Overview
Title
Agency Information Collection Activities: Requests for Comments; Clearance of a Renewed Approval of Information Collection: Safety Assurance System (SAS) External Portal
Agencies
ELI5 AI
The FAA wants to hear people’s thoughts on a computer program that helps airplane companies fill out important forms to keep their planes safe. They want to know if the program is helpful or too complicated, and you can tell them what you think by a certain date!
Summary AI
The Federal Aviation Administration (FAA) is seeking public comments on the renewal of an information collection tool known as the Safety Assurance System (SAS) External Portal. This online tool helps applicants and certificate holders exchange information with Flight Standards employees for tasks like submitting applications and documents related to aviation certification and maintenance. Comments are invited on aspects like the necessity of the information collection and its burden, with the comment period closing on February 18, 2025. The portal aims to streamline processes by providing direct access to necessary forms and reducing wait times.
Abstract
In accordance with the Paperwork Reduction Act of 1995, FAA invites public comments about our intention to request the Office of Management and Budget (OMB) approval to renew an information collection. The SAS external portal is a web-based tool developed for applicants and certificate holders (also referred to as external users) to exchange information with Flight Standards (FS) employees, primarily to collaborate and communicate with their FS counterparts regarding initial certification applications, and requesting new programs for acceptance and approval.
Keywords AI
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AnalysisAI
The Federal Aviation Administration (FAA) has published a document inviting public feedback on a renewed approval for their Safety Assurance System (SAS) External Portal. This online platform is designed for applicants and certificate holders in the aviation industry to interact with FAA's Flight Standards employees. The portal simplifies the application process for aviation-related certifications and programs. Public comments are welcomed until February 18, 2025, focusing on the information collection process, its necessity, and its associated burden.
Overview
The SAS External Portal serves as a digital hub where external users, such as aviation applicants and certificate holders, can submit necessary documents and applications directly to FAA employees. This setup is intended to streamline the traditional paper-heavy processes, providing quicker processing and tracking of submissions. Through this web-based tool, users have access to a range of forms and data collection tools essential for various certifications.
Significant Issues and Concerns
While the document outlines the functions and benefits of the SAS External Portal, it raises several concerns:
Transparency in Cost Calculations: The document states estimated annual burden costs—$7,027,935 for applicants and $40,104,456 for certificate holders—but does not offer a detailed breakdown of how these figures were derived. This lack of transparency could be concerning for stakeholders who seek to understand the financial implications.
High Estimated Burden Hours: The reported average burden per response, with 135 hours for applicants and 90 hours for certificate holders, appears substantial. Such high figures could indicate areas in the process that are overly complex or inefficient, warranting further investigation or refinement.
Technical Jargon: The document includes technical descriptions such as 'Submitting a Preapplication Statement of Intent (PASI) Form', which may be inaccessible to those not deeply familiar with aviation-specific terminologies. Simplifying or elucidating these terms could broaden the document's accessibility to a wider audience, including possible public commentators.
Lack of Clarity on Public Comments Utilization: There is scant information on how the public comments will be used by the FAA. Greater detail on how stakeholder input will influence decision-making could enhance trust and engagement with this process.
Impact on the Public and Stakeholders
For the general public, this document highlights an avenue for contributing opinions on FAA processes impacting aviation safety and efficiency. The invitation for public comment exemplifies a participatory approach to governance, empowering individuals to influence procedures that may affect domestic aviation industries indirectly.
For specific stakeholders, particularly those within the aviation sector, the SAS External Portal represents both an opportunity and a potential challenge. On the positive side, it promises decreased wait times and better workflow efficiency by offering direct submission channels to FAA personnel. However, the concerns about substantial burden hours and unexplained financial estimates could pose burdens for smaller aviation entities, potentially impacting their operations by demanding significant resource allocations for compliance.
Through this feedback initiative, FAA aims to refine the portal, ensuring it serves both its regulatory purpose and the needs of its users effectively. Stakeholder participation in the commenting process could help address existing concerns and improve the portal's functions, ultimately benefiting the wider aviation industry.
Financial Assessment
The Federal Register document outlines the Federal Aviation Administration's (FAA) intention to renew an information collection for the Safety Assurance System (SAS) External Portal. This portal serves as a bridge for information exchange between applicants, certificate holders, and Flight Standards (FS) employees regarding various certification processes in aviation. The financial implications of this renewal are significant and warrant careful examination.
Estimated Financial Burden
The document highlights the estimated total annual burden as follows: $7,027,935 for applicants and $40,104,456 for certificate holders. These figures represent the costs associated with the time and resources required to comply with the information collection requirements facilitated by the SAS External Portal. This financial burden is a crucial aspect of understanding the impact of the information collection on stakeholders in the aviation industry.
Calculation Transparency
One of the issues identified in the document is the lack of transparency regarding how these substantial cost estimates were calculated. The absence of detailed information on the methodology for deriving these figures may lead to questions about their accuracy and reasonableness. For instance, without understanding how the number of hours and associated costs were determined, stakeholders may find it challenging to assess the fairness of these estimates or to provide meaningful feedback during the comment period.
Efficiency and Complexity
The document also indicates that applicant respondents face an estimated average burden of 135 hours per response, while certificate holders have a burden of 90 hours per response. These estimates suggest a high level of complexity or inefficiency in the process, which directly influences the financial burden. Efforts to streamline procedures or offer more efficient tools within the SAS External Portal could potentially reduce these hours, leading to decreased costs for both applicants and certificate holders.
Benefits Versus Costs
While the document notes several benefits of using the SAS External Portal—such as ease of submission and direct communication with FS employees—the financial benefits are not quantified. Providing explicit data on potential cost savings, such as reductions in processing times or improvements in operational efficiency, could help justify the high estimated burden hours and corresponding costs. This omission could lead to skepticism about whether the financial investments required by this initiative truly align with the potential gains in efficiency.
In summary, while the document outlines significant financial figures associated with the SAS External Portal's information collection process, it lacks detailed explanations behind these calculations. Enhancing transparency and providing quantitative justifications could help stakeholders better understand and evaluate the financial aspects of the proposed renewal.
Issues
• The document does not provide specific details on how the total annual burden costs for applicants ($7,027,935) and certificate holders ($40,104,456) were calculated, which may lead to concerns about the transparency of the financial estimates.
• There is a potential concern regarding the estimated average burden per response being significantly high (135 hours for applicants and 90 hours for certificate holders), which might indicate inefficiencies or complexity in the process.
• The benefits outlined for using the SAS external portal, while generally clear, could provide more quantitative data on time saved or efficiency gained to better justify the estimated burden hours.
• The description of the forms and processes (e.g., 'Submitting a Preapplication Statement of Intent (PASI) Form') may be too technical for all stakeholders, potentially limiting the document's accessibility to those outside the aviation fields.
• There is limited information provided about how FAA plans to use the comments received from the public, which could be seen as a lack of transparency in how stakeholder input will be integrated.