On Sept. 26, ARSA commented on the FAA’s second Federal Register notice regarding its assessment of the paperwork burden associated with FAA requirements for repair station certificate applications. In general, the association praised the agency’s updated analysis of the records and documents required by part 145.
Under the Paperwork Reduction Act (PRA), executive branch agencies like the FAA must regularly request Office of Management and Budget (OMB) review and approval for collection of information from the public. The notice continues the process begun in July for the ninth review of repair station application burden since the current part 145 was established in 2001.
ARSA commented on the initial notice by explaining the FAA’s past assessments drastically underestimated the burden associated with an application made under § 145.51. In response, the agency’s supporting statement submitted to OMB for this review has been completely redesigned and its resulting estimated industry burden dramatically expanded.
“[The FAA’s] new analysis includes a thorough review of all paperwork and recordkeeping requirements established by the plain language of part 145. The FAA’s explanation of circumstances making collection necessary…and “Reporting Burden Calculations” cover various submissions required of applicants and information management mandated for certificate holders including manuals, capability lists, and various compliance records,” ARSA’s comments said.
In its July comments, the association urged the FAA to audit its assessment of application and recordkeeping requirements in part 145. ARSA explained repair stations must do far more than simply complete an application on Form 8310-3, they must also produce and maintain multiple manuals, documents, and lists in support of their proposed procedures. The new assessment acknowledges these various requirements and estimates the total annual burden on the international repair station community to be 240,869 hours costing $11,507,548 annually.
“Considering all recordkeeping requirements and not just completion of an application on FAA From 8310-3 resulted in a 23,000 percent increase in hours and a 2,600 percent increase in estimated cost; these increases greatly exceed the estimates offered by ARSA in its initial comments,” the association said.
The association’s comments, signed by Vice President of Operations Brett Levanto, praised the updated analysis while highlighting further improvements possible in the FAA’s description. Levanto noted the agency had overstated the compliance expectations necessary for the government to issue a repair station certificate. He also highlighted the continued practice of applicants completing the Data Collection Tools via the Safety Assurance System (SAS) External Portal, despite agency guidance directing inspectors that DCTs are for internal use only; a paperwork burden not addressed in the agency’s analysis.
To read ARSA’s comments, click here.
July 29, 2024
On July 29, ARSA commented on a Federal Register notice requesting comment regarding the paperwork burden associated with FAA requirements for repair station certificate applications. The association’s comments, based on the agency’s past justifications to the Office of Management and Budget regarding its collection of information under the Paperwork Reduction Act, explained the government is drastically underestimating the burden associated with an application made under § 145.51.
Under the PRA, executive branch agencies like the FAA must regularly request OMB review and approval for collection of information from the public. The notice begins the process for the ninth review of repair station application burden since the current part 145 was established in 2001. The FAA’s past supporting statements to OMB – there has not yet been a statement released for this year’s request – focused solely on the completion of the Form 8310-3. These assessments ignored the manuals and documents applicants must prepare to accompany the form and only estimated six to 19 hours of burden on repair station personnel, depending on the organization’s size.
ARSA’s comments reviewed the complete requirements of § 145.51(a). The paragraph states an application must include numerous documents including repair station, quality, and training program manuals, as well as an organizational chart, facility description, and other detailed lists. Based on the association’s experience assisting members implement its RSQM Compilation, the comments estimated the FAA has underestimated its paperwork burden by as much as 900 percent (based on a conservative estimate).
“As a result [of this underestimation], the agency has a well-noted backlog of persons seeking certification but awaiting review,” the comments said. “Before continuing this request to OMB, the FAA should audit its application requirements and procedures to assess the full burden associated with the rule and current agency practices.”
To read the complete comments, click here.
