Yesterday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved a revision to the DOT’s Federal Aviation Administration’s information collection request (ICR) for “Airspace Authorizations in Controlled Airspace under 49 U.S.C. 44809(a)(5) [link added]”. This supports the FAA’s requirement for unmanned aircraft system operators to request permission to fly UAS in certain controlled airspaces. Changes were made to the burden estimate based upon actual usage during the first three years of operations under this ICR.
Commentary
Dramatic changes in burden estimates are not unusual for the first update of an ICR. The agency has to guess how many folks will be using the new system and may not have a strong basis for making that guess. So, a radical decrease, based upon three years of actual data makes a certain amount of sense. But…
There is no indication here that the FAA has gone back and
done a study to see if the actual data reflects full compliance with the
coordination requirements of the regulation, or if there are substantial instances
of non-compliance. And to be fair, ICR notices are not really the place to
discuss compliance investigations in any sort of detail, but it would be nice
to see some notification that the FAA was investigating potential non-compliance
issues as a response to those instances of non-compliance may have an impact on
future burden estimates.
For more details about the ICR revision, including new
burden estimates, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/omb-approves-update-for-faa-icr-for
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