2120-0756 2019 renewal

Supporting Statement A

Helicopter Air Ambulance, Commercial Helicopter, and Part 91 Helicopter Operations

OMB#: 2120-0756

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

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.

Some sections of this final rule are already covered by OMB-approved package 2120-0039 titled Part 135 – Operating Requirements: Commuter and on-demand operations and rules governing persons on board such aircraft. The existing part 135 rules require certain manuals for operations and training. This new collection adds some requirements for those same manuals. Each reference to manuals is addressed in the appropriate section below.

This information collection supports the Department of Transportation’s strategic goal of safety. Specifically, the goal is to promote the public health and safety by working toward the elimination of transportation-related deaths, injuries, and property. Future reports of these same sections will be reported in 2120-0039 for part 135.

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.

These requirements in part 135 are addressed specifically to helicopter air ambulances, often referred to as emergency medical services (EMS), and to on-demand operations including overwater operations. The National Transportation Safety Board recommended several changes following accident investigations. The FAA aims to improve the safety record of helicopter air ambulances through better oversight of their operations. The FAA will use the information it collects and reviews to ensure compliance and adherence with regulations and, if necessary, to take enforcement action on violators of the regulations.

Section 44731 of the Modernization and Reform Act of 2012 required the FAA to collect from part 135 certificate holder providing helicopter air ambulance services a report containing the number of helicopters that the certificate holder uses to provide helicopter air ambulance services, the base locations of the helicopters, the number of flights and hours flown by registration number while providing helicopter air ambulance services, the number of flight requests for a helicopter providing air ambulance services that were accepted or declined by the certificate holder and the type of each such flight request (such as scene response, inter-facility transport, organ transport, or ferry or repositioning flight), the number of accidents, if any, involving helicopters operated by the certificate holder while providing air ambulance

services and a description of the accidents, the number of flights and hours flown under instrument flight rules by helicopters operated by the certificate holder while providing air ambulance services, the time of day of each flight flown by helicopters operated by the certificate holder while providing air ambulance services, and the number of incidents, if any, in which a helicopter was not directly dispatched and arrived to transport patients but was not utilized for patient transport.

Section 314(d) of the FAA Reauthorization Act of 2018 amended these reporting requirements for the report to contain the number of helicopters that the certificate holder uses to provide helicopter air ambulance services and the base locations of the helicopters, the number of hours flown by the helicopters operated by the certificate holder, the number of patients transported and the number of patient transport requests for a helicopter providing air ambulance services that were accepted or declined by the certificate holder and the type of each such flight request (such as scene response, inter-facility transport or organ transport), the number of accidents, if any, involving helicopters operated by the certificate holder while providing air ambulance services and a description of the accidents, the number of hours flown under instrument flight rules by helicopters operated by the certificate holder, the number of hours flown at night by helicopters operated by the certificate holder, the number of incidents, if any, in which a helicopter was not directly dispatched and arrived to transport patients but was not utilized for patient transport.

Essentially, this relieved the requirement for reporting of flight time by individual aircraft and by time of day and now only requires the reporting of the total flight hours, in aggregate, flown by the certificate holder and the number of hours flown at night. The amendment added the requirement to report the number of patients flown by the certificate holder.

The requirement for reporting is placed upon the certificate holders via Operations Specification paragraph A021, Air Ambulance Operations—Helicopter. A reporting template is provided to the certificate holders by the FAA Part 135 Commuter and On-demand Operations Branch, AFS-250.

The data collected is to provide a report to the Committee on Transportation and Infrastructure of the House of Representatives and the Committee on Commerce, Science, and Transportation of the Senate as required by §44731. It is also being collected to ensure that the database required and the report required will best inform efforts to improve the safety of helicopter air ambulance operations.

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.

The FAA encourages electronic transmission and most certificate holders readily use electronic transmission to communicate with the FAA. However, electronic transmission is optional and there are some certificate holders that still do not use it for their own reasons.

The form provided to the certificate holders by the FAA is in Excel format and is easily submitted as an email attachment. The email address for submission is provided on the form.

Operations Specifications (the documents that give the operators their authority) are completely automated via the FAA online web-tool, WebOPSS. Many operators currently use and access WebOPSS on a daily basis to manage their operations and authorizations. Still, the few operators that do not participate in automation may let their FAA principal inspectors know what they need and the inspectors will generate the appropriate approvals and give the operator printed copies. All the data is available at FAA Headquarters in Washington, D.C. in the WebOPSS electronic database.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

We reviewed the supporting statements for information collection, FAA regulatory parts 121, 135, and 136. We found no duplication and do not know of any other agency collecting the same information.

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

The collection of information does not have a significant impact on a substantial number of small entities.

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.

Without this collection, helicopter air ambulance pilots would be able to use designated local flying areas without demonstrating their familiarity and detailed knowledge of the hazards and high altitude terrain in local flying areas in order to use the lower minimums every year. Therefore, pilots would be able to use the local flying area weather minimums without having to pass an examination given by the certificate holder within the 12 months prior to using the local flying area minimums (§135.609). Additionally, pilots would not have to document the highest obstacle along the planned route of flight (§135.615).

Without this collection, the certificate holder performing helicopter air ambulance operations would not have to have an FAA-approved pre-flight risk-analysis program and their pilots would not have to complete a worksheet prior to the first leg of each helicopter air ambulance operation. (§135.617)

Without this collection, operations control specialists would not complete safety duties to include review of the pilot’s worksheet required in §135.617 or complete training and testing. (§135.619)

Without this collection, medical personnel would not require training or briefings. (§135.621)

In addition, the FAA would not have access to training records or sections of manuals that this rule requires.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document; requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances that require these collections to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5 (d)(2).

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 September 17, 2019 (84 FR 48989) solicited public comment. No comments were received.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

No payments or gifts will be provided to respondents.

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

There is no assurance of confidentiality provided to respondents.

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 the hour burden of the collection of information.

The average hourly rate for Helicopter Chief Pilots is $40.66 per hour.¹ A 31.4 percent multiplier was then applied to account for fringe benefits which brings the salary to $53.43 per hour.² To account for overhead, a multiplier of 17 percent was applied.³ The total salary with fringe and overhead is $63 per hour (rounded to the nearest dollar). The average hourly rate of a Helicopter Pilot is $32.45 per hour.⁴ A 31.4 percent multiplier was then applied to account for fringe benefits which brings the salary to $42.64.⁵ To account for overhead, a multiplier of 17 percent was applied.⁶ The total salary with fringe and overhead is $50 per hour (rounded to the nearest dollar). The average hourly rate of a typist (clerical) is approximately $18.25 per hour, based on a typist (clerical) earning FG-5, Step 5 (Kansas City Locality Pay).⁷ Kansas City locality pay was utilized as it is a mid-point, cost wise, for locality pay. A 31.4 percent multiplier was then applied to account for fringe benefits which brings the salary to $23.98 per hour.⁸ To account for overhead, a multiplier of 17 percent was applied.⁹ The total salary with fringe and overhead is $27 (rounded to the nearest dollar).

• Drug and Alcohol Testing (§§ 120.5, 120.15)

Operations control specialists would be subject to certificate holders' drug and alcohol testing programs. 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 the records would be negligible.

• Radio altimeters for rotorcraft operations (§135.160)

This section will only require a collection of information from certificate holders that request a deviation under its provisions. Under the previous collection 107 deviations were granted to operators. We do not have any active requests for deviation and currently everyone is in compliance with the rule. However in the future, it is possible that an eligible rotorcraft operator will apply for the deviation. We estimate that we may receive 1 deviation request per year that we must process for approval or rejection. The total yearly cost for this requirement is 1 hour and $63.

Radio Altimeters

Application for On Demand Helicopters	Time for Deviation	Total Hours	Wage for Chief Pilot	Total Cost
1	1 hr	1	$63	$63

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1
# of Responses per respondent	1
Time per Response	1.0 Hour
Total # of responses	1
Total burden (hours)	1

• VFR ceiling and visibility requirements for class G airspace. (§135.609)

Each certificate holder may designate local flying areas (50 nautical miles in any direction from a designated location). Each certificate holder could designate more than one local flying area but no certificate holder is required to designate any local flying areas. A pilot employed by a certificate holder using local flying areas must pass an examination given by the certificate holder within the 12 calendar months prior to using the local flying area. This a one time collection that was captured in the last revision of this information collection. Today, there are 63 HAA operators who have complied with this requirement. This requirement would apply for a new entrant. Therefore, this calculation will be based on one new entrant per year.

Local Flying Area

Air Ambulance Operators	Hours to Develop Local Flying Area	Total Hours	Wage for Chief Pilot	Total Cost
1	2	2	$63	$126

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1
# of Responses per respondent	1
Time per Response	2.0 Hours
Total # of responses	1
Total burden (hours)	2

• VFR flight planning (§135.615)

This section requires the pilot in command to document the highest obstacle along the planned route of flight. Changes to the planned flight that occur while the helicopter is on the ground at an intermediate stop require evaluation of the new route. VFR flight planning procedures must be added to the certificate holder’s operations manual if not already there.

Each pilot would spend 5 minutes prior to each air ambulance operation and a change would occur 5% of the time taking another 5 minutes. We estimate 367 operations per helicopter per year. 95% of the operations will take 5 minutes and 5% will take 10 minutes.

VFR Flight Planning

Year	Helicopters	Operations Per Year	Hours of Flight Planning	Total Hours	Pilot Wage	Cost
1	1,230	324	0.08	31,881	$50	$1,594,050
2	1,230	324	0.08	31,881	$50	$1,594,050
3	1,230	324	0.08	31,881	$50	$1,594,050
TOTAL				95,643		$4,782,150

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1,230
# of Responses per respondent	324
Time per Response	0.08 Hour
Total # of responses	398,520
Total burden (hours)	31,881 Hours

• Pre-flight risk analysis (§135.617)

This section requires each certificate holder performing helicopter air ambulance operations to implement an FAA-approved pre-flight risk-analysis program documented in its existing operations manual. This section lists the areas that must be covered in the manual. The certificate holder must develop a pre-flight risk analysis worksheet that covers at least the same listed areas. The pilot in command must complete the worksheet prior to the first leg of each helicopter air ambulance operation, sign it and specify the date and time it was completed. The certificate holder must retain each completed worksheet for at least 90 days. This a one-time collection that was captured in the last revision of this information collection. Today, there are 63 HAA operators who have complied with this requirement. This requirement would apply for a new entrant. Therefore, this calculation will be based on one new entrant per year. We estimate a chief pilot would take 30 hours to develop the program and to document it in the operations manual. A clerk would take 30 hours to edit, copy, and distribute the changes to the manual.

Develop Pre-flight Risk Analysis Program

Year	Air Ambulance Operator	Hours to Develop Risk Analysis	Hour-Chief Pilot	Hours-Clerical	Total Hours	Wage for Chief Pilot	Wage for Clerical	Total Cost
1	1	60	30	30	60	$50	$27	$2,310
2	1	60	30	30	60	$50	$27	$2,310
3	1	60	30	30	60	$50	$27	$2,310
TOTAL	3	180	90	90	180			$6,930

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1
# of Responses per respondent	1
Time per Response	60.0 Hours
Total # of responses	1
Total burden (hours)	60 Hours

The pilot would perform the risk analysis taking 10 minutes per operation. We estimate 324 helicopter operations per year.

Perform Risk Analysis

Year	Helicopters	Operations Per Year	Hours Per Risk Analysis	Total Hours	Wage for Pilot	Total Cost
1	1,230	324	0.17	67,748	$50	$3,387,420
2	1,230	324	0.17	67,748	$50	$3,387,420
3	1,230	324	0.17	67,748	$50	$3,387,420
TOTAL				203,244		$10,162,260

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		1,230
# of Responses per respondent		324
Time per Response		.17 Hours
Total # of responses		398,520
Total burden (hours)		67,748 Hours

• Operations control centers (135.619)

This section requires certificate holders authorized to conduct helicopter air ambulance operations, with 10 or more helicopter air ambulances, to have an operations control center staffed by operations control specialists (OCS). Those specialists would communicate with pilots, advise pilots of weather conditions, and provide flight-following services. They would also participate in the pre-flight risk analysis completed by the pilot in command (§135.617); acknowledging it and specifying the date and time it was completed, and that according to their professional judgment, the flight can be conducted safety. The certificate holder must have an FAA-approved OCS initial and recurrent (every 12 months) training program and conduct an FAA-approved knowledge and practical test. The certificate holder must retain a training record for each specialist for the duration of that individual’s employment and for 90 days thereafter. The certificate holder must document the duties and responsibilities of the OCS in their operations manual and the OCS training program in its training manual. The information would not likely already be contained in the existing manuals since this is a new position although some already voluntarily use employees with different titles but some similar duties. Compliance for this section was 2 years after the effective date of the final rule. This a one-time collection that was captured in the last revision of this information collection. Today, there are 63 HAA operators who have complied with this requirement. This requirement would apply for a new entrant. Therefore, this calculation will be based on one new entrant per year.

The OCS would take 5 minutes per operation to finish review of the pilot’s worksheet.

Pilot’s Worksheets

Year	Helicopters	Ops Per Year	Hours Per Pilot Worksheet	Total Hours	Wage for Pilot	Cost
1	1,230	324	0.08	31,881	$50	$1,594,080
2	1,230	324	0.08	31,881	$50	$1,594,080
3	1,230	324	0.08	31,881	$50	$1,594,080
TOTAL				95,643		$4,782,240

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		1,230
# of Responses per respondent		324
Time per Response		0.08 Hours
Total # of responses		398,520
Total burden (hours)		31,881 Hours

There are currently 13 operators with 10 or more air ambulance helicopters that have already complied with this requirement. There is currently one operator that is going through certification that needs to develop an OCS training/operations manual. It is estimated that no more than one operator would apply for certification per year. The chief pilot would take 60 hours to develop the OCS training/operations manual. The typist/clerical would need 30 hours to edit, make copies, and distribute the revisions to the manuals. We estimate 2 operators would only need to make a small amendment to their existing manuals because they have a similar program currently in place. For these operators, the chief pilot would take 1 hour to revise the manual and the clerk would need 1 hours to edit, make copies, and distribute the revisions to the manuals.

Develop OCS Training

Year	Operators Developing New Plan	Hours Chief Pilot	Hours Clerical	Total Hours	Wage for Chief Pilot	Wage for Clerical	Total Cost
1	1	60	30	90	$3,000	$810	$3,810
2	1	60	30	90	$3,000	$810	$3,810
3	1	60	30	90	$3,000	$810	$3,810
Total				270 Hours			$11,430

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1
# of Responses per respondent	1
Time per Response	90.0 Hour
Total # of responses	1
Total burden (hours)	90 Hours

Amendment to Existing Manual

Year	Operators Revising Manual	Hours Chief Pilot	Hours Clerical	Total Hours	Wage for Chief Pilot	Wage for Clerical	Total Cost
1	2	1	1	4	$100	$54	$154
2	2	1	1	4	$100	$54	$154
3	2	1	1	4	$100	$54	$154
Total				12 Hours			$462

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	2
# of Responses per respondent	1
Time per Response	2.0 Hours
Total # of responses	2
Total burden (hours)	4 Hours

Total cost for development/amendment of a manual is 282 hours and $11,892.

The OCS would require training every 12 months with a test at the end. A record of the training including the test must be retained. The clerk would maintain the training records of the OCS’s spending 5 minutes on each record documenting that training and the test was completed on a certain date.

Training Records for Operators without OCCs

Year	OCS	Hours Per OCS Record	Total Hours	Wage	Cost
1	130	0.08	10	$27	$270
2	130	0.08	10	$27	$270
3	130	0.08	10	$27	$270
Total			30 Hours		$810

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		130
# of Responses per respondent		1
Time per Response		0.08 Hours
Total # of responses		130
Total burden (hours)		10 Hours

Certificate holders with operations control centers are required to retain operations control specialist training records.

Training Records for Operators with OCCs

Year	OCS	Hours per OCS Record	Total Hours	Wage	Cost
1	400	0.08	32	$27	$864
2	400	0.08	32	$27	$864
3	400	0.08	32	$27	$864
Total			96 Hours		$2,592

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		400
# of Responses per respondent		1
Time per Response		0.08 Hours
Total # of responses		400
Total burden (hours)		32 Hours

• Training of medical personnel (§135.621)

This section indicates that medical personnel may either be trained each 24 calendar months or receive a briefing prior to each air ambulance operation. The certificate holder would retain a record of each medical personnel trained for 24 calendar months. The certificate holder conducting helicopter air ambulance operations would need to add training of medical personnel to the existing training manual. Medical personnel may or may not be employees of the certificate holder. If they are not an employee they are still trained by the certificate holder. We estimate that 50% of certificate holders will develop and conduct training and 50% will brief medical personnel prior to each operation. For development of a training program, this was a one-time collection that was captured in the last revision of this information collection. Today, there are 63 HAA operators who have complied with this requirement. This requirement would apply for a new entrant. Therefore, this calculation will be based on one new entrant per year. We estimate 10 hours by the chief pilot to develop the training and 10 hours by the clerk to edit, make copies, and distribute the training. After training is conducted, the clerk will spend 5 minutes per training record documenting the date training was completed. Development of the training is a one-time event. The training records must be updated every 24 calendar months.

Develop Medical Personnel Training

Year	Air Ambulance Operators	Hours for CP to Develop Training	Wage for Chief Pilot	Hours for Clerical to Develop Training	Wage for Clerical	Total Hours	Total Cost
1	1	10	$50	10	$27	20	$770
2	1	10	$50	10	$27	20	$770
3	1	10	$50	10	$27	20	$770
Total						60	$2,310

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	1
# of Responses per respondent	1
Time per Response	20.0 Hours
Total # of responses	1
Total burden (hours)	20.0 Hours

Recordkeeping for Medical Personnel Training

Year	Training Data to be Maintained	Hours for Data Input	Wage for Clerical	Total Hours	Total Cost
1	5,858	0.08	$27	469	$12,663
2	No Data	Input due to	24 Month	Requirement
3	5,858	0.08	$27	469	$12,663
Total				938	$25,326

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents		5,858
# of Responses per respondent		1
Time per Response		0.08 Hours
Total # of responses		5,858
Total burden (hours)		469 Hours

• Requirements of FAA Reauthorization Bill of 2018 – Report to Congress.

Congress is mandating that operators complete a Helicopter Air Ambulance Data Report that will be submitted to congress on an annual basis. Operators have estimated that it may take between 2 and 24 hours (depending on their fleet size) to complete the reporting to the FAA so the information can be given to Congress. This reporting will be completed and submitted electronically. For the purposes of this report, an average of 7 hours will be used for each operator to complete the report. The salary will be based on the clerical wage rate sourced above.

Year	Number of HAA Operators	Hours for Data Input	Wage for Clerical	Total Hours	Total Cost
1	63	7	$27	441	$11,907
2	63	7	$27	441	$11,907
3	63	7	$27	441	$11,907
TOTAL				1,323	$35,721

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	63
# of Responses per respondent	1
Time per Response	7 Hours
Total # of responses	63
Total burden (hours)	441 Hours

Summary of all Burden Hours and Costs

		Section	Total Annual Burden Hours	Total Annual Cost
1	Radio Altimeters	135.160	1	$63
2	Local Flying Area	135.609	2	$126
3	VFR Flight Planning	135.615	31,881	$1,594,080
4	Develop Pre-flight Risk Analysis Program	135.617	60	$2,310
5	Perform Risk Analysis	135.617	67,748	$3,387,420
6	Pilots Worksheet	135.617	31,881	$1,594,080
7	Develop OCS Training/Amendment to Existing Manual	135.619	94	$3,964
8	Training Records for Operators without OCCs	135.619	10	$270
9	Training Records for Operators with OCCs	135.619	32	$864
10	Develop Medical Personnel Training	135.621	20	$770
11	Recordkeeping for Medical Personnel Training	135.621	469	$12,663
12	Reauthorization 2018 Congressional Report Requirement		441	$11,907
	Total Cost of this Information Collection		132,639 Hours	$6,608,517

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

There are no additional costs not already included in #12 above.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

This figure is the estimated cost for the government to approve and monitor FOQA programs. Typically inspectors at the GS-13 level would inspect and approve these programs. Generally, these inspectors are GS-13 (GS-13, Step 5 hourly wage, Kansas City Locality Pay) for an average wage of $47.66 per hour¹⁰ with 31.4%¹¹ fringe benefits cost for a total of $62.76 per hour. With overhead added¹², the total salary is 70.86 per hour.

Radio Altimeters

Application for On Demand Helicopters	Application for Air Tour Operators	Time for Review of Ops Specs	Total Hours	Wage for Inspector at HQ	Total Cost
1	1	1 hr	2	$71	$142

A certificate holder would designate a local flying area and send their request to the FAA field office. An FAA inspector would review and send the certificate holder approval or edits. We estimate one hour of FAA review at the above GS-13 pay rate.

Local Flying Area

Air Ambulance Operators	Hours to Review Request	Total Hours	Wage for Inspector	Total Cost
1	1	1	$71	$71

Each certificate holder would develop a revision to their existing operations manual on how they will perform pre-flight risk analysis. The revision would be sent to the FAA district office for review. An FAA inspector would review.

Review Pre-flight Risk Analysis Program

Year	Air Ambulance Operator	Hours to Review	Total Hours	Wage for Inspector	Total Cost
1	1	1	1	$71	$71
2	1	1	1	$71	$71
3	1	1	1	$71	$71
TOTAL		3			$213

Each impacted certificate holder would develop/revise their training manual and send it to the FAA field office.

Review New OCS Training

Year	Operators Developing New Plan	Hours for Review	Total Hours	Wage for Inspector	Total Cost
1	1	1	1	$71	$71
2	1	1	1	$71	$71
3	1	1	1	$71	$71
Total			3 Hours		$213

Review Amendment to Existing Manual

Year	Operators Revising Manual	Hours for Review	Total Hours	Wage for Inspector	Total Cost
1	2	1	2	$71	$142
2	2	1	2	$71	$142
3	2	1	2	$71	$142
Total			6 Hours		$426

Each certificate holder would develop a revision to their existing training manual for medical personnel and submit it to the FAA field office where an inspector would review it.

Review Medical Personnel Training

Year	Air Ambulance Operators	Hours for Review	Wage for Inspector	Total Hours	Total Cost
1	1	1	$71	1	$71
2	1	1	$71	1	$71
3	1	1	$71	1	$71
Total				3 Hours	$213

Summary of all annual Burden Hours and Costs

		Section	Total Burden Hours	Total Cost
1	Radio Altimeters	135.160	2	$142
2	Local Flying Area	135.609	1	$71
3	Review Pre-Flight Analysis	135.617	1	$71
4	Review OCS Training/Amendment to Existing Manual	135.619	3	$213
5	Review Development of Medical Personal Training	135.621	1	$71
	Total		8 Hours	$568

15. Explain the reasons for any program changes or adjustments.

The burden has been updated and revised. For many of the rules, they were one time requirements. Each existing operator has already complied with the requirements. Therefore the burden now reflects new entrants only.

Existing form 2170-0761 has been revised due to requirements of the FAA Reauthorization Act of 2018. This information collection is including the revised form. Section 314(d) of the FAA Reauthorization Act of 2018 amended these reporting requirements for the report to contain the number of helicopters that the certificate holder uses to provide helicopter air ambulance services and the base locations of the helicopters, the number of hours flown by the helicopters operated by the certificate holder, the number of patients transported and the number of patient transport requests for a helicopter providing air ambulance services that were accepted or declined by the certificate holder and the type of each such flight request (such as scene response, inter-facility transport or organ transport), the number of accidents, if any, involving helicopters operated by the certificate holder while providing air ambulance services and a description of the accidents, the number of hours flown under instrument flight rules by helicopters operated by the certificate holder, the number of hours flown at night by helicopters operated by the certificate holder, the number of incidents, if any, in which a helicopter was not directly dispatched and arrived to transport patients but was not utilized for patient transport.

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. 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 publication plan.

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

The FAA is not seeking approval to not display the expiration date.

18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions in Item 19, OMB Form 83-I.

1 https://www.payscale.com/research/US/Job=Chief_Helicopter_Pilot/Salary

2 https://www.bls.gov/news.release/ecec.nr0.htm

3 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.

4 https://www.payscale.com/research/US/Job=Helicopter_Pilot/Salary

5 https://www.bls.gov/news.release/ecec.nr0.htm

6 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002) ), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.

7 https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2018/general-schedule/

8 https://www.bls.gov/news.release/ecec.nr0.htm

9 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.

10 https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/GS_h.pdf

11 Bureau of Labor Statistics, Employer Costs for Employee Compensation – September 2018, USDL-18-1941, Released December 14, 2018

12 Source: Cody Rice, U.S. Environmental Protection Agency, “Wage Rates for Economic Analyses of the Toxics Release Inventory Program” (June 10, 2002), https://www.regulations.gov/document?D=EPA-HQ-OPPT-2014-0650-0005.