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## Department of **Tr ansportation**  **Federal Av**  **iation Administration**  **SUPPOR TING**  **ST AT**  **EMENT Helicopter** 

**A ir**  **A mbulance Operator** **Reports**
IN TRODUCTION **This information collection is submitted to the Office of Management and Budget (OMB) to request a three**  **- year app**  **roval clearance for the new information collection entitled, Helicopter Air Ambulance Operator Reports.**  **Part A. Justification 1. Circumstances that make collection of information necessary.**  The FAA Modernization and Reform Act of 2012 (the Act) manda tes 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 attached Section 306, 49 USC § 44731]. The FAA Administrator had 180 day s to develop a methodology to collect and store those data. That has been accomplished. The Act further mandates that not later than 2 years after the date of enactment, and a nnuall y 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 col lected. **2. How, by whom, and for what purpose is the information used.**  The helicopter air ambulance operational data provided to the FAA will be used by the agency

as background information useful in the development of risk mitigation strategies to re duce the currently

unacceptably

high helicopter air ambulance accident rate , and to meet the mandates set b y Congress . **3. Extent of automated information collection.**  Submission of data is 100% electronic. The helicopter air ambulance operators will be able to download an Excel spreadsheet reporting template with blank fields in which they can populate their information / data.2

Upon completing their report they will be able to submit it via an FAA email mailbox set up for that purpose . **4. Efforts to i**  **dentify duplication.** Of the nine items of data required b y the Act (identified in the Act in seven paragraphs), the FAA alread y collects two

– the number of helicopters used to provide air ambulance services and the number of helicopter air ambulance acci dents

– which will not be requested of the operators in the context of this data collection. **5. Efforts to minimize the burden on small businesses.**  The information requested is limited to the minimum necessary to fulfill these new reporting requirements mandated by the Act and as developed by FAA. **6. Impact of less frequent collection of information.**  FAA is initially requesting that helicopter air ambulance operators submit reports quarterl y. This will allow the FAA to assess the efficacy

of the data gathering methodology to ensure that accurate reporting will be made to Congress. After some experience and having developed a baseline of information about helicopter air ambulance operations, the agency may re - assess the frequency of reporting requireme nts. **7. Special circumstances.**  There are no special circumstances that are applicable to this request. **8. Compliance with 5 CFR 1320.8**  A notice for public comments was published on July 31, 2013, vol. 78 no. 147, page 46405. **9. Payments or gifts**  **to respondents.** No pay ment or gift to respondents is made. **10. Assurance of confidentiality**  **:** No specific authority for confidential information applies to the reported data. **11. Justification for collection of sensitive information**  **:** No sensitive inf ormation is requested. 12. **Estimate of burden hours for information requested :**   Nationwide, there are 73 authorized helicopter air ambulance certificate holders utilizing 1,073 approved air ambulance helicopters. Certificate holders will be required to report their air ambulance
- related information on a quarterl y basis.3 The annual hour burden will vary greatl y between the operators based on the number of authorized helicopters operated b y each. The actual number of flights each operator conducts per ye ar per authorized helicopter is currently unknown. However, it is estimated that 367 flight operations are conducted per helicopter per year 1 . This translates into an aggregate total number of helicopter air ambulance operations of 393,791 ( 1,073 helicop ters X 367 ops per).

 Authorized helicopter air ambulance certificate holders who operate 10 or more air ambulance helicopters would be required under a proposed regulation 2 to have Operation s Control Centers (OCC). For the purposes of this anal ys is, cert ificated holders falling into this category are defined as “large . ” Fifteen certificate holder s fall into this category , and operate 895 air ambulance helicopters in aggregate , or 83% of the fleet . The balance of the certificate holders ( 58 ) each operate fewer than ten helicopters and are defined here as “small. ” Small certificate holders operate 179 helicopters in aggregate.

 C ertificate holders will input their data in an Excel spreadsheet template, which requires some general information that the oper ator must input regarding his compan y (e.g., name of company, FAA certificate number). In addition, for each helicopter air ambulance operation they conducted during a calendar quarter they will need to enter the time of day that the operation occurred , b ase locations of each of their helicopters, hours flown b y each of their authorized helicopters under instrument flight rules, and number of flight requests accepted or declined. Certain data mandated by the Act are currentl y being collected and will not be requested for this clearance. These include the number of helicopters that the certificate holder uses to provide helicopters air ambulance services and number of accidents in which they have been involved.

 Based on estimates developed for air tour f light data operations reporting (approved in December, 2012 by OMB for meeting an essentiall y identical requirement mandated b y the Act), it will take each small certificate holder (those operating fewer than 10 helicopters), approximately 6 hours on aver age to fill out and submit the required quarterl y report. Our burden estimate for large operators (those operating greater 10 or more helicopters) did not scale linearl y. These large operators would be required under proposed the regulation to have OCCs. Due to the high volume of activity of these large certificate holders, nothing other than electronic means of data recording and dispatching would be practical for compliance with this mandate. W e believe that those operators who employ electronic fligh t dispatch databases should be able to largely automate exporting the required data into an Excel
- readable format (i.e., comma or space
- delimited

1 Source: Helicopter Air Ambulance, Commercial Helicopter, and Part 91 Helicopter Operations, NPRM , 75 Federal Register Vol. 626 40, 6 2661 (Oct. 12, 2010) . Itshould be noted that t he exact number of certificated operators and the number of authorize d air ambulance helicopters in service at any given time are in constant flux. These estimates are based on the best available dat a at the time of this analysis. Actual figures at time of reading may vary slightly.
2 Ib id.4 text files). Therefore, for each large certificate holder who conducts a large number of operations, we estim ate that it will take , on average , approximately 16 hours to fill out and submit each quarterly report.

 There are 58 “small” certificate holders and 15 “large” operators as defined in the context of this request. Thus it will take 58 x 6 = 348 hours pe r quarter or 1,392 hours per ye ar for “smaller” operator labor burden; 15 x 16 = 240 per quarter or 960 hours per ye ar for “larger” operator labor burden. The aggregate hourly burden total would be 588 labor hours per quarter, or 2,352 a ye ar for all the respondents.

 Using the automated “export” and “import” features in Excel is a relatively simple task and can be performed by an administrative clerk. The assumed hourl y labor rate for an industry

clerk is $25 / hour 3

. Therefore, the average annual burden to an individual small operator (as defined in this context) would be $600 (24 hours X $25), and for an individual large operator, $1,600 (64 hours X $25). T he total aggregate annualized burden to all respondents is estimated to be approximately $58, 800 ( 2,352 hrs X $25). **13. Estimate of total annual costs to respondents.**  Itis not anticipated that there would be an y additional capital / startup costs or operation / maintenance associated with this reporting effort . The helicopter air ambulance operators are being asked to fill in an Excel spreadsheet template, which would only require a computer and standard software package that virtually

every one would reasonably be expected to alread y possess. Therefore, the onl y costs are related to keepin g data and reporting it to the FAA, which we estimate to be approximately $58,800
. **14. Estimate of cost to the Federal government.**  The helicopter air ambulance operators will electronically submit this information directly to FAA. Agency

costs will in clude a review of each operator’s quarterly submittal to ensure every operator has submitted the proper report , and t o ensure the data are properl y reported. It is anticipated that it will take the agency approximately 40 hours each quarter to review all the quarterl y reports that are submitted by the helicopter air ambulance operators, for a total of 160 hours per ye ar. The review would likely be conducted b y a GS - 13 level employ ee working in the Washington, D.C. area (i.e., a policy anal ys t or Aviation Safety I nspector). The cost to the federal government for a Washington, D.C. based emplo yee at a grade 13, step 5 level is $ 64.06 / hour ($4 8 . 35 /hr. , which includes a 24.22% locality adjustment 4 , X 1 .325 benefits cost), for a cumulative government cost of $ 10 , 250 . It is further 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 likel y to be conducted

3 Ib id. 4 Source: OPM .gov , Pay & Leave Salary Table 2012, the most recent year for which OPM salary data are available .5

by a GS - 13 (step 5) level employ ee for a cost to the government of $2, 56 2 , bringing the overall estimated aggregate cost to the federal government of $1 2 , 812 . **15. Explanation of program changes or adjustments.**  This is a new collection, therefore it is a program change. **16. Publication of results of dat**  **a collection.** No publication of the compre hensive 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 operatio ns, 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 congr essional mandate . **17. Approval for not displaying the expiration date of OMB approval.**  We are not seeking approval to not display the expiration date.
**18. Exceptions to certification statement.**  There are no exceptions to the certification statement .