2120-0657 2015

5

Supporting Statement

Type Certification Procedures for Changed Products

OMB Control Number 2120-0657

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.

This collection supports the Department of Transportation’s strategic goal of increased level of safety.

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 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 Secretary of Transportation (or 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.

The latest amendments to 14 CFR Part 21 require that, with certain exceptions, all aviation product changes comply with the latest airworthiness standards when determining the certification basis for aeronautical products. This process is intended to increase safety by applying the latest regulations where practicable.

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 certification application request, in letter form, and the supporting data package is made to the appropriate Federal Aviation Administration (FAA) Aircraft Certification Office by an aircraft/product manufacturer/modifier or FAA approved delegated organization. The application and supporting data needs to be submitted only once with each application. If the application is accepted, the applicant is authorized to begin the necessary certification process, allowing for the manufacture of products and parts indefinitely under an approved manufacturing process. The application is the controlling document for aeronautical certification processes either though a type certificate (TC), supplemental type certificate (STC), or amendments to TCs and STCs.

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.

We have instituted in Aircraft Certification Offices and FAA approved delegated organizations specific procedures that allows for electronic submission of data which includes signatures on certification documents. Electronic signatures are acceptable for application and submission of data.

While paper submission of applications is the standard method, electronic transmission of supporting documentation is 100% available and accepted, in compliance with the Government Paperwork Elimination Act (GPEA). Reference Order 1370.104.

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 any other reporting system. Applicants need to submit evidence that each modification data package conforms to the requirements only once. However, if a previous modification is enhanced, the applicant can use the existing data, modify it as appropriate, and resubmit the information for the latest revision update.

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.

This rule has significant impact on a substantial number of small entities. The impact of the new rule process has been reduced by an exception to the rule for airplanes of 6000 lbs. or less and non-turbine rotorcraft of 3000 lbs. or less. The burden on this aircraft class certification process will remain with the FAA certification engineering staff. In addition, guidance material, with examples, is available to the small manufacturer allowing ease in the determination of significant or not-significant product design changes.

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 information collection by the FAA is based on the number of application requests for product changes and will be required only once per application. If the application is not submitted, the FAA cannot analyze the request, nor authorize any product certifications or changes to those certifications.

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.

The FAA met with the Small Business Administration and industry representatives to address these issues and the general concerns of the small business entities in the final rule.

The final rule comments identified additional burden, primarily with the large airplane manufactures, associated with the determination of the level of product change. The rule effectivity date was extended eighteen months to allow for methods/processes to be developed to deal with these issues. Guidance material was created, and continues to be amended, identifying examples and processes allowing for ease in determining the significance of the product level changes.

A notice requesting public comment was published in the Federal Register on December 22, 2014, vol. 79, no. 245, pages 76437-76438. 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.

No assurance of confidentiality is necessary.

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.

Based upon the requirements in the rule, each applicant requesting a design change to an aeronautical product must submit an application and supporting documentation defining a proposal how they will comply with the regulatory standards required for their design change. This collection imposes the following burdens:

Annual recordkeeping and reporting burden:

Approximate time to compile existing data, along with the necessary application paperwork, and for submittal to the FAA	7.355 hours per response
Number of respondents (This number represents the average number of applications for design changes submitted each year by industry)	2,558
Total annual responses	2,558
Percentage of these respondents
collected electronically (estimate)	75%
Total annual hours requested	18,815
Fully burdened industry overhead rate	$107 an hour
Annual cost to the respondents	$2,013,205

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

There are no additional costs not already included 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 equivalent to the applicant cost outlined in Item 12. The review time is estimated to be 7 hours per application times 2,558 applications per year equals 18,815 hours spent per year. An Aircraft Certification Office (ACO) engineer’s (GS-13/5) hourly salary of $40.00 per hour is multiplied by the benefit overhead rate of 1.21 to equal $48.00/hour. This figure is then multiplied by the total application hours per year ($48 X 18,815) to result in a total cost estimate to the FAA of $903,120 per year.

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

There are no changes to the hourly burden from the previous submission. Costs to the public and to the Federal government have been revised.

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.

There is 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.