September 14, 2001Ms. Rosalind A. Knapp
Deputy General Counsel
Department of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590
Dear Ms. Knapp:
On March 2, 2001, the Department of Transportation (DOT) submitted a Federal Aviation Administration (FAA) draft proposed rule titled "Corrosion Control Program" to the Office of Management and Budget (OMB) for review Under Executive Order No. 12866. This proposed rule would require most multiengine airplanes in commercial service to include an FAA approved corrosion and control program in the airplane's maintenance or inspection program.
In addition, on July 27, 2001, the Department submitted for our review a related draft final rule, titled "Aging Aircraft Safety." The final rule would require inspections and records reviews for airplanes at a specific age to ensure that the maintenance of these airplanes' age-sensitive parts and components has been adequate and timely.
We have raised questions and have several concerns with these rulemakings. The FAA responded to some of these concerns in a revised regulatory evaluation of the corrosion control rule on July 27, 2001. Many of the concerns, however, also apply to the analysis supporting the aging aircraft rule. We believe that a concurrent review of the two rules will help resolve these concerns and assist in determining the most cost-effective way to detect and correct problems affecting aging aircraft safety.
Since the resolution of the concerns will take some additional time, I am returning the two rules to the Department for your reconsideration. Our staff is available for further discussion with you on the concerns that have been raised. We look forward to working with you to improve these important rulemaking efforts.