Supporting Statement Update 2120-0663 1015020

Supporting Statement A

OMB #2120-0663

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 44701 makes the Administrator responsible for promoting safe flight of civil aircraft in air commerce. Subsection 44701 (a) (5) authorizes the Administrator to prescribe regulations and minimum standards that the Administrator finds necessary for safety. Subsection 44701 (c) authorizes the Administrator to carry out assigned duties and responsibilities in a way that best tends to eliminate or reduce the possibility of recurrence of accidents in air transportation. The Administrator determined, based on evaluations of previous accidents and other incidents, that certain events involving malfunctions and defects may be precursors to recurrence of accidents. Regulations included in the 2005 Service Difficulty Report final rule (70 FR 76974), which modified the previously existing requirements, enumerate these events and require that operators and repair stations report them to the Administrator. Based on these reports the Administrator can systematically evaluate the circumstances and conditions that cause the events and determine whether or not corrective action is needed.

This activity supports the US DOT Strategic Plan on Safety.

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.

FAA Form 8070-1, Service Difficulty Report (SDR), may be used by the air carrier industry and repair stations to submit mandated reporting of occurrences or detection of failures, malfunctions, or defects. As described in 14 CFR 121.703(e), these submitters may use another method that is suitable to their management system, provided that system is acceptable to the Administrator and contains mandated information. Service difficulty information may also be submitted in an electronic format.

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.

FAA Form 8010-4, Malfunction and Defect Report may be used by the general aviation public to submit voluntary reporting of occurrences or detection of failure, malfunctions, or defects. 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

The regulations enhance air carrier safety by collecting additional and timelier data pertinent to critical aircraft components. This data identifies mechanical failures, malfunctions, and defects that may be a hazard to the operation of an aircraft. The FAA uses this data to identify trends that may facilitate the early detection of airworthiness problems. Reports are submitted on occasion.

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.

This required information is now and will in the future involve mechanical and electronic means for data collection. In compliance with the Government Paperwork Elimination Act, this collection is 100% submittable electronically. Currently, approximately 90% are voluntarily submitted in an electronic format on the Service Difficulty Reporting website at http://av-info.faa.gov/sdrx. The mechanical or paper form is also available. The electronic submission of data may eliminate the costs of mailing and storing service difficulty information in a paper format. The Service Difficulty Report and Malfunction/Defect form can be downloaded from the website: https://www.faa.gov/forms/.

The submitted reports can be searched at the following website: https://av-info.faa.gov/sdrx/

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.

We have reviewed other FAA data collection reports and find no duplication. Also, we know of no other agency collecting this data. In fact, the FAA provides this information to other government agencies and foreign regulatory authorities upon request.

Most of the usable data collected is only available from certificate holders, although certain limited data would be available from FAA inspectors during the course of their daily involvement with the aviation industry. FAA inspectors may also collect this information as a result of an accident.

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

The FAA has found that this collection does not have a significant impact on a substantial number of small businesses.

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.

The FAA would have no means of systematically collecting information on incidents and occurrences that are considered to be precursors of unsafe conditions that may lead to accidents and incidents. The frequency of collection is totally dependent on the amount of reportable service difficulties that a certificate holder encounters.

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

There is an exception to the requirements of not submitting a report more often than quarterly. Each report of occurrences during a 24-hour period shall be submitted to the FAA within the next 96 hours. This is not anticipated to be a burden, as the existing rule requires certificate holders to report occurrences during a 24-hour period within the next 72 hours. This reporting requirement is consistent with the rest of the guidelines in 5 CFR 1320.5(d)(2).

8. Provide information on the PRA Federal Register Notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the 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 Federal Register Notice published on August 7, 2020 (49 U.S.C. 44701) solicited public comment. No comments were received.

Five respondents were contacted by email. I received 3 responses. 2 of the respondents found the information that was collected useful, the burden and cost were accurate and reasonable. They found the instructions to be adequate.

One of the respondents felt that the information was not useful. They felt that their company had other programs in place such as SMS, Reliability, and CASS to report the same problem. The burden and cost were accurate and reasonable. They found the instructions to be adequate.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

There are no monetary or gift considerations for the submission of information.

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

Respondents have been 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 statement should:

1. Sections 121.703, 125.409, 135.415 permit part 121, 125, and 135 certificate holders to authorize a repair station to submit an SDR on their behalf.

Section 145.221 requires that the repair stations provide a copy of the report submitted by the repair station to the part 121, 125, or 135 certificate holder on whose behalf the report was submitted. FAA Form 8070-1 is used to submit the reports.

Table 1:

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	6,000
# of Responses per respondent	1
Time per Response	.167
Total # of responses	6,000
Total burden (hours)	1002
Labor Cost	$35,972

2. These are reporting requirements for part 121, 125, and 135 certificate holders. FAA Form 8070-1

These sectional changes are:

• 121.703(a)(1), 125.410(a)(3); 135.415(a)(9),

• 121.703(a)(2); 125.410(a)(4), 135.415(a)(10);

• 121.703(a)(3), 125.410(b); 135.415(a)(12),

• 121.703(a)(4); 135.415(a)(1), 135.415(c);

• 121.703(a)(5), 135.415(a)(2), 135.415(e)(11);

• 121.703(a)(6); 135.415(a)(3),

• 121.703(c), 135.415(a)(4);

• 121.703(e)(11), 135.415(a)(5),

• 125.409(a); 135.415(a)(6)

Table 2:

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	14,000
# of Responses per respondent	1
Time per Response	.167
Total # of responses	14,000
Total burden (hours)	2338
Labor Cost	$83,934

3. These are reports submitted by the general aviation. Submissions are voluntary. FAA Form 8040-1 is used to submit the reports.

Table 3:

Summary (Annual numbers)	Reporting	Recordkeeping	Disclosure
# of Respondents	2,000
# of Responses per respondent	1
Time per Response	.167
Total # of responses	2,000
Total burden (hours)	334
Labor Cost	$11,991

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Calculations will be used for the following wage rates for respondents:

Employee Benefit factors:

• Private Industry: $25.18

• Fully loaded wage rate $35.90

Note: Based on the percent of employer cost for total employee compensation that is related to benefits (not wages and salaries). This amount to 30% in 2020 based on the Bureau of Labor Statistics, Employer Cost for Employee Compensation (https://www.bls.gov/news.release/pdf/ecec.pdf) . Data provided in news release may vary slightly by month.

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

There are no additional material costs.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

No cost to Federal government.

15. Explain the reasons for any program changes or adjustments.

The agency has separated collection activity into appropriate information collections, there has not been additional forms or applications added. The burden estimate has decreased due to decrease in submissions from the airlines and aviation public. In the last 6 months there has been a decrease due to COVID-19. The labor cost have been updated to reflect current wage rates.

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.

Collection of the required data is an ongoing effort. Publication of data will be on the FAA, Flight Standards Service, Service Difficulty Reporting web site, < http://av-info.faa.gov/sdrx/>. Data is available to query on-line with tools available on the web site. It is also available for download in flat file format in both weekly and yearly summaries.

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

We are not seeking approval to not display the expiration date.

18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions.