2120-0020 05 10 18 blh

Supporting Statement

Maintenance, Preventive Maintenance, Rebuilding,

and Alterations—FAR 43

OMB 2120-0020

Justification:

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

Title 49, United States Code, Section 44702/44703, specifically empowers the Secretary of Transportation to prescribe reasonable rules and regulations and minimum standards governing, in the interest of safety, the inspection, servicing, and overhaul of aircraft, aircraft engines, propellers, and appliances, including provision of examinations and reports the Secretary may accept in lieu of those made by its officers and employees.

The information collection associated with FAR 43 is necessary to ensure that maintenance, rebuilding, or alteration of aircraft, aircraft components, etc., is performed by qualified individuals and at proper intervals. Further, proper maintenance records are essential to ensure that an aircraft is properly maintained and is mechanically safe for flight. Clearly, aircraft airworthiness, through proper maintenance, is a major component of aviation safety. This provides a record of all major modifications, repairs, and alterations performed on U.S. civil registered aircraft.

2. Indicate how, by whom, how frequently, and for what purpose the information is to be used.

This collection encompasses the reporting of maintenance recording madated by FAR 43, which may only be done by certified mechanics, repair stations, and air carriers authorized to perform maintenance. Pilots are also authorized to perform and record preventive maintenance, however, the authorization applies only to those pilots who own or lease their aircraft for private operation, and are not responsible for the completion of the Form 337. The reporting and maintenance recordkeeping requirements of FAR 43 is a ongoing process and initiated during the time of maintenance, preventive maintenance, rebuilding and alteration of an aircraft airframe, aircraft engine, propeller, or appliance.

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.

FAA Form 337 is found on the FAA website located off of the FAA Homepage. The form is currently in a pdf fillable format for ease of completion. This also provides a backup copy for the facility or mechanic to retain for his/her records. Also, similar or identical type installations in different U.S. registered aircraft can be quickly reproduced on the computer by merely changing the registration number block.

A new system termed eform service (https://eformservice.faa.gov/eForms.aspx) has been developed with interactive automation capability and reporting functionality.

4. Describe efforts to identify duplication.

Efforts are continually made to reduce both duplication and information collection burden through regulatory review of FAR 43. We have reviewed other FAA public-use reports and find no duplication. FAR 121 air carriers have been allowed by regulation to incorporate a form and manner acceptable to the Administrator to record all major repairs, alterations and modifications in lieu of the FAA Form 337. This can be an engineering order or format of their own design, and approved by the FAA in the company manual. This reduces the reporting and recording requirement thus reducing the burden of the air carrier operator. These records are maintained by the certificate holder and are transferred to the new owner/operator upon sale of the aircraft and are not submitted to the FAA Registry for retention but have to be reviewed by the local FAA office. This affects a total fleet of 5,406 air carrier aircraft that do not require the use of the FAA Form 337. We estimate approximately 20 percent of the carriers opt to use the FAA Form 337 in lieu of creating their own format which equates to 1,081 air carrier aircraft still using the form. The reporting and recordkeeping information required by FAR 43 can only be supplied by airmen or maintenance facilities providing the information. The information is not available from any other source.

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.

Our information collection requirements are kept to the minimum necessary to ensure compliance with FAR 43. FAA’s airworthiness inspectors in the field provide special assistance, as needed, too individual mechanics and small repair stations that may require more support.

6. Describe the consequence 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.

FAA would be unable to determine if aircraft, airframe, aircraft engine, propeller, appliance, or component part overhauls were accomplished in accordance with the regulations. The collection of this information does not occur at a preset time dictated by our regulations. Response is determined by the need to accomplish maintenance.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with guidelines.

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

There is one exception to 5 CFR 1320.5 (paragraph iv) concerning limitation of record retention to three years. FAR 43 is concerned with maintenance. A portion of FAR 43 is concerned with maintenance record entries (Sections 43.9(a), 43.9(b), and 43.11(a), as well as, the retention period for maintenance for the life of the aircraft as specified in FAR 91.417(b)(2). Maintenance records must be retained for the life of an aircraft and transferred to the new owner during the sale of the aircraft.

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 record keeping, disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or reported.

A notice was published in the Federal Register on March 28, 2018,( 83 FR 13339). No comments were received.

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

No payments or gifts are provided in connection with the information collection burden.

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

Respondents are given no assurance of confidentiality

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 questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statements should: Indicate the number of respondents, frequency of response, annual hour burden and an explanation of how the burden was estimated. If this request is for approval covers more than one form, provide separate hour burden estimates for each form. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

YEARLY: Man Hours 27,119 hrs Manpower Cost @ $22/hr = $596,607

This data is based on Record submission totals from AFS-750 and electronic data derived from eForms portal. In a 12 month period starting on October 2016 to September 2017 there were 54,237 records completed and submitted to the aircraft records division.

54,237 337s take approximately .5 hours to complete.

27,119 hours are spent completing 337 forms at an average cost of $22/hour

$596,618 is spent to record the major reapirs and alterations capturing the modifications perfomed on airworthy aircraft flying in the NAS today.

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

There are no startup costs associated with this collection not already included in item number 12.

14. Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses and any other expense that would not have been incurred without this collection of information.

The estimated annual cost to the Federal government is $682,500 based on the processing of 68,250 FAA Form 337’s.

Number of FAA Form 337’s processed: 54,237

Estimated hours per form .5 hrs (30 minutes)

Estimated cost per report on Form 337 $11.00

Estimated cost $596,607

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

There is change in the estimated average annual total of reports received.

The changes are derived from the electronic databases available today indicating a more accurate representation of the amount of 337 forms submitted.

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

There are no plans to publish this information.

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.

We are not seeking this approval.

18. Explain each exception to the certification statement identified in item “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.

There are no exceptions.