2120-0003 2015

SUPPORTING STATEMENT

OMB No. 2120-0003

Malfunction or Defect Report

Federal Aviation Regulations 121, 135, 145 and all General Aviation

Justification:

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The information collections required by FAR 121, 135 and 145 are authorized by U.S. Code, Title 49, Chapter 447, Subsection 44702, as amended, which empowers the Secretary of Transportation to issue certificates for air taxi operators and repair stations, respectively, and to prescribe such terms, conditions, and limitations on those certificates as necessary to ensure safety in air transportation. Submission of Malfunction/Defect Reports is necessary to ensure safety.

This paperwork burden directly supports the Department of Transportation Strategic Goal on Safety. Specifically, the goal is to promote 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.

Repair stations certificated under Part 145 and Air taxi operators certificated under Part 135 are required to submit Malfunction or Defect Reports, or Service Difficulty Reports. Federal Aviation Administration (FAA) Form 8010-4 is available for use for this purpose, and some use this form to report. However, the same information may be submitted in a different format. General Aviation is the largest user of the Form 8010-4. Report information is collected, collated by the FAA, and used to determine service performance of aeronautical products. When defects are reported which are likely to exist on other products of the same or similar design, the FAA may disseminate safety information to a particular section of the aviation community. The FAA also may adopt new regulations or issue Airworthiness Directives (AD’s) to address a specific problem. AD’s are mandatory repair or modifications essential for the prevention of accidents.

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.

The acceptance of reports in formats other than FAA Form 8010-4 and the use of automated data processing and storage is encouraged. AFS-620 has developed a web based data entry system for Air Operators and Repair Stations located at http://av-info.faa.gov/sdrx/. They are also receiving files of records through a utility upload program. It is estimated that 99% of reports are received electronically. A Web-based system that will allow for 100% of electronic acceptance of reports has been approved for development and is currently in the Planning phase of development. It is currently planned to be ready for production by the end of the 3^rd QTR of FY17.

4. Describe efforts to identify duplication.

The web software has incorporated in it a system to identify duplicates. The web based program will not allow records with the same control number OT be submitted. Data collected in the past is continuously modified since the rate of failure is a vital factor in determining the need for ADs or other corrective actions.

5. If the collection of information impacts small businesses or other small entities, describe the methods used to minimize burden.

Service Difficulty and/or Malfunction or Defect reporting is required of all Part 121, 135 and 145 certificate holders, irrespective of their size. General Aviation submits on a voluntary basis. Requesting only necessary information and accepting incomplete data on the forms, when it is impractical for the reporting person to provide all the data requested minimizes burden. Records may be submitted on-line to eliminate paperwork. The records are available to the submitter to add supplemental data.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently.

Reports are only required when a malfunction or defect occurs. Therefore, report frequency is not controllable.

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

Collection is consistent with CFR 1320.5(d)(2)(i)-(viii).

8. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

A notice for comment was published in the Federal Register on September 3, 2014, vol. 79, no. 170, pages 52406-52407. No comments were received.

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

There are no provisions to provide payment to the malfunction or defect respondents.

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

If the Submitter includes identification, there is provision for the identification portion of FAA Form 8010-4 to be removed and forms are accepted without names or signatures. When electronic entry is used to submit a Service Difficulty Report, no identification information is saved in the record. For General Aviation the anonymity of confidentiality is given to respondents.

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 on the form.

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

The vast majority of the 87,000 reports that the FAA receives annually are sent via the Service Difficulty Reporting system, which is approved by OMB under control number 2120-0663. However, FAA still accepts the Malfunction or Defect Report form, and some Part 135, Part 145, and General Aviation users continue to use this form.

The total annual cost burden for the Malfunction or Defect Report is $2,742.30 and the hour burden is 90 hours. The approximate number of Malfunction or Defect Report forms submitted annually by all Part 135, Part 145 and General Aviation users is 600. The average labor rate is $30.47 per hour and the average time to complete the form is .15 hours (9 minutes).

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

There are no additional costs included in question 12.

14. Provide estimates of annualized cost to the Federal government.

The annualized cost to the Federal Government given the electronic and manual submission capabilities is around $100,000 per year. This includes labor costs for analysis of the data.

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

The majority of the burden for this collection has been transferred to the active information collection Service Difficulty Reports (OMB #2120-0663). This submission represents the use of the alternative Malfunction or Defect Report form by Part 135, Part 145 and General Aviation users. The average hourly labor rate shown in this statement has been increased for inflation.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

The information collected is not routinely published for operators of possible problems. Summary reports and ADP printouts are provided on request.

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.

The FAA is not seeking approval to not display the expiration date.

18. Explain each exception to the certification statement identified in Item 19, of OMB Form 83-I.

There are no exceptions.

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