October 10, 2014 U.S. Department ofTransportation Docket Operations West BuildingGround Floor Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590-0001 RE: Commentsto Petitionfor Rulemaking on 14CFR §145.221 Docket No. FAA-2014-0767-0001 To Whom It MayConcern: The current revision to 14 CFR §145.221(aL which removes the word "serious" from SDR reporting requirements,will have asubstantial impacton this and all other repair stations. Unless the petition is granted, our organization will be required to submit reports for all componentsthat arrive at ourshop. Every article has a "failure, malfunction, ordefect"-that is why maintenance, preventive maintenance oralteration 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 ofthe information requested is not readily available and must be obtained from the customer, who in turn may need to obtain informationfromthe 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 totheir rosters to complywith the rule; at a lowwage 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 perweek that boils out to over 31 million reports annually. Again Isuspectthe numberis 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 thefactthat no mention ofthe potential change was made in the latest Notice of Proposed Rulemaking (NPRML thus no chance to comment was afforded and no economic analysiswas made regardingthis serious change.

8493 BaymeadowsWay * Jacksonville, FL 32256 * 904-292-2328The 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 byfollowing 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 newor unusual and serious problems that have not been p_reviously addressed and that will have an effect on the continued safe flight and landingofan 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 responsibleforcompliance can understand and commenton the change. Furthermore, it does notseem the agency's current system could handlethe volume of reports required underthe new rule. Itcannot possibly have the staffingand 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 documentsthat complain aboutthe current SDR system and how it needs improvement; adding millions of required reports on issues that have already been addressed will notenhancethatsystem. Forthe reasons stated in the associations' petition and above, we requestthe agency grantthe petition and reinserttheword "serious" in 14CFR § 145.221(a) on adirectfinal rule basis.

FAA 145YJAR840L

8493 BaymeadowsWay * Jacksonville, FL 32256 * 904-292-2328