Supporting Statement A V5

Supporting Statement A

Safety Statement Requirement for Manufacturers of Small Unmanned Aircraft

OMB 2120-0809

• There are no changes to this collection as the burden table provided below was written in a broad way to accommodate all the variables due to the fast pace of the Unmanned Aircraft Systems (UAS) industry, it is difficult to reliably estimate the number respondents as new manufacturers are frequently joining the UAS industry while existing manufacturers leave. Additionally, the FAA has developed an example safety statement that can be used to satisfy the requirement and reduce the burden to the manufacturer, however the manufacturer may elect to develop materials of their own.

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

Section 2203 of the FAA Extension, Safety, and Security Act of 2016 (P.L. 114-90) requires manufacturers of small unmanned aircraft to make available to the owner a safety statement that satisfies requirements detailed in that section.

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 requirement mandates manufacturers to provide safety information to the public for using small unmanned aircraft. This information must be provided when someone purchases a small unmanned aircraft and may be done as a packing insert or via electronic means. No additional information is anticipated to be disseminated to the public. The FAA will not be collecting information related to this requirement.

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.

Section 2203 does not prescribe how manufacturers must satisfy the requirement. It is up to the manufacturer to select their method of compliance, including website content, mobile applications, or other electronic means. Additionally, the FAA has developed an example safety statement that can be used to satisfy the requirement and reduce the burden to the manufacturer, however the manufacturer may elect to develop materials of their own.

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.

Currently no duplication.

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

In order to minimize the burden on small businesses, the FAA has developed an example safety statement that can be used to satisfy the requirement. Manufacturer's Toolkit | Federal Aviation Administration

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.

This is a Congressional requirement under Section 2203 of the FAA Extension, Safety, and Security Act of 2016 (P.L. 114-90). A person who violates subsection (a) shall be liable for each violation to the United States Government for a civil penalty described in section 46301(a) of title 49, United States Code.

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

There are no special circumstances that would require this collection to be conducted in a manner inconsistent with the points presented in 5 CFR section 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.

The Federal Register Notice was published on June 2, 2025 (90 FR 23415) with the solicitation for public comment.

One comment was received during the 60Day comment period. The commentor mentioned the lack of compliance from the manufacturers with the requirement through their experience. The commentor suggested the FAA start enforcing the requirement or end it but would want the FAA to enforce the requirement due to the lack of education for first time drone buyers that would learn from it.

The FAA is working on educating the manufacturers of the requirement.

The commentor did not leave contact information.

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

No payments or gifts were provided to respondents.

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

No assurance of confidentiality is 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.

No sensitive information is collected.

12. Provide estimates of the hour burden of the collection of information. The statement should:

Due to the fast pace of the UAS industry, it is difficult to reliably estimate the number respondents as new manufacturers are frequently joining the UAS industry while existing manufacturers leave. Additionally, the FAA has developed an example safety statement that can be used to satisfy the requirement and reduce the burden to the manufacturer, however the manufacturer may elect to develop materials of their own.

Assuming there are 100 UAS manufacturers: 50% of those use the FAA developed guidance and 50% develop their own guidance, the time burden would be:

40 hours/year to develop and approve content x $75/hour¹ = $3,000 development cost

50 manufacturers x $3,000 development cost = $150,000/year

Summary (Annual Numbers)	Disclosure	Recordkeeping	Reporting
Estimated Number of Respondents	50 manufacturers	N/A	N/A
Estimated Number of Responses per Respondent	1 response per year per manufacturer	N/A	N/A
Cost per Response	$3,000	N/A	N/A
Hours per Response	40	N/A	N/A
Total Number of Responses	50	N/A	N/A
Total Burden (Hours)	2,000	N/A	N/A
Total Burden (Cost)	$150,000	N/A	N/A

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

Section 2203 does not prescribe how manufacturers must satisfy the requirement. It is up to the manufacturer to select their method of compliance (including but not limited to printed materials, website content, mobile applications, or other electronic means).

The material cost for 50 manufacturers x $3,000 development cost = $150,000/year

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.

Annualized costs to the Federal government could include content modification development, coordination, and distribution.

80 hours x $60/hour² (or J band equivalent) = $4,800/year

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

This is a renewal information collection and no change other than the current labor rates.

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.

The results will not be published.

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 to the certification statement.

1 U.S. Bureau of Labor Statistics (BLS); Occupational Employment and Wage Statistics https://data.bls.gov/oes/#/industry/481000

2 Federal Aviation Administration (FAA) Pay and Benefits https://www.faa.gov/jobs/working_here/benefits