2120-0775 20240604 v3

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Operation of Small Unmanned Aircraft Systems over People

OMB: 2120-0775

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Department of Transportation

Federal Aviation Administration



SUPPORTING STATEMENT

Operation of Small Unmanned Aircraft Systems over People

SUMMARY OF CHANGES IN THIS SUBMISSION:


This submission includes adjusted estimates of burden hours for information requested and estimates of cost to the federal government based on 2024 labor rates and comments received from the 60-day Federal Register Notice. In addition, the estimated number of responses is lower than in the previous submission, as these figures are based on real-world data rather than on estimates.

INTRODUCTION


The Federal Aviation Administration (FAA) submits this Supporting Statement to the Office of Management and Budget (OMB) in support of an existing information collection request (ICR). The FAA requests this information collection approval include information an applicant or manufacturer submits to receive acceptance from the FAA for a means of compliance or a declaration of compliance, both of which are critical to ensuring small unmanned aircraft systems (small UAS) are constructed to fulfill the performance-based requirements of the FAA’s regulations. The FAA also requests this information collection approval include development of remote pilot operating instructions and recordkeeping to reflect compliance with maintenance requirements for small UAS with an airworthiness certificate. In addition, this supporting statement includes the items that a manufacturer the holder of a declaration of compliance must include or display with a small UAS that is eligible to operate over people; these include the label on the small unmanned aircraft and remote pilot operating instructions.


Part A. Justification:


1. Circumstances that make the collection of information necessary.

On January 15, 2021, the FAA published the Operation of Small Unmanned Aircraft Systems over People final rule (86 FR 4314, January 15, 2021). This final rule updated the requirements under 14 Code of Federal Regulations part 107 to permit operations of small UAS over people under certain circumstances, which had previously been prohibited. The regulations finalized in this rule expanded the ability to conduct operations over people, provided that the operation meets the requirements of one of four operational categories. This rule established subpart D to part 107, which sets forth the aircraft eligibility and operating requirements for the four categories of operations over people. The first three categories of operations over people are based on the risk of injury they present to people on the ground, while the fourth category permits operations over people if the small unmanned aircraft has an airworthiness certificate. To ensure compliance with certain requirements, the FAA must review information from applicants whose intention is to receive a determination from the FAA that the small UAS is eligible to operate over people. Without engaging in such information collections, the FAA would be unable to ensure compliance with the proposed performance-based requirements.

The information the FAA reviews under Part 107, subpart D includes applications requesting acceptance of means of compliance, as well as applications for acceptance of declarations of compliance that use an FAA-accepted means of compliance. These information collection requirements apply only to small UAS that a person seeks to operate in accordance with Category 2 or Category 3 of subpart D of part 107.1 For these categories, the regulations require that declarations of compliance include certain types of specific information. The FAA will only require the minimum amount of information necessary to ensure the FAA could identify an applicant and evaluate the small UAS on which the declaration of compliance is based. And while no mandatory information collections (reporting or disclosure) occur under Category 4 operations, it is important to note that Category 4 does impose record keeping requirements on the owner of the aircraft, and those records must be provided to the FAA or NTSB upon request. These record requests would typically be performed as part of the investigation process for any applicable accidents or incidents involving the small UAS. The owner or operator may keep these records electronically or by paper.

In addition to requesting acceptance of declarations of compliance, holders of an FAA-accepted declaration of compliance for small UAS that are eligible for operations over people are required to label the small unmanned aircraft with the appropriate category in which the small UAS is eligible to operate. Such labeling ensures the remote pilot in command who seeks to operate over people is informed of the category of operation in which the small unmanned aircraft is eligible to operate, in addition to the requirement for the remote pilot in command to ensure the small unmanned aircraft is listed on an FAA-accepted declaration of compliance. The regulations also require holders of an FAA-accepted declaration of compliance to accompany each small UAS eligible to operate over people with remote pilot in command operating instructions. These instructions ensure the remote pilot in command is aware of conditions that may render the small UAS ineligible to operate over people; for example, when the FAA’s acceptance of a declaration of compliance is contingent upon restricting certain types of payloads, the operating instructions would list such contingencies. Labeling, remote pilot operating instructions, and an FAA-accepted declaration of compliance ensure compliance with the performance-based requirements of Part 107.

Furthermore, operators and owners of small UAS issued an airworthiness certificate under Part 21 must retain records of all maintenance performed on their aircraft and records documenting the status of life-limited parts, compliance with airworthiness directives, and inspection status of the aircraft. The records must be kept for the time specified in § 107.140, and they must be available to the FAA and law enforcement personnel upon request. These records are used to validate the aircraft has been maintained in a manner that ensures the reliability associated with having an airworthiness certificate continues to be valid and that the operations over people privileges afforded to category 4 operations continue to be appropriate. The owner or operator may keep these records electronically or by paper.


2. How, by whom, how frequently, and for what purpose the information is to be used.


These regulations require applicants who seek FAA acceptance of means of compliance and declarations of compliance to submit applications. In addition, holders of a declaration of compliance for small UAS in Categories 2 and 3 are required to label all small unmanned aircraft eligible to operate over people. Lastly, for small UAS in Categories 2 and 3, applicants who obtain an FAA-acceptance declaration of compliance are required to make available, upon sale, transfer, or use by another person, remote pilot operating instructions that describe the small UAS and the declared category or categories of eligibility, describe permissible modifications that would not change the ability of the small UAS to meet the requirements for the applicable category or categories; and, if applicable, instruct operators on how to verify and change the mode or configuration of the small UAS. Lastly, owners and operators of small UAS with an airworthiness certificate under Part 21 are required to retain records of all maintenance performed on their aircraft and records documenting the status of life-limited parts, compliance with airworthiness directives, and inspection status of the aircraft.



  1. Declaration of Compliance and Means of Compliance


The FAA collects this information to determine whether an applicant’s submission of the declaration of compliance establishes the small UAS would be eligible for operations under either Category 2 or Category 3 of subpart D of part 107. This information collection renewal also includes record retention requirements applicable to manufacturers upon the FAA’s acceptance of a declaration of compliance for a small UAS.

Declarations of Compliance

The Declaration of Compliance would be required to include the following information:

(1) Applicant’s name;

(2) Applicant’s physical address;

(3) Applicant’s email address;

(4) The small unmanned aircraft system make and model name, and series, if applicable;

(5) The small unmanned aircraft system serial number or range of serial numbers that are the subject of the Declaration of Compliance;

(6) Whether the Declaration of Compliance is an initial declaration or an amended declaration;

(7) If the Declaration of Compliance is an amended declaration, the reason for the re-submittal;

(8) A declaration that the applicant:

(i) Has demonstrated that the small unmanned aircraft, or specific configurations of that aircraft, satisfies § 107.120(a)(1) and § 107.120(a)(2), or § 107.130(a)(1) and §107.130(a)(2) or both, through an accepted means of compliance;

(ii) Has verified that the unmanned aircraft system does not contain any safety defects identified by the Administrator.

(iii) Has satisfied § 107.120(d) or § 107.130 (d), or both; and

(iv) Will, upon request, allow the Administrator to inspect its facilities, technical data, and any manufactured small unmanned aircraft system and witness any tests necessary to determine compliance with this subpart; and

(9) Other information as required by the Administrator.

The holder of an FAA-accepted declaration of compliance must keep the detailed description of the means of compliance, including any substantiating material, until the later of either two years after the cessation of production of the small unmanned aircraft system(s) or the submission of the declaration of compliance. In addition, the person who holds the declaration of compliance must retain any accompanying data containing detailed information on the type of means of compliance on which the declaration of compliance is based, and the results or justification used to demonstrate the small UAS meets the applicable performance-based requirements to establish eligibility.

Means of Compliance

Each declaration of compliance must identify the FAA-accepted means of compliance the applicant has used. Any person may apply to the FAA for acceptance of a means of compliance. Such applications must include a detailed description of the means of compliance and justification, including any substantiating material, showing the means of compliance establishes achievement of the safety requirements identified for small UAS eligibility pursuant to Category 2 or Category 3. The means of compliance must demonstrate the achievement of the safety requirements through test, analysis, or inspection that the small UAS is eligible for operations pursuant to Category 2 and/or Category 3.

All FAA-accepted means of compliance used to satisfy the performance-based requirements for eligibility must be kept for as long as the means of compliance is accepted by the FAA. If the means of compliance involved testing, the accompanying data or information must describe the test, analysis, or inspection procedures that outline the test methodology, as well as justification showing the means of compliance establishes achievement of the safety requirements identified in the performance-based requirements.

The FAA will use the applicant’s declaration of compliance and means of compliance to determine whether to accept the declaration or means of compliance. This review of information to decide acceptability is a critical component of the final rule, as it is the mechanism for FAA oversight to ensure compliance with the standards.

These regulations apply to any person who seeks acceptance of a means of compliance. It also applies to any person who seeks acceptance of a declaration of compliance. While many applicants who seek acceptance of means of compliance may also seek to produce the small UAS and submit a declaration of compliance, these regulations permit an applicant who seeks acceptance of a means of compliance to be distinct from the applicant who seeks acceptance of a declaration of compliance.

  1. Labeling

Given that a small UAS could be qualified to conduct more than one category of operations, these regulations require an applicant to label the small UAS to indicate each category of operation the small UAS is qualified to conduct. For example, a small UAS qualified to conduct Category 2 operations may also be qualified to conduct Category 3 operations. The holder of a declaration of compliance would label such a small UAS with each category, as follows: “Cat. 2, 3” or “Category 2, 3”. The label could be painted onto, etched into, or affixed to the aircraft by some other permanent means.

The labeling requirement will assist the remote pilot to know which category of operation their small UAS is eligible to conduct, and accordingly, provide awareness of any technical and operational limitations that apply to the operations. The labeling requirement also assists the FAA in its oversight role because it provides an efficient means for an inspector to evaluate whether an operation is consistent with the category or categories of operation the small UAS may conduct. Additionally, the labeling requirement assists law enforcement agencies to determine whether an operation is consistent with the safety requirements of the regulation. Because Category 3 operations entail unique operating limitations, the label on small unmanned aircraft eligible to conduct Category 3 operations indicates to the remote pilot that he or she must adhere to the applicable operating limitations.2 If a Category 2 or 3 label affixed to a small unmanned aircraft is damaged or destroyed such that it is no longer legible, a remote pilot in command must relabel the aircraft in English such that the label is legible, prominent, and will remain on the small unmanned aircraft for the duration of the operation before conducting operations over human beings. The label must correctly identify the category or categories of operation over human beings that the small unmanned aircraft is qualified to conduct in accordance with this subpart.


  1. Remote Pilot Operating Instructions

The information collection also includes information dissemination in the form of remote pilot operating instructions for small UAS that are eligible to operate over people. As noted above, the remote pilot operating instructions must address, at a minimum:

  • A system description that includes the required small UAS components, any system limitations, and the declared category or categories of operation;

  • Modifications that will not change the ability of the small UAS to meet the requirements for the category or categories of operation the small UAS is eligible to conduct, and

  • Instructions for how to verify and change the mode or configuration of the small UAS, if they are variable.

These regulations require the provision of these remote pilot operating instructions at the time of sale, transfer, or use of the aircraft by someone other than the applicant who submitted a declaration of compliance. In addition, subpart D of part 107 requires the holder of an FAA-accepted declaration of compliance ensure instructions remain up to date to account for any changes the holder of the FAA-accepted declaration of compliance might make to the small UAS. Thes regulations do not require the holder of an FAA-accepted declaration of compliance to provide remote pilot operating instructions in a particular format. Holders of an FAA-accepted declaration of compliance may include the operating instructions as part of the packaging of the small UAS, make them available electronically, or provide them in some other manner.


  1. Product Support and Notification Process


Part 107 requires the holder of an FAA-accepted declaration of compliance for a small UAS to establish and maintain a product support and notification process to notify the public and the FAA of any defect or condition that would affect the eligibility of the small UAS to operate over people.


  1. Maintenance Records for Category 4


Records documenting maintenance performed must be retained for 1 year from when the work is performed or until the maintenance is repeated or superseded by other work. Records documenting the status of life-limited parts, compliance with airworthiness directives, and inspection status of the aircraft, must be retained and transferred with the aircraft upon change in ownership. These records are used to validate the aircraft has been maintained in a manner that ensures the reliability associated with having an airworthiness certificate continues to be valid and that the operations over people privileges afforded to Category 4 operations continue to be appropriate. The owner or operator may keep these records electronically or by paper.


3. Extent of automated information collection.

The FAA requires an applicant who seeks acceptance of a declaration of compliance to submit their DOC to an FAA website, https://uasdoc.faa.gov, the portal developed for the purpose of submitting and accepting applicant DOCs. Paper-based fillable forms will not be accepted, and declarations of compliance will not be accepted via email. The FAA reviews declarations of compliance to ensure the applicant has satisfied the eligibility and safety requirements in accordance with the part 107 rule using an FAA-accepted means of compliance. The FAA’s review of a means of compliance will not lend itself to an automated review process, because each means of compliance will likely be based on unique, commercially valuable information.

The requirements for labeling and providing remote pilot operating instructions consist of requirements regarding display of information and recordkeeping, rather than submission of information. As a result, the opportunity for automated collection does not exist for such information.

Maintenance records required to be kept by the owner or operator used to validate the aircraft has been maintained in a manner that ensures the reliability associated with having an airworthiness certificate continues to be valid and that the operations over people privileges afforded to Category 4 operations continue to be appropriate, are not part of this automated system.



4. Efforts to identify duplication.


FAA has carefully analyzed existing information collection activities to ensure the collection of information does not duplicate any other information collection in which the agency engages. FAA does not presently collect information from small UAS manufacturers for complying with any other rule regarding operations of small UAS over people. As a result, the information collection does not entail any duplicative information collection requirements.


5. Efforts to minimize the burden on small businesses.


The information collection involves only the information that is necessary to ensure compliance with performance-based requirements and the FAA believes it does not create a significant burden on small businesses.


6. Impact of less frequent collection of information.


The information collection does not affect any Federal program or policy activities.


7. Special circumstances.


No special circumstances cause the FAA to conduct the information collection in a manner inconsistent with the Office of Management and Budget guidance on Paperwork Reduction Act compliance.


8. Compliance with 5 CFR 1320.8.


The FAA sought comment in a 60-day Federal Register notice published on April 2, 2024 (89 FR 22764). One comment was received from the Small UAV Coalition.

The Small UAV Coalition commented that the burden estimate for retaining maintenance records for UAS operating under Category 4 should use an estimated hourly burden of 1 to 2 hours per aircraft, as opposed to the 0.5 hours per aircraft estimated by the FAA.

The FAA notes that this recordkeeping requirement only involves the documentation of maintenance and the status of life-limited parts. The documentation includes a description of the work performed, the date the work was completed, and the name of the person who performed the work.

The FAA believes most Category 4 operators will keep this information electronically, but accepts the commenters estimate of 1 hour per aircraft per year. The FAA has updated the burden estimate to reflect the new hourly burden estimate.

9. Payments or gifts to respondents.


No provision or payments or gifts to respondents in exchange for submitting the information will occur.


10. Assurance of confidentiality.


While no assurance of confidentiality to respondents occurs concerning the information respondents submit, the FAA exercises care in handling any information that a submitter designates as proprietary. The FAA posts notices of availability to indicate the FAA’s acceptance of means of compliance. In addition, the FAA posts declarations of compliance online, but does not include any Personal Identifiable Information (PII) from the submitter. When the information that accompanies an application seeking FAA acceptance consists of information that is commercially valuable, the FAA does not make such accompanying information available to the public.


11. Justification for collection of sensitive information.


The FAA would not request information of a sensitive nature from any respondent.




12. Estimate of burden hours for information requested.


Declaration of Compliance and Means of Compliance

These regulations under 14 CFR part 107, subpart D require the manufacturers of small UAS to submit a means of compliance and/or declaration of compliance to the FAA. The FAA estimates below are based on actual data collected since 2021 and estimated future growth. Between 2021 and 2024, the FAA accepted 3 MOCs and 9 DOCs for a total of 12 separate documents. However, the FAA believes that the number of submissions will increase gradually, and therefore provides the estimates below.

Table 1: Annual Hourly Burden for Means of Compliance

and Declaration of Compliance

Initial

Submissions

Resubmissions

Pages Per Submission

Average Hours Per Page

Total Hours

8

1

50

1

450

FAA estimates the number of responses to total 8 submissions and 1.0 resubmissions per annum, for an annual burden totaling 450 hours per year.



Remote Pilot Operating Instructions

These regulations require the holders of a declaration of compliance to provide remote pilot operating instructions (RPOI). For a simple small UAS with no approved modifications or alternate configurations, the RPOI could be as few as two pages. For a more complex small UAS, the RPOI could be up to 10 pages. Each page could take the manufacturer between 10 and 40 hours to draft.3 For this analysis, the FAA uses an average of six pages ([2 + 10] / 2 = 6) and an average of 25 hours per page ([10 + 40]) / 2 = 25).


Table 2: Annual Hourly Burden Estimates for Remote Pilot Operating Instructions

Operating Instructions

Pages

Hours Per Page

Hourly Burden

8

6

25

1,200

Row and column totals may not sum due to rounding.

The FAA estimates the number of responses to total 8 per year, for an hourly burden totaling 1,200 per annum.



Labeling of Small Unmanned Aircraft

These regulations require a holder of an FAA-accepted declaration of compliance to label the small UAS with each category of operations the small UAS is qualified to conduct. Some small UAS could be qualified to conduct more than one category of operation. For example, a small UAS qualified to conduct Category 2 operations may also be qualified to conduct Category 3 operations; in such a case, the label on the small unmanned aircraft would list both Category 2 and Category 3. The label could be painted onto, etched into, or affixed to the aircraft by some other permanent means. A manufacturer would likely redesign an existing label already affixed to the aircraft, and that the label redesign would take a maximum of two hours.



Table 3: Annual Burden Estimates for Labeling Unmanned Aircraft (Hours)

Number of Platforms

Hours Per Redesign

Hourly Burden

8

2

16

Row and column totals may not sum due to rounding.

FAA estimates the number of respondents to total 8 per year, for an annual burden totaling 16 hours per annum.



Maintenance Records

Owners of small UAS issued an airworthiness certificate under part 21 must retain records of all maintenance performed on their aircraft and records documenting the status of life-limited parts, compliance with airworthiness directives, and inspection status of the aircraft. The records must be kept for the time specified in §107.140, and they must be available to the FAA and law enforcement personnel upon request.

The FAA expects that 100 hundred small UAS that could also be eligible to conduct category 4 operations will be added to the fleet each year. It is estimated that on a per aircraft basis, 1.0 hours would be required per year for the purpose of documenting and retaining maintenance records.

Table 4: Annual Hourly Burden Estimates for Part 107 Maintenance Records

Number of Respondents

Affected

Small UAS

Hourly Burden

(1.0 per sUAS)

1

100

100


Declaration of Compliance and Means of Compliance

The annual cost burden for the applicants to complete the declaration of compliance equals the number pages per submission multiplied by the hours per page, multiplied by a fully burdened hourly wage of $91.924. The cost is approximately $41,364 per annum in 2024 dollars.



Table 5: Annual Burden and Cost for Means of Compliance

and Declaration of Compliance

Initial

Submissions

Resubmis-

sions

Pages Per Submission

Average Hours Per Page

Total Hours


Total Cost

8

1.0

50

1

450

$41,364

Row and column totals may not sum due to rounding


Remote Pilot Operating Instructions

For applicants to develop and maintain remote pilot operating instructions, a fully-burdened hourly wage of $91.925 is multiplied by the total hourly burden of 1,200 hours for total cost of approximately $110,304 per annum.

Table 6: Annual Burden Estimates for Remote Pilot Operating Instructions

Operating Instructions

Pages

Hours Per Page

Hourly Burden

Total Cost

8

6

25

1,200

$110,304

Row and column totals may not sum due to rounding.



Labeling of Unmanned Aircraft

A manufacturer would likely redesign a label already affixed to the aircraft, which would take a maximum of approximately two hours at a fully burdened hourly wage of $91.926 for an annual cost of $1,551 per annum.

Table 7: Annual Burden Estimates for Labeling Unmanned Aircraft (Hours)

Number of Platforms

Hours Per Redesign

Hourly Burden

Total

Cost

8

2

16

$1,551

Row and column totals may not sum due to rounding.


Maintenance Records

Maintenance record upkeep and documentation is performed by a Part 107 airman certificated remote pilot. The fully burdened hourly wage for a part 107 remote pilot is estimated to be $56.82.7 Multiplying an annual 100-hour burden by the fully burdened hourly wage of $56.82 yields a total cost of approximately $5,682 for the three year period.

Table 8: Annual Hourly Burden Estimates for Part 107 Maintenance Records

Number of Respondents

Affected

Small UAS

Hourly Burden

(1.0 hours/ sUAS)

Total Cost

($56.82/hour)

1

100

100

$5,682

Row and column totals may not sum due to rounding.





Total Economic and Time Burden

Table 9: TOTAL Annual Burdens

IC

Number of Submissions

Time Per Submission

Total Hours

Total

Cost

DOC/MOC (Reporting)

8

50

400

$38,067

Resubmission (Reporting)

1

50

50

$4,596

RPOI (Reporting)

8

150

1,200

$110,304

Labeling (Disclosure)

8

2

16

$1,551

Mx Records (Recordkeeping)

100

1.0

100

$5,682

Total

125

253

1,766

$160,200



Row and column totals may not sum due to rounding.


13. Estimate of total annual costs to respondents.


There are no additional start-up costs associated with this collection not already included in item number 12.


14. Estimate of cost to the Federal government.



The agency estimates the number of hours for the agency to review the declaration of compliance and means of compliance and notify an applicant as to whether the means of compliance or declaration of compliance has been accepted to be three hours. The hourly wage for a FAA subject matter expert to review the submission is a fully-burdened hourly wage of $111.76 per hour8 for an annual cost of $3,017.

Table 7: Annual Hourly Burden and Cost for FAA Review of Manufacturer Means of Compliance and Declaration of Compliance

Initial

Submissions

Resub-

missions

Average FAA Review Time (Hours)

Total Hours




Total Cost

8

1.0

3

27

$3,017

Row and column totals may not sum due to rounding.

The agency does not expect to incur any costs related to the labeling of the small unmanned aircraft eligible for operations over people or regarding the requirement for manufacturers to provide remote pilot operating instructions. Declarations of compliance request a statement in which manufacturers affirm the small UAS is subject to remote pilot operating instructions. The above estimate for reviewing declarations of compliance reflects the FAA’s review of this required statement.


15. Explanation of program changes or adjustments.


This submission includes adjusted estimates of burden hours for information requested and estimates of cost to the federal government based on 2024 labor rates. In addition, the estimated number of responses is lower than in the previous submission, as these figures are based on real-world data rather than on estimates. The FAA also updated the hourly burden associated with keeping maintenance records from 0.5 hours per year to 1.0 hours per year based on public comment.


16. Publication of results of data collection.


No requirement exists that will obligate FAA to publish for statistical use any information collected in accordance with this collection. The final rule, however, notifies the public of the FAA’s intent to post notices of availability indicating the FAA’s acceptance of means of compliance. The FAA also intends to post declarations of compliance online. However, the FAA does not intend to post the information on which these decisions of acceptance are based.


17. Approval for not displaying the expiration date of OMB approval.


FAA does not seek approval to refrain from displaying the expiration date of OMB approval of this proposed information collection.


18. Exceptions to certification statement.


FAA has not identified any exceptions in Item 19, OMB Form 83-I.

1 For Category 2 operations, the small unmanned aircraft must be designed, upon impact with a person, to not result in an injury equivalent to or more severe than the injury that would result from a transfer of 11 ft-lbs of kinetic energy from a rigid object. For Category 3 operations, the small unmanned aircraft must be designed, upon impact with a person, to not result in an injury equivalent to or more severe than the injury that would result from a transfer of 25 ft-lbs of kinetic energy from a rigid object. For both categories, the small unmanned aircraft used in the operation would be prohibited from having any exposed rotating parts that could lacerate human skin and from having safety defects.

2 The labeling requirement is not the sole means by which a remote pilot in command will be aware of the operating limitations applicable to Category 3 operations. Remote pilots in command must maintain awareness of updated regulations, as required by §§ 107.73(a) and 107.74(a).

3 The range in time of 10 to 40 hours is inclusive of all activities required to draft and review the remote pilot operating instructions.

4 Based on the Regulatory Evaluation for the final rule titled “Operation of Small Unmanned Aircraft Systems over People”, the FAA assumes a technical expert performing this level of work in the private sector would earn an amount equivalent to that of an FAA Technical Subject Matter Expert at “J” Pay Band hourly wage. The fully burdened wage is $91.92 (in 2024 dollars).

5 See footnote 4.

6 See footnote 4.

7 Average is based on information found at https://www.thedroneu.com/blog/drone-pilot-salary-how-to-make-money-with-a-drone/. Accessed 5/21/2024. This pay is assumed to account for 70.4 percent of compensation, leading to a loading factor of 1.42 (see BLS Employer Costs for Employee Compensation by ownership at https://www.bls.gov/news.release/ecec.t01.htm for details).

8 Based on the analysis in Regulatory Evaluation of proposed rule titled “Operation of Small Unmanned Aircraft Systems over People”, an FAA Technical Subject Matter Expert performing this review would earn an upper-bound “J” Pay Band hourly wage of $72.91 (in 2024 dollars).

11


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