# A_,DELTA~~

October20, 2014

U.S. DepartmentofTransportation DocketOperations West Building Ground Floor Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590-0001 DeltaAir Lines, Inc. TechOps. 1775 M.H. Jackson Service Road Atlanta, Georgia 30354

Re: Commentsto Petition for Rulemaking on 14CFR §145.221 -Docket No. FAA-2014-0767-0001
To Whom It May Concern: The current revision to 14CFR §145.221(a), which removes the word "serious" from Service Difficulty Reporting (SDR) requirements, will havea substantial impacton ourand all small or large repairstations. Unless this petition is granted, ourorganization will be required to submit reportsfor all articlesthat are inducted at our facility. This includes aircraft, engine, and component work. Every article has some kind of "failure, malfunction, or defect"; therefore, maintenance, preventive maintenance or alteration must be performed and will require reporting regardless ofseverity. For example, Delta's repair station processes more than 200,000 aircraft components peryear. To file a report on each unit would take at least 15 minutes, if not more, since information requested may not be readily available and must be obtained from the customer, who in turn may need to obtain information from the actual operator. To comply with the expanded reporting, organizations will have to consider hiring additional personnel to process "all failures, malfunctions and defects" on articles received by our repair station. As there are over 4,000 domestic repair stations; if half of those facilities are required to add one additional head to their rosters to comply with the rule; at a low wage of $10.00 per hour; that is $41,600,000 in annual economic impact to the repair station community (not calculating required overhead costs such as federal taxes, health benefits and the like). Delta anticipates this number is substantially higher. Using the basic methodology above, if half of all domestic repair stations submit 300 reports per week that comes to over 31 million reports annually. Again this number may be substantially higher. Delta is surprised that the agency removed the word "serious" 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 ofthe potential change was made in the latest Notice of Proposed Rulemaking (NPRM), thus an opportunityto commentwas notafforded and no economicanalysiswas made regarding this change. 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

### 'J methods,techniques and practices as required by 14 CFR § 43.13. Ifthe problem is known and can be fixed, the

# t agency certainly does not need data regarding the condition and repair ofthe article. However, data on new or unusual and serious problems that have not been previously addressed and that will have an effect on the continued safeflight and landing ofan aircraftwill continueto be reported as required. Furthermore, it does not seem the agency's current SDR reporting system could handle the volume of reports required under the new rule. The agency cannot possibly have the staffing and other resources necessary to minetheflood ofdata reported. Undoubtedly, the agency has internal documentsthat report inefficiencies oftheCommentsto Petition for Rulemaking Page 2
current SDR system and how it needs improvement. Consequently, adding millions of required reports on issues that have already been addressed will notenhancethe system butwill furtherdegrade its reliability. The agency agreed that only serious issues needed to be reported when it attempted to remove the word in an earlier rulemaking procedure. To understand the agency's reasoning to remove the word has to be vetted through another rulemaking process so the parties directly responsible for compliance can understand and commenton the change. Forthe reasons stated in the petition and above, we requestthe agency grantthe petition and reinsertthe word "serious" in 14CFR § 145.221(a)on a directfinal rule basis.
Ifyou should need further explanation regarding the response tothis concern, please contact Rodney Markesbery, Program Manager- FAA/NTSB Liaison at404-714-1066.

Bob Gleason Director
- Quality Control, ChiefInspector DeltaTechOps

cc: Don Mitacek, SeniorVice President
- DeltaTechOps David Garrison, Vice President
- Engineering 

### &Quality Lee Gossett, Vice President- Line Maintenance Operations; DirectorofMaintenance JeffHodowanic, General Manager
- QualityAssurance Christopher Bisgard, Manager
- Regulatory Compliance Robert Ireland, Managing Director, Engineering 

### &Maintenance
- A4A Sarah Macleod, Executive Director
- Aeronautical Repair StationAssociation