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Fri, Mar 07, 2003

AEA Says FAA's Paperwork is Burdensome

If FAA Had Been Around a Hundred Years Ago, Would the Wrights Still be Trying?

In comments submitted on Tuesday to the Small Business Administration, as part of their public outreach meeting regarding current efforts to implement the Small Business Paperwork Relief Act of 2002, the Aircraft Electronics Association (AEA) challenged the Federal Aviation Administration (FAA) for failure to adhere to the Paperwork Reduction Act and their systematic increases in the administrative burden shouldered by aviation small businesses.

AEA challenged the FAA for not having a program to review and improve any of the paperwork burdens that it imposes on small businesses. The Association cited the FAA-certified repair station manual and FAA Form 337 as the most egregious examples of poor management of the burden on small businesses.

In their comments, Ric Peri, AEA's vice president of government and industry affairs, stated, "It is not unusual for a small business to spend 40 hours developing a manual and 30, 60 and, in some cases, over 300 days in negotiating the acceptance of the manual by their local FAA inspector. This negotiation usually includes numerous editorial revisions." Peri also noted, "Since the content of the repair station manual is dictated by the individual FAA inspector, a routine FAA inspector transfer or retirement usually results in some degree of manual re-write to meet the needs of the new inspector."

Form 337 Misued, Overused, Abused

AEA's comments also cited the FAA Form 337 by pointing out that while the FAA Form 337 is required for documenting major repairs and major alterations, many FAA field inspectors "encourage" the business to document ALL alterations on this form.  AEA's comments noted that this action by individual inspectors to "encourage" redundant recordkeeping is just another case where the local FAA inspector places an excessive administrative burden on small businesses.

AEA asked for the assistance of the Small Business Administration to encourage the FAA to develop small business friendly administrative procedures.



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