Overview
Title
Agency Information Collection Activities: Requests for Comments; Clearance of Renewed Approval of Information Collection: Report of Inspections Required by Airworthiness Directives, Part 39
Agencies
ELI5 AI
The FAA wants people to tell them what they think about changing how some airplane safety rules (called Airworthiness Directives) are followed. If someone can't do things exactly as the rules say, they can suggest another safe way, and the FAA wants to know if this is easy for people to do or if it takes too much time.
Summary AI
The Federal Aviation Administration (FAA) is seeking public comments on renewing an information collection related to Airworthiness Directives (ADs). This collection allows the public to propose Alternative Methods of Compliance (AMOC) if they can't follow an AD or find a different way to meet its requirements. Comments are invited on the necessity and burden of this collection, which the FAA estimates will involve about 28,000 reports annually. Comments should be submitted by February 12, 2025.
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 Federal Register Notice with a 60-day comment period soliciting comments on the following collection of information was published on October 21, 2024. The collection involves the member of the public that may submit an Alternative Methods of Compliance (AMOC) request to the FAA by using the Airworthiness Directives Development (ADD) External website. The information to be collected will be used to support publicly disseminated information to the FAA and/or is necessary because this information supports the Department of Transportation's strategic goal to promote the public health and safety by working toward eliminating transportation-related deaths and injuries.
Keywords AI
Sources
AnalysisAI
The document from the Federal Register presents a notice from the Federal Aviation Administration (FAA) seeking public comments on renewing their information collection related to Airworthiness Directives (ADs). Under ADs, aircraft owners or operators are required to maintain compliance with specific safety regulations. Sometimes, due to practical issues, complying directly with an AD may not be feasible. In such cases, stakeholders can propose Alternative Methods of Compliance (AMOC) to the FAA. The current collection underway seeks the Office of Management and Budget's approval to renew the process for collecting such AMOC requests from the public.
General Summary
The FAA's notice essentially calls for public feedback on their intention to renew information collection associated with AMOCs. The document acknowledges the submission mechanism via the Airworthiness Directives Development (ADD) External website, enabling the public to propose alternative solutions when direct compliance with an AD is problematic. The desired comments should pertain to the necessity and burden of the information collection, estimated to result in approximately 28,000 reports yearly, each entailing about an hour's worth of effort.
Significant Issues and Concerns
One noticeable concern is the complexity associated with the AMOC submission process. While it allows significant flexibility—permitting submissions via letter, email, fax, or even telephone—this lack of a standard form could lead to inconsistencies, potentially complicating the FAA's review process. Furthermore, the mention of "Order 8110.103B Alternative Methods of Compliance (AMOC), Section 32" without an exhaustive explanation might confound those unfamiliar with such directives.
Another critical issue is the slight inconsistency observed in citation details within the document. The discrepancy between the Federal Register notice reference in the summary and what is mentioned in the background section can create confusion among stakeholders.
Public Impact
The public at large may find this document overwhelmingly technical. The FAA's request for comments reflects a sense of transparency and public involvement, crucial for policies involving public safety. This open call for participation allows stakeholders, especially those directly impacted, to voice opinions or concerns about the documentation or the AMOC process itself.
Impact on Stakeholders
For aircraft owners and operators, the ability to submit AMOCs represents an essential flexibility, potentially preventing operational disruptions where traditional compliance isn't feasible. However, the absence of a standardized submission form and the intricate nature of the submission process might present hurdles for less-informed stakeholders.
On the positive side, the move to digital submissions via the ADD External website signifies an advance towards more efficient and quicker processing. Yet, it could also pose barriers to those less savvy with digital tools.
Ultimately, while the FAA is making strides in involving public opinion and ensuring adaptability in compliance, there remain areas that could benefit from expanded clarity and accessibility. Addressing these issues would enhance the process's usability for all stakeholders involved.
Issues
• The document does not specify any financial implications or specifics about potential spending, which could obscure wasteful expenditures.
• The document does not mention any particular organizations or individuals being favored, but the potential for favoritism cannot be assessed due to lack of detailed information on how AMOC requests are processed.
• The description of the Alternative Methods of Compliance (AMOC) and its submission process could be more straightforward to improve clarity for the general public.
• There is a discrepancy in citation details mentioned in the background section ('October 21, 2024 89 FR 84236') which is not aligned with the citation provided in the metadata ('90 FR 2772'). This could cause confusion.
• The frequency of the reports mentioned as 'As needed' might be ambiguous; a more defined schedule could improve clarity.
• The reference to 'Order 8110.103B Alternative Methods of Compliance (AMOC), Section 32', without further explanation, might be difficult for readers not familiar with the specific order.
• There is no standard form for AMOC submissions, which might challenge consistency and comprehensiveness of the submitted information.
• Information on how the ADD External website works and how submissions are processed may not be fully clear for readers unfamiliar with the system.