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