ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

Still Nothing Generic About Generic Clearance

On Mar. 12, ARSA submitted its continued objections to the FAA’s request for generic clearance of information collections contained in Airworthiness Directives.

ARSA again provided the Office of Information and Regulatory Affairs (OIRA) with evidence that generic approval of information collections contained in ADs is inappropriate, and that the FAA’s supporting statement was inadequate under the Paperwork Reduction Act. ARSA gave OIRA reason to disapprove the information collection request, or at a minimum to return the request as improperly submitted due to its procedural deficiencies.

And now we wait – will OIRA do the right thing? Stay tuned.

Previously from ARSA...

Double the Paper, Double the Fun

February 17, 2015

For years the FAA has been allowed to collect mandatory information related to Airworthiness Directives (AD) on a “generic” clearance from the Paperwork Reduction Act (PRA). On Jan. 29, ARSA objected to the generic clearance; on Feb. 10, the FAA gave another notice of its intent to obtain the generic clearance, without responding to ARSA’s legal, factual and practical comments.

To obtain approval from the Office of Information and Regulatory Affairs (OIRA) an agency must first post a 60-day notice seeking public comments in the Federal Register. After the agency receives and considers any submissions, it files a revised notice with a 30-day comment period while simultaneously providing a statement to OIRA justifying the information collection request.

Ironically, congress created the PRA to ensure oversight of federal agencies’ paperwork burdens on businesses and individuals. Thus, the FAA cannot simply avoid the requirements of the act by misleading OIRA in its request for approval. In the case of AD information collections, the FAA’s second notice provides consideration of ARSA’s comments; the facts and burden estimate remain inaccurate and misleading.

The association now has the ability and obligation to provide double the paperwork and take the facts directly to OIRA.

The nuances of the federal regulatory system are boring, but important. Good news: ARSA works to capture and address these details – so you don’t have to!

ARSA to FAA: Nothing Generic About AD Info Collection


On Jan. 29, ARSA objected to the generic clearance of information collections contained in Airworthiness Directives (ADs). Although the practice has been going on for years, the recent request for renewal of the generic collection prompted the association to take action.

The Paperwork Reduction Act (PRA) mandates that federal agencies obtain the Office of Management and Budget’s (OMB) authorization to collect information from the public. Each request must be evaluated according to criteria including the requirement for “a specific, objectively supported estimate of burden.”

Generic information collection approvals are not specified in the PRA; rather they are allowed by an OMB memorandum that sanctions them for activities that are “usually voluntary, low-burden, and uncontroversial.” Where the OMB provides generic approval, the requesting agency outlines a plan providing an estimate of the average burden imposed on respondents, but does not need to seek public comment on each specific collection.

ARSA provided evidence that generic clearance is ill-suited for ADs where each information collection is unique and requires the individualized approval mandated by law. Additionally, the association pointed out that the FAA’s estimate of a five minute burden per response was inaccurate and misleading.

To see more about how ARSA works on behalf of the aviation maintenance industry, visit our ARSA Works page.



More from ARSA

Symposium 2017 – See What Happened

Thanks to all the participants, speakers, sponsors and allies who made ARSA’s 2017 Legislative Day & Annual Repair Symposium possible.  See what happened when the maintenance community descended on the…Read More

International Spec for Technical Pubs Modernizes CMM Terminology

The S1000D, “International specification for technical publications using a common source database,” has added new language to supplement the term “component maintenance manual.” The specification now offers “component maintenance publication”…Read More

At Senate Hearing, GAO’s Dillingham Reviews FAA Certification & Consistency Initiatives

At a March 23 hearing of the Senate Commerce, Science and Transportation Committee, Dr. Gerald Dillingham, director of physical infrastructure issues for the Government Accountability Office (GAO), reported on the…Read More

Screening Room – Finding Space for Progress

ARSA works every day to help remind the world of a simple fact: You can’t fly without us. The dedicated effort of the men and women chronicled in the association’s…Read More

SLC 2017 – Save the Date

The Strategic Leadership Conference (SLC) provides industry leaders from around the world an informal setting to discuss important issues facing aviation maintenance. Federal agencies, elected leaders, customer representatives and industry…Read More
ARSA