SUPPORTING STATEMENT - PART A
Civil Aircraft Landing Permit System, DD Form 2400/2401/2402
OMB 0701-0050
Summary of Changes from Previously Approved Collection
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1. Need for the Information Collection
The Federal Aviation Act of 1958 (PL 85-726, Section 1107) authorized government agencies to regulate public use of government-owned airfields. Military airfields are established and funded to support the level of operations necessary to support the national defense mission; therefore, civil aircraft access to military airfields is not comparable to civil airports. The military departments have made military airfield available to civil aircraft operators, primarily to conduct official government business; however, use for other purpose is also occasionally accommodated (AFI 10-1001, AR 95-2, and SECNAVINST 3770-IC). Access must be managed to ensure that security and operational integrity at the airfields are maintained and that the government is not held liable for accidents if the civil aircraft becomes involved in an accident or incident while using military airfields, facilities, and services. The collection of information is necessary to identify the aircraft operator and the aircraft to be operated; establish that purpose for use of military airfields; and protect the US Government against litigation.
2. Use of Information
The respondents for this collection include any civil aircraft operator applying for landing rights on a DoD airfield. The Air Force does 3x more than other military branches of service, thus the Air Force is the owner of the Civil Aircraft Landing Permit System program and DD Forms 2400, 2401, and 2402. The respondents access the collection instruments via a Google search for the forms website or by contacting the base of interest to obtain info on how to request forms for landing approval. Respondents complete the collection instrument by typing into form and printing the form to sign and email to the base location of the service component of interest. For civil aircraft requests, the approval/disapproval is designated by the military departments when the approving official completes the back-side of the collection instrument. The military departments also use the information from the collection instrument to advise installation commanders of approved users, aircraft registration numbers, and purpose for use. Copies of the approved form are returned to the applicant for use in obtaining final landing clearance from the installation commander. The end result or successful effect of the information collection as a whole is to have a process to identify the services of legal responsible if an unforeseen incident occurs on the landing airfield after an approval is granted.
3. Use of Technology
An electronic version of the form is available on the internet. The burden involved in this collection of information consists of the time required for respondents to complete the three forms. The current forms are used by all military department to simplify application procedures for civil aircraft operators. With no centralized source for the information and the diversity in applicants, there is no improved information technology that would further reduce the burden on the respondents.
4. Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source. Each military department requires respondents to file the forms to apply for use of its airfields; however, due to differences in missions and the legal nature of the DD Forms 2400 and 2402, a single filing is not practical. The insurance certification that commercial operators provide to the Department of Transportation (DOT) does not include the legal provisions of the DD Form 2400 to protect the Department of Defense against litigation. Non-commercial operators are not required to provide proof of insurance to DOT or civil airports. Landing permits and hold harmless agreements are not required by DOT or civil airports. No existing combination of sources provides the full range of information required in making application for civil aircraft use of a military airfield.
5. Burden on Small Businesses
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities. The information collected is the minimum required to allow civil aircraft to use military airfields. User must: Complete DD Form 2401 to identify themselves; indicate where they want to operate; state their purpose for use; list their aircraft, complete the DD Form 2402 agreeing to hold the government harmless, and notify their insurance company to complete the DD Form 2400 showing evidence of third party liability insurance coverage. The forms are provided at no cost to the individual or company, and when use is for official government business, there is no charge for use of the airfield.
6. Less Frequent Collection
If the information is not collected, the security, operational, and liability risks would preclude approval for civil aircraft use of military airfields. The purposes of use vary greatly. In some cases, the civil aircraft operator would suffer the greater consequences if access was denied. For example, scheduled air carriers use designated military airfields as weather alternates. Denied access would increase the air carriers operating cost because the additional fuel required to reach a more distance civil airport alternate would reduce payload capacity. On the other hand, there are military department charter civil aircraft to move passengers and cargo - denied access for these aircraft would adversely impact the military department’s capability to transport troops, dependents, and cargo. The collection cannot be conducted less frequently. It must be accomplished as respondents make application. Frequency of application is based on insurance expiration or purpose of use of the military airfield.
7. Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
8. Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for the collection published on 29 May 2020. The 60-Day FRN citation is 85 FR 32364, 32364-32365.
No comments were received during the 60-Day Comment Period.
A 30-Day Federal Register Notice for the collection published on Monday, October 19, 2020. The 30-Day FRN citation is 85 FR 66310, FRN 66310-66311.
Part B: CONSULTATION
There was limited consultation with outside agencies or respondents representatives concerning collection of the required information. The information collected is the minimum required by the military departments to authorize civil aircraft operations at military airfields. The type of information provided (insurance, coverage, user identification, purpose of use, and aircraft data) is minimal and readily available to the respondents. Queries in excess of 1200 users would generate a paperwork burden on all parties. Randomly selected customers were questioned during routine contact concerning clarity and format of forms. There were no negative responses.
9. Gifts or Payments
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
10. Confidentiality
The required Privacy Act of 1974 statement is included on each of the required forms in this collection. Assurance of confidentiality related to the respondents’ information is stated in the Privacy Act statement area of each of the forms. Information collected remains on file with the specific approval authority only and information is not released to agencies outside the Department of Defense.
The System of Record Notice (SORN), F010 AFXO A, Civil Aircraft Landing Permit Case Files (July 30, 2001, 66 FR 39306) can by reviewed at the following DPCLD web site-
https://dpcld.defense.gov/DesktopModules/ArticleCS/Print.aspx?PortalId=49&ModuleId=13614&Article=569686
A draft copy of the PIA, Civil Aircraft Landing Permit System, has been provided with this package for OMB’s review.
All forms collected are destroyed 2 years after expiration date on completed form or when superseded by a subsequent submission.
11. Sensitive Questions
No sensitive questions are asked in this collection of information.
12. Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
Collection Instrument(s)
[DD Form 2400, Certificate of Insurance]
Number of Respondents: 1800
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 1800
Response Time: 0.17 hours
Respondent Burden Hours: 306 hours
[DD Form 2401, Civil Aircraft Landing Permit]
Number of Respondents: 1800
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 1800
Response Time: 0.17 hours
Respondent Burden Hours: 306 hours
[DD Form 2402, Hold Harmless Agreement]
Number of Respondents: 1800
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 1800
Response Time: 0.17 hours
Respondent Burden Hours: 306 hours
Total Submission Burden
Total Number of Respondents: 3600
Total Number of Annual Responses: 3600
Total Respondent Burden Hours: 918 hours
Part B: LABOR COST OF RESPONDENT BURDEN
Collection Instrument(s)
[DD Form 2400, Certificate of Insurance]
Number of Total Annual Responses: 1800
Response Time: 0.17 hours
Respondent Hourly Wage: $30
Labor Burden per Response: $5.10
Total Labor Burden: $9,180
[DD Form 2401, Civil Aircraft Landing Permit]
Number of Total Annual Responses: 1800
Response Time: 0.17 hours
Respondent Hourly Wage: $30
Labor Burden per Response: $5.10
Total Labor Burden: $9,180
[DD Form 2402, Hold Harmless Agreement]
Number of Total Annual Responses: 1800
Response Time: 0.17 hours
Respondent Hourly Wage: $30
Labor Burden per Response: $5.10
Total Labor Burden: $9,180
Overall Labor Burden
Total Number of Annual Responses: 3600
Total Labor Burden: $27,540
The Respondent hourly wage was determined by using the [Department of Labor Wage Website] ([http://www.dol.gov/dol/topic/wages/index.htm])
13. Respondent Costs Other Than Burden Hour Costs
There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.
14. Cost to the Federal Government
Part A: LABOR COST TO THE FEDERAL GOVERNMENT
Collection Instrument(s)
[DD Form 2400, Certificate of Insurance]
Number of Total Annual Responses: 1800
Processing Time per Response: 0.17 hours
Hourly Wage of Worker(s) Processing Responses : $30
Cost to Process Each Response (P: B multiplied by C): $5.10
Total Cost to Process Responses (P: A multiplied by D): $9,180
[DD Form 2401, Civil Aircraft Landing Permit]
Number of Total Annual Responses: 1800
Processing Time per Response: 0.17 hours
Hourly Wage of Worker(s) Processing Responses : $30
Cost to Process Each Response (P: B multiplied by C): $5.10
Total Cost to Process Responses (P: A multiplied by D): $9,180
[DD Form 2402, Hold harmless Agreement]
Number of Total Annual Responses: 1800
Processing Time per Response: 0.17 hours
Hourly Wage of Worker(s) Processing Responses : $30
Cost to Process Each Response (P: B multiplied by C): $5.10
Total Cost to Process Responses (P: A multiplied by D): $9,180
Overall Labor Burden to the Federal Government
Total Number of Annual Responses: 3600
Total Labor Burden: $27,540
Part B: OPERATIONAL AND MAINTENANCE COSTS
Cost Categories
Equipment: $0
Printing: $0
Postage: $0
Software Purchases: $0
Licensing Costs: $0
Other: $0
Total Operational and Maintenance Cost: $0
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Labor Cost to the Federal Government: $27,540
Total Operational and Maintenance Costs: $0
Total Cost to the Federal Government: $27540
15. Reasons for Change in Burden
There has been no change in burden since the last approval.
16. Publication of Results
The results of this information collection will not be published.
17. Non-Display of OMB Expiration Date
Request approval to not display the OMB expiration date on the DD forms 2400, 2401, and 2402. These forms are used by individuals and corporations all over the world that retain blank copies and repeatedly copy them. Many respondents do not have the capability to get forms off the internet. It would save time and cost of postage and telephone calls for respondents if the form did not become unusable simply because of an expired approval date.
18. Certification Statement
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement For |
| Author | Tim.Bennett |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |