A_,DELTA~~ 

October 20, 2014 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590-0001 

Delta Air Lines, Inc. 

TechOps. 

1775 M.H. Jackson Service Road 

Atlanta, Georgia 30354 

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(a), which removes the word "serious" from Service Difficulty Reporting 

(SDR) requirements, will have a substantial impact on our and all small or large repair stations. 

Unless this petition is granted, our organization will be required to submit reports for all articles that 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 of severity. 

For example, Delta's repair station processes more than 200,000 aircraft components per year. 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 of the potential change was made in the latest Notice of Proposed Rulemaking (NPRM), thus an 

opportunity to comment was not afforded and no economic analysis was 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. If the problem is known and can be fixed, the t 

agency certainly does not need data regarding the condition and repair of the 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 safe flight and landing of an aircraft will continue to 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 

mine the flood of data reported. Undoubtedly, the agency has internal documents that report inefficiencies of the 
Comments to 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 not enhance the system but will further degrade 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 

comment on the change. 

For the reasons stated in the 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. 

If you should need further explanation regarding the response to this concern, please contact Rodney 

Markesbery, Program Manager- FAA/NTSB Liaison at 404-714-1066. 

Bob Gleason 

Director - Quality Control, Chief Inspector 

Delta TechOps 

cc: Don Mitacek, Senior Vice President - Delta TechOps 

David Garrison, Vice President - Engineering & Quality 

Lee Gossett, Vice President- Line Maintenance Operations; Director of Maintenance 

Jeff Hodowanic, General Manager - Quality Assurance 

Christopher Bisgard, Manager - Regulatory Compliance 

Robert Ireland, Managing Director, Engineering & Maintenance - A4A 

Sarah Macleod, Executive Director - Aeronautical Repair Station Association