October 25, 2010
Ms. Carla Scott
Federal Aviation Administration
IT Enterprises Business Services Division, AES-200, Room 712
800 Independence Ave., SW
Washington, D.C., 20591
Re: Office of Management and Budget (OMB) approval to renew information collection (FAA Form 337).
The Aircraft Electronics Association (AEA) represents more than 1,300 aviation businesses, including repair stations that specialize in maintenance, repair and installation of avionics and electronic systems in general aviation aircraft. AEA membership also includes instrument facilities, manufacturers of avionics equipment, instrument manufacturers, airframe manufacturers, test equipment manufacturers, major distributors, and educational institutions.
The Aircraft Electronics Association does not support the FAA’s request for continuance of information collection as proposed in OMB Control Number: 2120-0020.
While the Association does support the continued use of FAA Form 337, it is important for the Agency to accurately account for the public burden associated with the use of this form in its request to the Office of Management and Budget. It is critically important for FAA Headquarters to understand and take responsibility for the public burden of this form, including the “unauthorized” uses of this form and the inappropriate local mandates for data, which is not supported through this OMB request. Finally, the FAA must not have conflicting public guidance in AC 43.9-1 and FAA employee guidance in FAA Order 8900.1.
To answer the specific questions asked of the Agency:
FAA question (a). Whether the proposed collection of information is necessary for the FAA’s performance.
Yes, the information is important for the Agency to collect in its efforts to manage and document the airworthiness of aircraft and components.
FAA question (b). The accuracy of the estimated burden.
No, the Agency has significantly underestimated the public burden. Unfortunately, the Agency only accounted for the recording of a major alteration that is accomplished via a Supplemental Type Certificate (STC). However, the use of FAA Form 337 has far exceeded the simple recording of an STC. In recent years the data collection burden has grown unbound with little or no control of the use of the form by FAA Headquarters.
FAA Form 337 is used as a simple record for major alterations and major repairs (as suggested in the public notice); however, the form also is used for the FAA approval of repair and alteration data (field approval); submitting an Instruction for Continued Airworthiness (ICA) for acceptance by the local FAA Flight Standards District Office (FSDO); and as a cover sheet for the FAA approval of Flight Manual Supplements (FMS).
While the use of FAA Form 337 for a “field approval” of alteration and/or repair data clearly is accounted for in FAA Advisory Circular 43.9-1F, the additional burden of using FAA Form 337 for ICA approval is contained in the internal FAA policy, FAA Order 8900.1. In this order, there is a prohibition of issuing a field approval to the public without the accompanying ICA. While FAA Headquarters has not officially endorsed the use of FAA Form 337 for FMS approval, it is common practice in the FSDO. Each of these non-accounted for uses of FAA Form 337 easily can add an additional eight hours of burden for each of the three approvals — in essence, adding as much as 24 additional hours of burden.
The reason the burden for these additional uses tends to be so high is because the approval is given at the local FAA field inspector level and the FAA does not have clear, concise guidance or policy to guide the pubic and/or limit FAA employees from adding their personal preferences to the data collection requirements.
FAA question (c): Ways for the FAA to enhance the quality, utility and clarity of the information collection.
The FAA must harmonize its public advisory circular with its internal FAA inspector guidance. The fact that FAA Order 8900.1 contains requirements not contained in AC 43.9-1F is a major deterrent to a simple, cost-effective use of FAA Form 337.
In addition, the “unofficial” use of FAA Form 337 for Flight Manual Supplement approval is not acceptable. AC 23-8 and AC 25-7 provide clear instructions for submitting FMS revisions to the FAA for approval. The instructions in these advisory circulars do not include the use of FAA Form 337 as a tracking document.
FAA question (d). Ways the burden could be minimized without reducing the quality of the collected information.
The FAA must take responsibility for the inconsistent use of this form and the “unofficial” uses of this form as mandated by the local FSDO offices. AC 43.9-1 must be updated to provide clear instructions on each application of FAA Form 337. In addition, FAA Headquarters must hold its field employees accountable to the limits of the data collection as provided in AC 43.9-1.
The Aircraft Electronics Association appreciates the opportunity to comment on the OMB request. Should you have any questions, please do not hesitate to contact us at 202-589-1144.
Richard A. Peri
Government & Industry Affairs
Aircraft Electronics Association
FOR MORE INFORMATION:
Contact Ric Peri, AEA vice president of government and industry affairs, by email at firstname.lastname@example.org or by phone at 202-589-1144.