Supprting Statement 2120-0044 UPDATED May 24 Final

Supporting Statement

Rotorcraft External‑Load Operator

Certificate Application ‑ FAR‑133

OMB 2120‑0044

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

Part A of Subtitle VII of the Revised United States Code authorizes the issuance of regulations governing the use of navigable airspace. 14 CFR Part 133, Rotorcraft External-Load Operations, was adopted to establish certification and operating rules governing nonpassenger-carrying rotorcraft external-load operations conducted for compensation or hire. As such, the Federal Aviation Administration (FAA) requires information reporting by affected Rotorcraft External‑Load Operators in order to maintain its regulatory responsibilities. The collection of this information directly supports the Department of Transportation’s strategic goal on safety.

2. 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.

The respondents to this collection are mandated to collect and report information to the FAA. Respondents are organizations wishing to conduct nonpassenger-carrying external-load operations for compensation or hire, which requires the proper certification and or renewal of certification. The FAA uses this information, required, to process the operating certificate as a record of aircraft authorized for use, and to monitor Rotorcraft External‑Load Operations. FAA Form 8710‑4, Rotorcraft External‑Load Operator Certificate Application, provides a record of surveillance activities when completed by an inspector. If the information was not collected, FAA would not be able to meet its regulatory responsibilities for oversight and surveillance under Part 133.

3. 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.

The collection of this information does not lend itself to sophisticated collection techniques or other forms of collection. There presently is no other method contemplated to replace the information collected by FAA Form 8710-4, Rotorcraft External-Load Operator Certificate Application. Applicants may electronically request applications to conduct operations or an activity. Therefore, it is felt that the spirit of the Government Paperwork Elimination Act (GPEA) is accomplished. However, most of the activity associated with this information collection must be physically verified (airmen certificates, aircraft inspections, etc.) by aviation safety inspectors prior to its approval. The United States cannot risk having unknown people operating within its critical infrastructure.

4. Describe efforts to identify duplication. Show specifically why any similar information already available can be used for the purpose described in Item 2 above.

We have reviewed our other public reports to insure that no duplication exists. To our knowledge, no other agency is responsible for collecting information on Rotorcraft External‑Load Operators.

All information gathered is compiled for a specific reason, from a specific source and relates to a unique and specific requirement and situation. This information is collected every 24 months for 133-certificate renewal; however, it is necessary to have the most timely and accurate information.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Small businesses or small entities may receive, upon request, specific assistance from FAA Aviation Safety Inspectors located in district offices around the country. This collection of information is reviewed periodically to ensure the requirements involved are kept to the minimum necessary to bring about effective compliance with Part 133. To keep the burden to a minimum on small businesses, the inspectors deal directly with the certificate holders' management personnel.

6. 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.

The Code of Federal Regulations determine frequency of collection for 133 certificate renewals. The respondents cannot legally conduct external-load operations without the proper certification and or renewal.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with 1320.5(d)(2)(i)-(viii).

The guidelines specified in 5 CFR 1320.5(d)(2)(i)-(viii) are being complied with in the collection of information required by this FAR Part.

8. Provide information on the PRA Federal Register Notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the efforts to consult with 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.

A Federal Register Notice published on January 19, 2018 (83 FR 2866), solicited public comment. No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts are made to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

There is no confidentiality requested or provided.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

There are no questions of a sensitive nature.

12. Provide estimates of hour burden of the collection information. This information should provide number of respondents, frequency of response, annual burden, and an explanation of how the burden was estimated.

A section by section breakdown of the applicable sections of Part 133 is listed below, showing frequency of response, number of respondents, annual burden, and how the burden has been estimated.

Section 133.15, Application for Certificate Issuance or Renewal. Requires that a would‑be operator make application on a form and manner prescribed by the Administrator. FAA Form 8710‑4, Rotorcraft External‑ Load Operator Certificate Application is the form prescribed by the Administrator and approved by OMB. It contains only information necessary for a Part 133 Operating Certificate.

Estimated number of annual recertifications

and new applications: 178.5 (was 200)

Estimated average hours per submission .5 (was .3)

Estimated annual reporting burden 89.25 hours

Section 133.21, Personnel.

Requires applicant to designate one pilot as chief pilot for rotorcraft external‑load operators. Paragraph (c) requires certificate holders to report any change in chief pilot designation.

Estimated number of annual chief pilot designations 40

Estimated average hours per submission .3

Estimated annual reporting burden 12 hours

Estimated annual reported changes in designations 40

Estimated average hours per submission .3

Estimated annual reporting burden 12 hours

Total 133.21 Estimated annual reporting burden 24 hours

Section 133.25, Amendment of Certificate.

This section indicates a certificate holder may submit a list of new or deleted aircraft to be used.

Estimated annual requests for amendment 89.25 (was 45)

Estimated average hours per request .5 (was .3)

Estimated annual reporting burden 44.625 hours

Section 133.27, Availability, transfer, and surrender of certificate.

Requires each certificate holder to keep the certificate and a list of authorized rotorcraft at the home base of operations.

Total number of operators maintaining records 400

Estimated time required to maintain records .5

Estimated annual recordkeeping burden 200 hours

Section 133.31, Emergency Operators.

Operators, upon request, are required to provide a report of a deviation from the rules.

Estimated number of operators required to report 25

Estimated time required to complete a report 2

Estimated annual reporting burden 50 hours

Section 133.33, Operating Rules.

This section requires an operator to develop a plan for congested area operations and obtain approval to implement that plan.

Estimated number of operators required to

develop the congested area plans 300

Estimated number of plans per operator, per year x 3

900

Estimated time required per plan x 2

Total annual reporting burden 1800 hours

Section 133.37, Crewmember training, currency, and testing requirements.

Each pilot must demonstrate his skill and knowledge before he can serve.

Estimated number of operators maintaining records 400

Estimated time required to maintain records .3

Total recordkeeping burden 120 hours

Section 133.47, Rotorcraft‑Load Combination Flight Manual. Requires the applicant to prepare a flight manual and submit

it for approval by the Administrator.

Estimated manual submissions (new applicants only) 25

Estimated average hours per submission 40

Estimated total reporting burden 1,000 hours

Total recordkeeping burden hours 320

Total reporting burden hours 3,007.875

Total information collection burden 3,327.875 hours

The annualized cost to the public to process the information required was determined by the following method:

Hours by Regulation Hours

133.15 178.5 applications @ .5 hours 89.25 (Reporting)

133.21 80 reports @ .3 hours 24.00(Reporting)

133.25 89.25 amendments @ .5 hours 44.625(Reporting)

133.27 400 operators @ .5 hours 200.00(Recording)

133.31 25 reports @ 2 hours 50.00(Reporting)

133.33 900 plans @ 2 hours 1800.00(Reporting)

133.37 400 records @ .3 hours 120.00(Recording)

133.47 25 submissions @ 40 hours 1000.00(Reporting)

3,327.875

Approximately 80 percent of the total cost is labor done by technical specialists at $25 per hour, and 20 percent is by clerical labor at $12 per hour. Wage estimates are based on the Bureau of Labor Statistics Occupational Employment and Wages data, May 2017, for Secretaries and Administrative Assistants, and Technical Specialists. Other expenses such as general and administrative costs, overhead costs, and other indirect costs are estimated to amount to approximately 15 percent of the direct labor costs. Based on the above, the annualized cost to the public is as follows:

Estimated total annual labor burden 3,327.875 hours

Technical Labor (3,327.875 x .8 x $25) $66,557.50

Clerical Labor (3,327.875 x .2 x $17) $11,314.78

$77,872.28

Overhead Labor Expenses ($74,544.40x .15) $11,680.84

TOTAL $89,553.12

13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information.

We estimate that there will be no start-up costs for this renewal.

14. Provide estimates of annualized cost to the Federal government.

The annualized cost to the Federal Government to collect, analyze, and process the information received was determined by the following method:

Hours by Regulation Hours

133.15 178.5 applications @ 2 hours 357

133.21 80 designations @ 1 hour 80

133.25 89.25 amendments @ 1 hour 89.25

133.27 400 changes @ 1 hour 400

133.31 25 reports @ 4 hours 100

133.33 900 reports @ 2 hours 1800

133.37 400 demonstrations @ 2 hours 800

133.47 25 manual reviews @ 4 hours 100

3,726.25

Approximately 80 percent of the total cost is government labor done by technical specialists at $53 per hour, and 20 percent is by clerical labor at $42 per hour. Other expenses such as general and administrative costs, overhead costs, and other indirect costs are estimated to amount to approximately 15 percent of the direct labor cost. Based on the above, the annualized cost to the Federal Government is as follows:

Estimated total annual labor burden 3,726.25hours

Technical Labor (3,726.25x .8 x $53) $157,993

Clerical Labor (3,726.25x .2 x $42) $31,300.50

$189,293.50

Overhead Labor Expenses ($22,669.50 x .15) 28,394.025

TOTAL $217,687.52

15. Explain reasons for program changes or adjustments reported in Items 13 or 14 of OMB Form 83-1.

The total hourly burden is updated to reflect a more accurate estimate of the actual burden. We estimated the number of annual recertifications and new applications to be 200 in the last submission. Based on actual figures we estimate this to be 179. We estimated the time required to complete these requests to be .3 hours in the previous submission, while in this submission we estimate the time to be .5 hours. In Section 133.25, Amendment of Certificate we now estimate there to be 89 responses, while in the previous submission we estimated 45. We also estimated the time required to complete this to be .3 hours in the previous submission and now estimate the required time per response to be .5 hours.

With this submission in ROCIS the burden is entered in a more granular format showing burden by sections of the regulation.

16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used.

There is no requirement for any of the information collected pursuant to FAA Form 8710-4 to be published.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We are not seeking approval to exclude the expiration date.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.

There are no exceptions.

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