2120-0704 2015

Supporting Statement For

Paperwork Reduction Act Justification

Organization Designation Authorization-Part 183, Subpart D.

OMB-2120-0704

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 statue 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 related to the examination, inspection, and testing necessary to the issuance of certificates.

Subpart D to part 183 establishes the Organization Designation Authorization. This rule allows the Federal Aviation Administration to appoint organizations as representatives of the administrator. As authorized, these organizations perform certification functions on behalf of the FAA. These functions may include approving data, issuing various kinds of aircraft and organization certificates, and any other functions the Administrator may deem necessary. Application, reporting, and recordkeeping requirements are contained in the rule.

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 is submitted to the appropriate Federal Aviation Administration (FAA) office by an interested organization. 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.

Procedures manuals are submitted and approved by the FAA as a means to ensure the organizations utilize the correct processes when performing functions on behalf of the FAA. The management of such activity is provided for in 49 USC 44702(d).

Reporting and recordkeeping requirements are necessary to manage the various approvals issued by the organization. The reporting and recordkeeping requirements are necessary to document approvals issued and must be maintained in order to address future safety issues which may arise.

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 compliance with the Government Paperwork Elimination Act (GPEA), applications and notifications may be submitted 100% electronically, at the discretion of the authorization holder. Electronic storage arrangements are acceptable providing the applicant has an FAA-approved agreement addressing the means of storage.

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 will reduce reporting by granting applicants authority to make approvals with fewer submittals than required under other reporting requirements. The information substantiating an applicant’s qualifications is not available elsewhere.

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 information required is the minimum needed to appoint and manage the activities of organizations authorized as a representative of the administrator. The collection is necessary to ensure the safety of the aircraft transportation system.

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 collection is required to ensure the future safety of products on which delegated organizations perform functions. Failure to collect the information would impact the FAA's ability to respond to and correct aviation safety deficiencies.

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 December 22, 2014, vol. 79, no. 245, page 76436 requesting public comments. No comments were received.

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 for proprietary business information.

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.

The estimated reporting burden imposed by this activity is 723 hours.

The estimated recordkeeping burden imposed by this activity is 4900 hours.

A section-by-section breakdown of the collection activity follows, showing frequency of response, burden and how the burden has been established.

The active Organization Designation Authorization rule imposes the following burdens:

Section 183.43. Application. The applicant for an authorization must submit an application and proposed procedures manual to the FAA.

Estimated number of annual applications 5

Estimated reporting burden hours per application 5 hours

Estimated reporting burden for proposed procedures manual 60 hours

Estimated annual reporting burden 325 hours

Section 183.45. Issuance of Organization Designation Authorizations. An authorization holder must apply to and obtain approval for any changes to the authorized functions or limitations.

Estimated application for changes 10

Estimated preparation time 1 hours

Estimated annual reporting burden 10 hours

Section 183.53. Procedures manual. An authorization is not issued until the applicant submits and obtains approval of a procedures manual. The manual submission requirements are included in Section 183.43.

Section 183.55. Limitations. An authorization holder may not perform an authorized function if there has been a change in the authorization holder's staff or organization until the FAA is notified of the change and it is documented in the approved procedures manual.

Estimated procedures manual changes 10

Estimated preparation time 2 hours

Estimated annual reporting burden 20 hours

Section 183.57. Responsibilities of an ODA Holder. 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 3

Estimated time per notification 1 hours

Estimated annual reporting burden 3 hours

Section 183.61. Records. Each authorization holder shall maintain at its facility current records that document the approvals they perform for the FAA. Each authorization holder must submit reports as required by the FAA. The recordkeeping requirements are dependent on the type of authorization holder. The following estimates are based on the assumption that there will be 9 organizations with large ODA systems covering multiple ODA types, 20 organizations with significant ODA systems covering multiple approvals, and 55 organizations with very limited authority.

Estimated large authority authorization holders maintaining records 9

Estimated recordkeeping burden per holder 200 hours

Estimated recordkeeping burden 1800 hours

Estimated significant authority authorization holders 20

Estimated recordkeeping burden per holder 100 hours

Estimated recordkeeping burden 2000 hours

Estimated limited authority authorization holders 55

Estimated recordkeeping burden per holder 20 hours

Estimated recordkeeping burden 1100 hours

Section 183.63 Continuing Requirements: Products, parts or appliances. If requested by the FAA, the authorization holders must investigate safety concerns and report the results of investigation to the FAA. If requested, the ODA holder must submit the information required for corrective action.

Estimated safety concerns requiring investigation 5

Estimated reporting burden per investigation 48 hours

Estimated total reporting burden 240 hours

Estimated items requiring corrective 3

Estimated reporting burden per corrective action 40 hours

Estimated total reporting burden 120 hours

Section 183.65 Continuing Requirements: Operational approvals. Authorization holders that issue operational approvals must notify the FAA of errors it makes in issuing certificates and if it finds out it issued a certificate to an unqualified applicant.

Estimated notifications of errors made or unqualified applicants 5

Estimated reporting burden per notification 1

Estimated total reporting burden 5

We estimate this activity imposes an annual public reporting burden of $39,765, based on 723 hours at $55.00 per hour. The estimated recordkeeping costs are $269,500, based on 4900 hours at $55.00 per hour.

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

There are no costs additional to those listed in question 12.

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 $8,800 per year. This estimate is based on 160 hours at $55.00 per hour.

Estimated number of Applications/Procedures Manuals 5

Estimated hours to review/approve 20

Estimated total hours 100

Estimated changes in functions 10

Estimated hours to review/approve 1

Estimated total hours 10

Estimated procedures manual changes 10

Estimated hours to review/approve 5

Estimated total hours 50

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

The burden has changed due to the reasonably stable number of ODA appointments. All delegated organizations have been appointed under ODA and there are a minimal number of new ODA applications yearly.

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.

Numbers/descriptions of approvals issued by the organization may be published in on-going FAA data products. Tabulation and publication are not specific to this data collection, but follow FAA standard practice for the publication of such data. For example, the FAA routinely publishes a description of certificates issued. Certificates issued by these organizations will be included in such a publication.

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.

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