Ms. Rosalind A.
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
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.
John D. Graham
Office of Information and Regulatory Affairs