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Department of Transportation

Federal Aviation Administration 

SUPPORTING STATEMENT

Helicopter Air Ambulance Operator Reports

INTRODUCTION

This information collection is submitted to the Office of Management and Budget 

(OMB) to request a three-year approval 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) 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 attached Section 

306, 49 USC § 44731]. The FAA Administrator had 180 days 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 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. 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 reduce 

the currently unacceptably high helicopter air ambulance accident rate, and to meet the 

mandates set by 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. 
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Upon completing their report they will be able to submit it via an FAA email mailbox set 

up for that purpose.

4. Efforts to identify duplication. Of the nine items of data required by the Act 

(identified in the Act in seven paragraphs), the FAA already collects two – the number of 

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

ambulance accidents – 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 quarterly. 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 requirements. 

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 payment 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 information 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 quarterly basis. 
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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. 

However, it is estimated that 367 flight operations are conducted per helicopter 

per year1. This translates into an aggregate total number of helicopter air 

ambulance operations of 393,791 (1,073 helicopters X 367 ops per).

 Authorized helicopter air ambulance certificate holders who operate 10 or more 

air ambulance helicopters would be required under a proposed regulation2to have 

Operations Control Centers (OCC). For the purposes of this analysis, certificated 

holders falling into this category are defined as “large.” Fifteen certificate holders

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.

 Certificate holders will input their data in an Excel spreadsheet template, which

requires some general information that the operator must input regarding his 

company (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, base locations of 

each of their helicopters, hours flown by each of their authorized helicopters 

under instrument flight rules, and number of flight requests accepted or declined. 

Certain data mandated by the Act are currently 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 flight data operations reporting 

(approved in December, 2012 by OMB for meeting an essentially identical 

requirement mandated by the Act), it will take each small certificate holder (those 

operating fewer than 10 helicopters), approximately 6 hours on average to fill out 

and submit the required quarterly report. Our burden estimate for large operators 

(those operating greater 10 or more helicopters) did not scale linearly. 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. We believe that those operators who employ

electronic flight dispatch databases should be able to largely automate exporting 

the required data into an Excel-readable format (i.e., comma or space-delimited 

 

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Source: Helicopter Air Ambulance, Commercial Helicopter, and Part 91 Helicopter Operations, NPRM, 75 Federal Register Vol. 

62640, 62661 (Oct. 12, 2010). It should be noted that the exact number of certificated operators and the number of authorized air 

ambulance helicopters in service at any given time are in constant flux. These estimates are based on the best available data at the 

time of this analysis. Actual figures at time of reading may vary slightly.

2

Ibid.
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text files). Therefore, for each large certificate holder who conducts a large 

number of operations, we estimate 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 per quarter or 1,392

hours per year for “smaller” operator labor burden; 15x 16 = 240 per quarter or 

960 hours per year for “larger” operator labor burden. The aggregate hourly

burden total would be 588 labor hours per quarter, or 2,352 a year 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 hourly labor 

rate for an industry clerk is $25 / hour3. 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). The 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. It is not anticipated that there 

would be any 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 everyone would reasonably be expected to already possess. 

Therefore, the only costs are related to keeping 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 

include a review of each operator’s quarterly submittal to ensure every operator has 

submitted the proper report, and to ensure the data are properly reported. It is anticipated 

that it will take the agency approximately 40 hours each quarter to review all the 

quarterly reports that are submitted by the helicopter air ambulance operators, for a total 

of 160 hours per year. The review would likely be conducted by a GS-13 level employee 

working in the Washington, D.C. area (i.e., a policy analyst or Aviation Safety Inspector). 

The cost to the federal government for a Washington, D.C. based employee at a grade 13, 

step 5 level is $64.06 / hour ($48.35/hr., which includes a 24.22% locality adjustment4, 

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 likely to be conducted 

 

3

Ibid. 

4

Source: OPM.gov, Pay & Leave Salary Table 2012, the most recent year for which OPM salary data are available.
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by a GS-13 (step 5) level employee for a cost to the government of $2,562, bringing the 

overall estimated aggregate cost to the federal government of $12,812.

15. Explanation of program changes or adjustments. This is a new collection, 

therefore it is a program change. 

16. Publication of results of data collection. 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. 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.