FAA - 2120-0765 - Supporting Statement - FINAL - 013117

Department of Transportation
Federal Aviation Administration

SUPPORTING STATEMENT
Small Unmanned Aircraft Registration System
2120-0765
INTRODUCTION
This revision to the 2120-0765/Small Unmanned Aircraft Registration System information
collection is submitted to the Office of Management and Budget (OMB) to request renewal of
the FAA collection necessary to register small unmanned aircraft for owners operating
exclusively in compliance with section 336 of the FAA Modernization and Reform Act. In
addition, this revision removes the “registration deletion” collection instrument approved under
an emergency clearance which was created in response to a mandate from the United States
Court of Appeals for the District of Columbia Circuit. Congress has since restored registration
for model aircraft in the National Defense Authorization Act of 2018 (P.L. 115-91).
Consequently, the FAA has discontinued its process for registration deletion and refund for
owners operating in compliance with section 336. All owners of small unmanned aircraft
weighing more than .55 pounds must register prior to operating outdoors in the national airspace
system.
Part A. Justification
1. Circumstances that make collection of information necessary.
The Secretary of the Department of Transportation (DOT) and the Administrator of the Federal
Aviation Administration (FAA) affirmed that all unmanned aircraft, including model aircraft, are
aircraft. As such, in accordance with 49 U.S.C. 44101(a) and as further prescribed in 14 CFR
part 47, registration is required prior to operation. See 80 FR 63912, 63913 (October 22, 2015).
Aircraft registration is necessary to ensure personal accountability among all users of the
national airspace system. Aircraft registration also allows the FAA and law enforcement
agencies to address non-compliance by providing the means by which to identify an aircraft’s
owner and operator.
Subject to certain exceptions discussed below, aircraft must be registered prior to operation. See
49 U.S.C. 44101-44103. Upon registration, the Administrator must issue a certificate of
registration to the aircraft owner. See 49 U.S.C. 44103
Registration, however, does not provide the authority to operate. Persons intending to operate a
small unmanned aircraft exclusively as model aircraft must operate in compliance with section
336 of Public Law 112-95, and are required to register. Persons intending to operate their small
unmanned aircraft not exclusively in compliance with section 336 must operate in accordance
with part 107, in accordance with a waiver issued under part 107, in accordance with an
exemption issued under 14 CFR part 11 (including those persons operating under an exemption
issued pursuant to section 333 of Public Law 112-95), or in conjunction with the issuance of a
special airworthiness certificate, and are required to register.

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The May 19, 2017 ruling by the U.S. Court of Appeals for the District of Columbia Circuit,
vacated the Small UAS Registration and Marking interim final rule vacated to the extent it
applied to model aircraft. As a result of the ruling, owners who were operating exclusively in
compliance with section 336 who wished to deleted their registration and receive a refund of the
registration fee could do so by requesting deletion from the FAA, which required the FAA to
collect their payment information. Congress has since restored registration for model aircraft in
the National Defense Authorization Act of 2018 (P.L. 115-91). Consequently, the FAA has
discontinued its process for registration deletion and refund for owners operating in compliance
with section 336. All owners of small unmanned aircraft weighing more than .55 pounds must
register prior to operating outdoors in the national airspace system. FAA is removing the
registration deletion collection instrument and hours from the collection.
2. How, by whom, and for what purpose is the information used.
The information collected as part of the small unmanned aircraft (sUAS) registration system will
identify to the FAA those persons owning small unmanned aircraft, whether the intended use is
as a model aircraft, or as other than a model aircraft. It will also allow the FAA to provide those
persons with educational materials regarding safety of flight in the National Airspace System
(NAS) to promote greater accountability and responsibility of these new users of the NAS.
3. Extent of automated information collection.
The part 48 small unmanned aircraft registration system is a fully automated, web-based online
registration system. The part 47 process will remain available as an alternative process for small
unmanned aircraft owners who wish to use a paper-based registration system.
4. Efforts to identify duplication.
The registration of small unmanned aircraft is within the purview of the FAA. Title 49, United
States Code, 44101-44106 and 44110-44113 require aircraft to be registered as a condition of
operation and establish the requirements for registration and registration processes. No other
Federal agency has similar requirements, thus there is no duplication.
The agency expects small unmanned aircraft owners to complete aircraft registration using the
part 48 registration process identified in the Interim Final Rule, “Registration and Marking
Requirements for Small Unmanned Aircraft”, RIN 2120-AK82 (part 48). Alternatively, small
unmanned aircraft owners may choose to register their aircraft by using the existing part 47
registration process (OMB Control No. 2120-0042).
5. Efforts to minimize the burden on small businesses.
The information required to be collected from persons intending to register small unmanned
aircraft as other than model aircraft is minimal:
(1) Applicant name and, for an applicant other than an individual, the name of the
authorized representative applying for a Certificate of Aircraft Registration.
(2) Applicant’s physical address and, for an applicant other than an individual, the
physical address for the authorized representative. If the applicant or authorized
representative does not receive mail at their physical address, a mailing address must also
be provided.

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(3) Applicant’s e-mail address or, for applicants other than individuals, the e-mail address
of the authorized representative.
(4) The aircraft manufacturer and model name.
(5) The aircraft serial number, if available.
The FAA believes that the minimal information requested, as well as efforts under way to permit
registration of multiple aircraft in one transaction, will significantly reduce any burden this
registration system might impose.
The FAA emphasizes that the minimal nature of the information being collected under the small
unmanned aircraft registration system discussed in this information collection should be viewed
in comparison with the current requirement that persons intending to use small unmanned
aircraft other than as model aircraft comply with the significantly more paperwork-intensive
requirements of 14 CFR part 47 and OMB information collection 2120-0042. That information
collection is estimated to take 30 minutes per response, as compared with the estimate of 5
minutes per response for this information collection.
6. Impact of less frequent collection of information.
Persons who own small unmanned aircraft are required to register with the FAA prior to
operation of those small unmanned aircraft. Registration is effective for three years and must be
renewed if the person wishes to continue to use small unmanned aircraft upon the expiration of
the Small Unmanned Aircraft Certificate of Registration. This update is requesting renewal for
registration through August 31, 2019 consistent with the terms of approval dated
August 12, 2016.
7. Special circumstances.
There are no special circumstances for this information collection.
8. Compliance with 5 CFR 1320.8.
A 60-day Notice was published in the Federal Register on November 3, 2017 (82 FR 51331)
requesting public comment on the renewal. No comments were received. The FAA published a
30-day Notice in the Federal Register on January 30, 2018 (83 FR 4395).
9. Payments or gifts to respondents. Explain any decision to provide a payment or gift to
respondents, other than remuneration of contractors or grantees.
No gifts or payments are provided for the registration of small unmanned aircraft.
10. Assurance of confidentiality.
The Privacy Act System of Records Notice DOT/FAA 801 Aircraft Registration Records,
provides notice to the public of the agency’s privacy practices regarding the collection, use,
sharing, safeguarding, maintenance, and disposal of information that affects individuals and their
personally identifiable information (PII). The SORN identifies the routine uses for the PII
collected for small unmanned aircraft registration. An updated SORN that addresses the
disclosure of the small unmanned aircraft owner’s name and address was published to the
Federal Register on December 15, 2015 (80 FR 77697).

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11. Justification for collection of sensitive information.
This information collection does not collect information of a sensitive nature. Only basic
identifying information in the form of name, physical and mailing address (if different than
physical address), and email address are collected. The rule requires that persons using the
system must be at least 13 years of age to register the small unmanned aircraft.
12. Estimate of burden hours for information requested.
The following table shows the total number of new registrations beginning January 2016 through
May 2016, their time, and their costs to fill out the online system. There is no differentiation
between modelers and non-modelers.
The average monthly number of respondents is 63,748 (318,739/ 5 months) and estimated annual
respondents are 764,976 (63,748 x 12 months) with estimated annual time burden of 63,746
hours (5312 average monthly hours x 12).
Month

# of Registrations

Minutes per
response

Hours

Jan

165,389

5

13,782

Feb

69,056

5

5,755

Mar

32,118

5

2,676

Apr

27,128

5

2,261

May

25,048

5

2,087

Total

318,739

26,561

*Hour time burden calculation: # of registrations x 5 minutes / 60*

Assuming a 10% increase each year and inclusion of renewals for the 3rd year (at least 90%
assumed), the Average Annual Respondents: 1,328,508 (2,532,071 + 1,453,454 / 3); Average
Annual Time Burden: 110,709 Hours (211,006 + 121,121 / 3).
Year

# of Registrations

Minutes per
response

Hours

1

764,976

5

63,748

2

841,474

5

70,123

3

925,621

5

77,135

Total

2,532,071

Renewal of
year 1
Registrations

1,453,454

Minutes per
response

5

Hours

121,121

211,006

An annual registration burden of 110,709 hours for a three year period from August 31, 2016
thru August 31, 2019 was approved in August 2016. This renewal request is submitted half way
through that approval period, thus for consistency the FAA is seeking approval of 55,355 hours
through August 31, 2019.
13. Estimate of total annual costs to respondents.
For persons registering an aircraft, the only costs to the respondents are the paperwork costs.
There are no capital or operation/maintenance costs for the respondents because of this rule.

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14. Estimate of cost to the Federal government.
The following table shows the total and present value costs to the government. An external
consultant estimated these costs based on the time and effort it would take to build the
registration system.
Year
0
1
2
3
4
5
Total

Calendar
Year
2015
2016
2017
2018
2019
2020

FAA Costs
(M$)
$3.9
$5.0
$3.2
$3.4
$3.0
$2.6
$21.2

7% P.V.
$3.9
$4.7
$2.8
$2.8
$2.3
$1.9
$18.4

Note: numbers may not add due to rounding

The cost of the information collection for the requested approval period is $15.5 million dollars,
averaged at $5.167M.
Year
0
1
2
3
Total

Calendar
Year
2015
2016
2017
2018

FAA Costs
($M)
$3.9
$5.0
$3.2
$3.4
$15.5

7% P.V.
$3.9
$4.7
$2.8
$2.8
$14.2

15. Explanation of program changes or adjustments.
Burden excludes actual registrations for the first 5 months of system activation. The 1st year
estimates are based on registrations for the final 7 months of the first year, as well as the
following 2 years with an assumption of 10% increase per year. The 3rd years add renewals from
year 1 with an assumption of 90% renewing.
16. Publication of results of data collection.
The System of Records Notice permits members of the public to search the collection by
registration number only. The results of the search would be limited per the Department’s
Privacy Act notice DOT/FAA 801 – Aircraft Registration Records. However, this capability for
a public search function has never been built in to the registration system.
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.

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18. Exceptions to certification statement.
There are no exceptions to the certification statement for this information collection.

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