October 10, 2014 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590-0001 

RE: Comments to Petition for Rulemaking on 14 CFR §145.221 

Docket No. FAA-2014-0767-0001 

To Whom It May Concern: 

The current revision to 14 CFR §145.221(aL which removes the word "serious" from SDR 

reporting requirements, will have a substantial impact on this and all other repair stations. 

Unless the petition is granted, our organization will be required to submit reports for all 

components that arrive at our shop. Every article has a "failure, malfunction, or defect"- that is 

why maintenance, preventive maintenance or alteration must be performed! 

This repair station processes 30 units per week, which equates to over 360 a year-to file a 

report on each unit would take at least 15 minutes (if not more since lots of the information 

requested is not readily available and must be obtained from the customer, who in turn may 

need to obtain information from the actual operator). 

Our organization is currently evaluating the hiring of up to 1-2 additional persons to comply 

with the expanded reporting. This is an unplanned 15% increase in headcount, simply to 

process "all failures, malfunctions and defects" on articles received by this repair station. As 

there are over 4,000 domestic repair stations; if half of those facilities have to add one 

additional head to their rosters to comply with the rule; at a low wage of $12.00 per hour; that 

is between $24,960.and $49,920. in annual economic impact to the repair station community 

(not calculating required overhead costs such as federal taxes, health benefits and the like). I 

suspect the number is substantially higher. Using the basic methodology above, if half of all 

domestic repair stations submit 300 reports per week that boils out to over 31 million reports 

annually. Again I suspect the number is substantially higher. 

I am surprised that the agency removed the word after the issue was vetted in a previous 

rulemaking AND the word was ADDED due to public comment during that process. Equally 

concerning is the fact that no mention of the potential change was made in the latest Notice of 

Proposed Rulemaking (NPRML thus no chance to comment was afforded and no economic 

analysis was made regarding this serious change. 

8493 Baymeadows Way * Jacksonville, FL 32256 * 904-292-2328 
The agency's desire to receive precursors to safety issues through SDR compliance has been 

eliminated by removing the word "serious" and requiring "all" failures, malfunctions and 

defects to be reported. Almost all failures, malfunctions and defects in articles are 

contemplated, covered and fixed by following acceptable methods, techniques and practices as 

required by 14 CFR § 43.13-if the problem is known and can be fixed, the agency certainly 

does not need information on it-the agency needs information on new or unusual and serious 

problems that have not been p_reviously addressed and that will have an effect on the 

continued safe flight and landing of an aircraft. 

The agency agreed that only serious issues needed to be reported when it attempted to 

remove the word in an earlier rulemaking procedure. What has made it change its mind? That 

reasoning has to be vetted through another rulemaking process so the parties directly 

responsible for compliance can understand and comment on the change. 

Furthermore, it does not seem the agency's current system could handle the volume of reports 

required under the new rule. It cannot possibly have the staffing and other resources necessary 

to mine the flood of data received for helpful and useful information on precursors to safety 

issues. Indeed, the agency has internal documents that complain about the current SDR system 

and how it needs improvement; adding millions of required reports on issues that have already 

been addressed will not enhance that system. 

For the reasons stated in the associations' petition and above, we request the agency grant the 

petition and reinsert the word "serious" in 14 CFR § 145.221(a) on a direct final rule basis. 

FAA 145 YJAR840L 

8493 Baymeadows Way * Jacksonville, FL 32256 * 904-292-2328