2120-0507 2008

Supporting Statement For

Paperwork Reduction Act Justification

SUBJECT: Special Federal Aviation Regulation (SFAR) 36 Development of Major Repair Data. OMB-2120-0507

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The purpose of Title 49, U.S.C. Subtitle VII - Aviation Programs, is to provide for a safe, secure, and efficient aviation system that contributes to national security and encourages civil aviation.

49 U.S.C. Section 40113(a) empowers the Secretary of Transportation (or the Administrator of the Federal Aviation Administration) to issue such regulations as he/she shall deem necessary to carry out the provisions of the Act.

49 U.S.C. Section 44701 empowers the Administrator of the Federal Aviation Administration to prescribe reasonable rules and regulations, or minimum standards necessary for safety in air commerce.

49 U.S.C. Section 44702(a) empowers the Administrator of the Federal Aviation Administration to issue and amend type certificates, and supplemental type certificates for aircraft, aircraft engines, propellers, and appliances. The section specifies that applications shall be as the Secretary prescribes as to form, content, retention, and manner served.

49 U.S.C. Section 44702(d) empowers the Administrator of the Federal Aviation Administration to delegate to any properly qualified private person functions respecting the examination, inspection, and testing necessary to the issuance of certificates.

Amended Special Federal Aviation Regulation (SFAR) No. 36 allows authorized certificate holders (domestic repair stations, air carriers, air taxi operators of large aircraft, and commercial operators of large aircraft) to approve aircraft products and articles for return to service after accomplishing major repairs using data developed by the holder that have not been directly approved by the FAA. The extension of SFAR 36 will allow uninterrupted major repair activity by the current authorization holders that qualify under the amended SFAR; those authorizations will be extended without the holders reapplying for authorization. The extension will also allow a new, qualified applicant to obtain an authorization instead of petitioning for exemption from the regulations.

This information collection supports the Department of Transportation strategic goal on safety. This is accomplished by promoting the public health and safety by working toward the elimination of transportation – related deaths, injuries, and property damage.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The application form 8100-8 is made to the appropriate Federal Aviation Administration (FAA) district office by a certificate holder. The applications are reviewed by the FAA to determine whether the applicant meets the qualification requirements necessary to be authorized as a representative of the Administrator. If approved, the authorization will enable the certificate holder to use major repair data it develops for approving an aircraft, airframe engine, propeller, or appliance for return to service after a major repair.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

In accordance with the requirements of the Government Paperwork Elimination Act (GPEA), we are working to utilize electronic signature technology to enable respondents to submit their material electronically. However, a standardized process to do this electronically is not currently in place and at present 0% of the collected information may be submitted electronically. Applications and guidance material of interest to SFAR 36 authorization holders is available for the public on the FAA's designee information website.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

This information collection is not a duplication of other reporting but actually reduces reporting by granting applicants authority to develop and use major repair data leading to the approval of the product and/or article on which the major repairs are made for return to service. The information substantiating an applicants qualifications is not available elsewhere.

The information submitted to the FAA under this SFAR grants the applicant authority for major repairs. The applicant maintains that authority as long as the requirements or issuance are met. Therefore, the likelihood of similar information being already available is eliminated by a single (one-time) applicant submission rather than the numerous submissions of technical data required before the FAR first became effective.

5. If the collection of information impacts small businesses or other small entities
(Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The SFAR is an excellent example of one effort used to minimize burden on all respondents by reducing reporting frequency to the FAA for approval of data for major repairs.

6. Describe the consequences to federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

This frequency of this information collection is not mandated by the FAA but is established as needed by the respondents.

7. Explain any special circumstances that would cause the collection to be conducted in a manner inconsistent with the guidelines in Title 5 CFR 1320.5(d)(2)(i)-(viii).

This information collection is consistent with the guidelines in Title 5 CFR 1320.5(d)(2)(i)-(viii).

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d) soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A notice was published in the Federal Register on May 15, 2008, vol. 73, no. 95, page 28183-28184. This notice allowed for a 60-day comment period. No comments were received. A copy is attached for your convenience.

An FAA specialist works with each SFAR 36 holders to do periodic reviews. During and in between reviews the holder provides feedback to the agency on their efforts to collect the necessary data and information.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

We do not provide any payments or gifts.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

We do not assure confidentiality, other than that provided by the provisions of the Privacy Act.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

There are no sensitive questions in this collection of information.

12. Provide estimates of the hour burden of the collection of information.

SFAR 36 imposes the following burdens:

Paragraph 4. Procedures Manual. No person holding an authorization issued under this SFAR may exercise an authority under the authorization unless he/she obtains FAA approval of and complies with a procedures manual and any subsequent “log-of-revisions” pages to that manual.

Estimated procedures manual changes 9

Estimated preparation time 10 hours

Total manual change reporting burden 90 hours

Paragraph 6. Maintenance of Eligibility. Each authorization holder shall continue to meet the requirements for issuance of the authorization or shall notify the Administrator within 48 hours of any change that could affect meeting those requirements.

Estimated notifications 1

Estimated time per notification 1 hours

Total 1 hours

Paragraph 11. Current Records. Each authorization holder shall maintain at its facility current records and FAA Form 8100-9 for each product for which it has developed and used major repair data.

Estimated authorization holders maintaining records 9

Estimated recordkeeping burden per holder 10 hours

Total recordkeeping burden 90 hours

The total estimated information collection burden of SFAR 36 is 91 hours reporting and 90 hours recordkeeping. Total Hours: 181

This SFAR burden is smaller with its one-time major repair authorization than it would be for each individual major repair to be approved by an FAA district office. This SFAR burden will be transferred to the ODA program by November 2009.

The annual cost to the respondent is estimated to be $20,720.00 per year. That figure is based on:

--9 current authorization holders requiring 10 hours each record maintenance and 10 hours manual change preparation time

--1 notification of change of eligibility

, all at $40 per hour.

9 x 20 hours x $40.00/hour = $7,200.00

1 x 1 hour x $40.00/hour = $40.00

TOTAL = $7,240.00

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information.

There are no additional costs over and above the hourly burden in question 12 and 14 of Supporting Statements for Paperwork Reduction Act.

14. Provide estimates of annual cost to the Federal Government and to the respondents.

The annual cost to the Federal Government to analyze and process the information received is estimated to be $1080 per year. This estimate is based on 9 manual revisions per year which take federal employees approximately 3 hours each to review and approve @ $40.00 per hour.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

The number of respondents has decreased, and the FAA no longer accepts applications for new SFAR 36 authorizations. Estimated government costs have been revised to include review of procedures manual revisions.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

No collections of information results are to be published.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

No request for seeking approval not to display expiration date for OMB

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB 83-1.

No exceptions to Item 19.

SFAR36 OMB2120-0507 6