will be asked
to provide additional safety mitigations applied to the operations. The relationship with operators
through USS is anticipated to increase efficiency and reduce the burden on businesses.
6. Impact of less frequent collection of information.
An applicant is required to request authorization prior to operating in controlled airspace. If the
frequency of the collection of information is reduced such that an applicant does not submit the
request for authorization prior to operating, that person will have no means by which to obtain
authorization to operate pursuant to 14 CFR at 107.41 in controlled airspace.
7. Special circumstances.
There are no special circumstances for this information collection.
8. Compliance with 5 CFR 1320.8.
This is an emergency request. The FAA has published a notice informing the public of this
emergency request. See 82 FR 47289 (October 11, 2017).
9. Payments or gifts to respondents.
No gifts or payments are provided for the processing of authorizations.
10. Assurance of confidentiality.
There is no confidentiality requested or provided.
11. Justification for collection of sensitive information.
The only information collected that may be considered “sensitive in nature” is the personal
information associated with an operation (aircraft operator name, telephone number, and
optionally provided registration number). This personal information is limited to what is
necessary for ATC to contact UAS operators in the event of a hazardous condition or if they
require additional coordination to approve an operation. Any records collected under the
LAANC process covered by the Privacy Act will be managed in accordance with the Department
of Transportation system of records notice (SORN) DOT/FAA 854 - Requests for Waivers and
Authorizations under 14 CFR Part 107, (81 FR 50789, Aug. 2, 2016). The FAA is in the

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process of developing a Privacy Impact Assessment (PIA) for LAANC for approval and
publication by the Departmental Chief Privacy Officer.
12. Estimate of burden hours for information requested.
Authorization Requests Using Web Portal/Drone Zone:
From September 2016 to July 2017, the FAA received 19,978 authorization requests. 3 Using the
current monthly growth rate of authorizations (35% ) the FAA estimates it will receive 26,970
authorization requests in 2018 and 36,410 requests in 2019. The total number of respondents
over three years would total 83,358, for an average annual response rate of 27,786 or 13,893 for
the span of the emergency request. The FAA estimates that completion the authorization form
on the portal will take 0.5 hour to complete. Therefore, the FAA estimates the annual time
burden for using the FAA’s electronic portal to be approximately 9,589 hours for authorizations
in 2017, 13,485 hours in 2018, and 18,205 hours in 2019 totaling 41,279 hours over a 3-year
period. On an annual basis, this burden is calculated at 13,760 or 6,880 for the span of the
emergency request.
Period

Respondents

Respondents Calculation

Burden
(hours)

Burden Calculation

Year 1 (2017)

19,978

19,978 (baseline)

9,989

Year 1 Respondents * .5 hours
19,978 * .5

Year 2 (2018)

26,970

Year 1 +35%(Year 1)
19,978 + 6992

13,485

Year 2 Respondents *.5 hours
26,970 *.5

Year 3 (2018)

36,410

Year 2 + 35%(Year 2)
26,970 + 9,440

18,205

Year 3 Respondents *.5 hours
36,410 * .5

Total

83,358

Year 1 + Year 2 + Year 3
19,978 + 26,970 + 36,410

41,679

Year 1 + Year 2 + Year 3 (Burden
Hours)
9,989 + 13,485 + 18,205

Annual

27,786

Total / 3 years

13,893

Total (Burden Hours) / 3
41,679/ 3

Emergency
(6 months)

13,893

Annual / 2

6,947

Annual (Burden Hours) / 2
13,893/ 2

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The 30-day notice for emergency processing (82 FR 47290) states that the FAA has received 20,566 authorization
requests from September 2016 thru July 2017. This number reflects both authorizations and waivers under Part 107
and the most recent analysis of respondent demand. This emergency processing request applies only to
authorizations to be processed via the LAANC deployment. The FAA recognizes that the number of authorizations
and waivers currently received by the FAA exceeds the current approved collection and had anticipated submitting a
revised package for 2120-0768. In consultation with the Department it was determined that the FAA should seek
emergency approval of the LAANC deployment to support safety improvements and address the overage in the full
approval package.

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The FAA estimates that using the USS, LAANC based method for authorizations will require
five minutes per transaction. If all operators seeking authorizations use the LAANC process, the
burden would be 1,598 for 2017, 2,158 for 2018, and 2,613 for 2018. The total and annual
burden for the collection would be 6,669 and 2,223 hours respectively and 1,112 hours for the
span of the emergency request.
Period

Respondents

Respondents Calculation

Burden (hours)

Burden Calculation

Year 1 (2017)

19,978

19,978 (baseline)

1,598

Year 1 Respondents * 5 minutes (.08 hours)
19,978 * .08

Year 2 (2018)

26,970

Year 1 +35%(Year 1)
19,978 + 6992

2,158

Year 2 Respondents * 5 minutes (.08 hours)
26,970 *..08

Year 3 (2018)

36,412

Year 2 + 35%(Year 2)
26,970 + 9,440

2,913

Year 3 Respondents * 5 minutes (.08 hours)
36,410 * .08

Total

83,358

Year 1 + Year 2 + Year 3
19,978 + 26,970 + 36,410

6,669

Year 1 + Year 2 + Year 3 (Burden Hours)
1,598 + 2,158 + 2,913

Annual Average

27,786

Total / 3 years

2,223

Total (Burden Hours) / 3
6,669 / 3 years

Emergency
(6 months)

13,893

Annual / 2

1,112

Annual (Burden Hours) / 2
1,112 / 2

The Burden Savings for using LAANC over the Web Portal/Drone Zone, assuming 100% usage
of LAANC is 8,381 hours in 2017, 11, 327 hours in 2018, and 16, 607 hours in 2019. Over a
three year period this equates to a savings of 36,325 hours or 12,108 hours annually, and 6,054
hours for the period of the emergency request.
Savings Calculation
Period

Burden Savings

Burden Calculation

Year 1 (2017)

8,391

Year 1 Web – Year 1 LAANC
9,989 - 1598

Year 2 (2018)

11,327

Year 2 Web – Year 2 LAANC
13,485- 2,158

Year 3 (2018)

16,607

Year 3 Web – Year 3 LAANC
18,205- 1598

Total

36,325

Year 1 + Year 2 + Year 3 (Burden Savings)
8,391 + 11,327 + 16,607

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Annual Average

12,108

Total (Burden Savings) / 3 years
36,325 / 3

Emergency
(6 months)

6,054

Annual (Burden Savings) / 2
12,108 / 2

The FAA will use the six months of the emergency collection to determine accurate rates of
usage and adjust its burden calculations as appropriate in the renewal package for the collection
expiring June 30, 2018. The FAA is currently approved for 9,500 hours for collections via the
web/DroneZone instrument. The FAA has created a burden of 12 respondents at 5 minutes in
ROCIS, resulting in a total burden increase of 1 hour in support of the emergency processing
request for the LAANC instrument, bringing the total burden for the information collection to
9,501 hours.
13. Estimate of total annual costs to respondents.
We estimate that there will be no additional start-up costs for this collection. No special
equipment is required for persons to submit air traffic control (ATC) authorization or waiver
requests under 14 CFR Part 107. The cost to access a USS to seek authorizations is determined
by the USS provider. The FAA will gather information regarding USS provider fees over the
emergency collection period and identify such costs in the renewal package
14. Estimate of cost to the Federal government.
System Sustainment and Maintenance
The LAANC shares system architecture and resources, allowing the FAA to save money on
cloud hosting fees and other sustainment costs. Due to both systems being deployed in FY 2018
there were no relevant hosting or sustainment fees. The estimated cost of both systems is
captured in table 1 below. The cost reflected below is solely for LAANC and does not include
other costs associated with the other collection instrument in 2120-0768.
2017

2018
$800,000
$500,000

2019
$800,000
$500,000

LAANC Sustainment
$0
LAANC Cloud
$0
Hosting Fees
Total
$0
1,300,000
$1,300,000
Table 1. Estimated System Sustainment and Maintenance Costs

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The following information is here for background purposes to demonstrate the level of effort
required in terms of staff (employees and contractors) to process authorizations not processed via
LAANC. The FAA will use the six months of the emergency collection to determine impact on
FAA staffing and will adjust cost calculations as appropriate in the renewal package for the
collection expiring June 30, 2018.
ATO FTE Analysts
The Air Traffic Organization (ATO) will add full-time equivalent (FTE) employees to analyze
the authorizations. As the FAA DroneZone and LAANC are introduced, the FAA anticipates a
slight reduction in FTE to analyze authorizations (both LAANC and DroneZone). Table 2
identifies the expected FTE’s required in Fiscal Year 2017, 2018, and 2019.
ATO

2017

2018

2019

Temporary
Support Specialist

16

16

14

Support Specialists

15

20

18

Total

31
36
32
Table 2: ATO FTE Employees Supporting the
Airspace Authorizations and Waiver Request Process

ATO FTE Analysts Costs – Total Wage Costs
To provide a conservative cost estimate for the FAA to add additional ATO FTEs to support the
Part 107 rulemaking, including Authorizations and Waivers, the FAA uses wages that are at the
top of the pay for the applicable job series. Table 3 identifies the expected hourly wage for
support personnel.
Hourly Wage
Support Specialists

$84.98

Table 3: Wage for ATO FTEs by Job Series
ATO FTE Analysts Costs – Additional Support
Presented in Table 4 below are the FAA’s costs to add FTEs employees in support of the Part
107 final rule over the 3-year analysis period. The costs are calculated by multiplying the
number of FTEs by job series shown in Table 2 by the column labeled “Total Compensation” in
Table 3.
ATO
Temporary Support
Specialists
Facility Support
Specialists
Total

2017

2018

2019

Total

$2,828,134

$2,828,134

$2,474,618

$8,130,886

$2,651,376

$3,535,168

$3,181,651

$9,368,195

$5,479,510
$6,363,302
$5,656,269 $17,499,082
Table 4: ATO Costs to Hire Full-Time Equivalent Employees

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15. Explanation of program changes or adjustments.
The program change is changing due to agency discretion in the way Part 107 authorization
requests are processed. A complete description of the change can be found in the in the response
to Question 1. The FAA collects this information in accordance with the Operation and
Certification of Small Unmanned Aircraft Systems Final Rule, 81 FR 42064 (June 28, 2016)
from operators wishing to conduct small unmanned aircraft operations in Class B, C, D, and the
lateral surfaces of Class E airspace and/or request a waiver of a regulation listed in 14 CFR
§ 107.205. The FAA uses the information it collects to approve or disapprove requests for
airspace authorizations. The information will be collected via LAANC is substantively similar to
information collected for authorization processing via the FAA web portal/Drone Zone.
Since the promulgation of Part 107, the FAA has received an extremely high volume of airspace
authorization requests for UAS operations. Requests have steadily increased over time and the
volume of these authorization requests has dramatically increased the time between submission
and approval of the same. Currently, airspace authorization requests may be in queue sixty to
ninety days before receiving a response. Using the LAANC system, the FAA will be able to
grant near-real time authorizations for the vast majority of operations.
16. Publication of results of data collection.
The FAA, however, posts online the waiver decisions, as described in DOT/FAA System of
Records Notice 854 (Requests for Waivers and Authorizations under 14 CFR Part 107), 81 FR
50789 (Aug. 2, 2016).
17. Approval for not displaying the expiration date of OMB approval.
The FAA is not seeking approval not to display the date of expiration of this information
collection.
18. Exceptions to certification statement.
There are no exceptions to the certification statement for this information collection.

CLAIRE W
BARRETT

Digitally signed by CLAIRE W BARRETT
DN: c=US, o=U.S. Government, ou=DOT
Headquarters, ou=OSTHQ, cn=CLAIRE W
BARRETT
Date: 2017.10.19 11:09:34 -04'00'

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