Supporting Statement 2120-0761 2024 Final

Department of Transportation

Federal Aviation Administration (FAA)

Supporting Statement A

Helicopter Air Ambulance Operator Reports

OMB Control Number 2120-0761

• The number of small and large operators was adjusted to 2023 levels.

• The wage rates for both Administrative Assistants and Aviation Safety Inspectors in questions 12 and 14 were updated.

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

The FAA Modernization and Reform Act of 2012 (the Act), as amended by the FAA Reauthorization Act of 2018, mandates that all helicopter air ambulance operators must begin reporting the number of flights and hours flown, along with other specified information, during which helicopters operated by the certificate holder were providing helicopter air ambulance services. See PL 112-95, Sec. 306, 49 USC § 44731 and PL 115-254, Section 314. The FAA Administrator had 180 days to develop a methodology to collect and store those data. The Act further mandates that not later than 2 years after the date of enactment, and annually thereafter, the Administrator shall submit to the Committee on Transportation and Infrastructure of the House of Representatives and the Committee on Commerce, Science, and Transportation of the Senate, a report containing a summary of the data collected.

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 helicopter air ambulance operational data provided to the FAA is used by the agency as background information useful in the development of risk mitigation strategies to reduce the helicopter air ambulance accident rate, and to meet the mandates set by Congress. All helicopter air ambulance operators must report data to the FAA.

The FAA collects 10 pieces of data from helicopter air ambulance operators which are mandated in the report to congress. We collect data on the following: number of helicopters, helicopter base locations, number of hours the helicopters are flown, number of patients transported, number of transportation requests accepted or denied, number of accidents, number of instrument flight hours flown, number of night flight hours flown, number of incidents in which a helicopter was not directly dispatched and arrived to transport patients but was not utilized for patient transport, and the number of accidents that occurred while conducting helicopter air ambulance operations. The information is collected annually.

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.

In accordance with the Government Paperwork Elimination Act (GPEA), the FAA allows and accepts electronic submission, and encourages the use of automation and electronic media for the gathering, storage, presentation, review, and transmission of these reports with the provision that such automation or electronic media has adequate provision for security (i.e., that such submissions may not be altered after review and acceptance by the FAA) and that the systems or applications are compatible with the systems or applications used by the FAA.

Helicopter air ambulance operators are able to download a Microsoft Excel spreadsheet-reporting template with blank fields in which they can populate their information/data. The link to the spreadsheet is available here: https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afx/afs/afs200/afs220/135_flt_ops Upon completing their report, they will be able to submit it via an FAA email mailbox set up for that purpose. The information collected will not be shared with the public.

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.

Of the fourteen items of data required by the Act, the FAA can access two – the number of helicopters used to provide air ambulance services and the number of helicopter air ambulance accidents. Since these items are more readily available to the operator, we have included them in this information collection.

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

The information requested is limited to the minimum necessary to fulfill these reporting requirements mandated by the Act and as developed by FAA. The amount of data required to be submitted is proportional to the size of the operation.

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 FAA initially requested that helicopter air ambulance operators submit reports quarterly. Based on the comments submitted, the FAA revised the reporting requirements to only request annual submissions, which are in accordance with the Congressional language requiring this data to be reported. If the data is not collected, then the FAA will not be able to comply with the congressional mandate to supply helicopter data to Congress.

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.

This collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2)(i)-(viii).

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 May 1, 2024 (89 FR 35299) followed by, in parentheses, the Federal Register citation, e.g. 73 FR 12345, solicited public comment. No comments were received.

Helicopter Air Ambulance operators have opportunities to meet with their assigned FAA offices and inspectors to offer feedback and comments.

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

No payment or gift to respondents will be made.

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

The Act requires the FAA to include a “method to protect the confidentiality of any trade secret or proprietary information” when collecting and storing the data. See 49 U.S.C. § 44731(c).

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 statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices. * If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included under item 13.
  
  
  

Nationwide, there are 65 authorized helicopter air ambulance certificate holders utilizing 1,309 approved air ambulance helicopters. This number fluctuates constantly because of mergers, acquisitions, industry growth, and operators ceasing operations. Certificate holders are required to report their air ambulance-related information on an annual basis. The annual hour burden will vary greatly between the operators based on the number of authorized helicopters operated by each. The actual number of flights each operator conducts per year per authorized helicopter is currently unknown. The FAA does collect data on the number of flight request accepted or declined and the actual number of patients flown. In 2023, the number of accepted requests was 418,669 which includes scene, inter-facility, and donor organ transport. The total number of patients flown was 385,366.

• Authorized helicopter air ambulance certificate holders who operate 10 or more air ambulance helicopters are required by regulation to have Operations Control Centers (OCC). For the purposes of this analysis, operators falling into this category are defined as “large.” Although the number fluctuates, currently twelve (12) certificate holders fall into this category, and operate 1,126 air ambulance helicopters in the aggregate, or 86% of the fleet. The balance of the certificate holders (53) each operate fewer than ten helicopters and are defined here as “small.” Small certificate holders operate 183 helicopters in the aggregate.

• Certificate holders will input their data in a Microsoft Excel spreadsheet template, which requires some general information that the operator must input regarding the company (e.g., name of company, FAA certificate number). The additional information will be limited to that required by the Act.

• The FAA estimates that it will take each small operator (those operating fewer than 10 helicopters), approximately 9 hours on average to fill out and submit the required annual report which has not changed since the last submission. Our burden estimate for large operators (those operating 10 or more helicopters) did not scale linearly. These large operators are required to have OCCs. Due to the high volume of activity of these large operators, nothing other than electronic means of data recording and dispatching would be practical for compliance with this mandate. We believe that those operators that employ electronic flight authorization databases should be able to largely automate exporting the required data into an Excel-readable format (i.e., comma or space-delimited text files). Therefore, for each large certificate holder that conducts a large number of operations, we estimate that it will take on average, approximately 24 hours to fill out and submit each annual report.

• There are 53 “small” operators and 12 “large” operators as defined previously. Thus it will take 53 x 9 = 477 hours per year for “small” operator labor burden and 12 x 24 = 288 hours per year for “large” operator labor burden. The aggregate hourly burden total would be 765 labor hours per year for all respondents.

• Using the automated “export” and “import” features in Excel is a relatively simple task and can be performed by an administrative assistant. The assumed hourly labor rate for a clerk/secretary is $22.12 / hour.¹ A 31.4 percent multiplier was then applied to account for fringe benefits which brings the salary to $29.07.² To account for overhead, a multiplier of 17 percent was applied.³ Therefore, the estimated hourly salary for an administrative assistant is $34. The average annual burden to an individual small operator (as defined in this context) would be $306 (9 hours X $34), and for an individual large operator, $816 (24 hours X $34). The total aggregate annualized burden to all respondents is estimated to be approximately $26,010 (765 hours X $34).

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	53
# of Responses per respondent	1
Time per Response	9 hours
Total # of responses	53
Total burden (hours)	477 hours
Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	12
# of Responses per respondent	1
Time per Response	24 hours
Total # of responses	12
Total burden (hours)	288 hours

The first chart is small operators and the second chart is large operators

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

There are no costs associated with this collection that have not already been identified in the responses to questions 12 and 14.

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.

• Helicopter air ambulance operators will electronically submit this information directly to FAA. Agency costs will include a review of each operator’s annual submittal to ensure every operator has submitted the proper report, and to ensure the data are properly reported. We anticipate that it will take the agency approximately 40 hours each year to review all the reports that are submitted by the helicopter air ambulance operators. The review would likely be conducted by a GS-14 level employee. An Aviation Safety Inspector or Policy Analyst would review this information. Since many of these employees are remotely sited, the Kansas City locality rates were applied as it is a median locality rate. The cost to the federal government for a Kansas City, MO based employee at a grade 14, step 5 level is $67.40 / hour.⁴ A 31.4 percent multiplier was then applied to account for fringe benefits which brings the salary to $88.56.⁵ To account for overhead, a multiplier of 17 percent was applied.⁶ The total salary including overhead and fringe benefits is $103.62. Therefore, the cost for reviewing reports is estimated to be $4,145. It is estimated that an additional 40 hours for end-of-reporting-year collation and report generation will also be needed. This final report assembly is also likely to be conducted by a GS-14 (step 5) level employee for a cost to the government of $4,145, bringing the overall estimated aggregate cost to the federal government of $8,290.

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

The number of small and large operators was adjusted to 2023 levels.

The wage rates for both Administrative Assistants and Aviation Safety Inspectors in questions 12 and 14 were updated.

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.

No publication of the comprehensive data set is anticipated; it is primarily for internal use and tracking and for reporting to Congress as stipulated in the statute. Some of the operational information collected (such as number of operations, locations, and aircraft makes and models) may be included as generalized background information to document baseline conditions in helicopter air ambulance operations to develop methodologies for mitigating risk in such operations and to meet the congressional mandate.

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.

Approval is not being requested.

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

There are no exceptions requested.

1 Secretaries and Administrative Assistants : Occupational Outlook Handbook: : U.S. Bureau of Labor Statistics (bls.gov)

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 SALARY TABLE 2024-KC (opm.gov)

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.