Memo to OMB Requesting Emergency Approval

Federal Aviation
Administration

Memorandum
Date:

November 2, 2020

To:

Kyle Gardiner, Policy Analyst, Office of Information and Regulatory Affairs,
Office of Management and Budget, Executive Office of the President
Digitally signed by JOHN R

JOHN R DERMODY DERMODY

Date: 2020.11.02 11:45:52 -05'00'

From:

John R. Dermody, Director, Office of Airport Safety and Standards

Prepared by:

Janel Showalter, Office of Airport Safety and Standards, 781-238-7617

Subject:

OMB Emergency Clearance for New Information Collection Request (ICR):
Runway to Recovery Recommendations to Help Airports and Airlines Mitigate
the Risks of COVID-19 Transmission

This is a request for an emergency clearance for a new information collection, titled “Runway to
Recovery Recommendations to Help Airports and Airlines Mitigate the Risks of COVID-19
Transmission.” This collection is necessary to determine the extent U.S. certificated air carriers
and airports have implemented practices recommended to reduce and mitigate the risks of
COVID-19 transmission during air travel. If the FAA does not receive emergency approval, the
economic recovery of the nation’s air transport system may be delayed and public health may be
endangered because of the inability to gauge rapidly changing conditions in virus spread and
containment among the nation’s airports and airlines.
Pursuant to 5 CFR § 1320.13, emergency processing is appropriate where (1) the collection of
information is needed prior to the expiration of time periods established under the Paperwork
Reduction Act and that collection is essential to the mission of the Agency; and (2) the Agency
cannot reasonably comply with the normal clearance procedures because public harm is likely to
result if normal clearance procedures are followed.
This Information Collection is Necessary and Essential to the Missions of the Agencies
FAA is collecting this information on behalf of itself and all partner agencies that issued the
Runway to Recovery guidance document, which includes the Departments of Transportation,
Homeland Security,1 and Health and Human Services.2 Runway to Recovery recommends a
1
2

Including the Transportation Security Administration and Customs and Border Protection.
Including the Centers for Disease Control and Prevention.

2
number of practices that U.S. airports and airlines can use to reduce disruptions to air travel
while maintaining essential health and security measures, all of which are critical to the recovery
of the aviation industry. This collection is necessary for the Runway to Recovery agencies to
gauge shifting implementations of recommended practices, identify the changing impacts on the
operations of airports and airlines, understand potential barriers to implementation, and identify
additional mitigation practices.
The collection of this information is essential to the missions of the FAA and partner Runway to
Recovery agencies to maintain the most efficient aerospace system in the world, enhance the
health and well-being of all Americans, and ensure the safety and security of the Homeland. Use
of the normal clearance process would prevent the agencies from attaining a timely and
meaningful assessment of mitigation measures in use by airports and airlines, which is urgently
needed to prevent harm to the public’s collective health and economic well-being. This
information collection is consistent with the Runway to Recovery guidance document and will
support the agencies’ assigned functions of maintaining an efficient aviation system, preventing
disease, and ensuring security.
Public Harm is Likely to Result if Emergency Processing is Not Granted
Public harm will likely result if the FAA and partner Runway to Recovery agencies are prevented
from immediately collecting this necessary and essential information. The Runway to Recovery
agencies are contending with rapidly changing conditions on an ad hoc basis due to phased reopenings in states and regions, fluctuations in COVID-19 spread, and ongoing international
travel negotiations with foreign governments. These circumstances complicate the agencies’
ability to fulfill their missions.
An emergency clearance allows for a more accurate evaluation of mitigation measures currently
deployed at airports and airlines, thus enabling the agencies to update their responses. Gathering
this information rapidly is critical to fulfilling our obligations to the American people, who will
benefit from this collection. Conversely, delay in obtaining and evaluating this information may
hinder economic recovery and endanger public health.
The FAA’s Role
To avoid unnecessary burdens on the public, the FAA has taken the role of lead agency for this
collection and has coordinated with its partner agencies and departments that issued Runway to
Recovery to ensure there is no duplication of effort. Accordingly, the FAA will share the
collected information with its partner agencies and departments. In addition to the emergency
clearance, the FAA will also complete the normal OMB review process and post the 60-Day and
30-Day Federal Register Notices following the Emergency Federal Register Notice.
Due to the Runway to Recovery agencies’ urgent need for this information collection, the FAA
respectfully requests approval by November 13, 2020.