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.
