NAATS' Minority Opinion On FSS Future Architecture
January 14,1997
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
Attention:
Ms. Darlene Freeman
Acting Associate Administrator for Air Traffic Services
Dr. George Donohue
Associate Administrator for Research and Acquisitions
Ladies and Gentlemen:
We are pleased to submit this "Minority Opinion and Analysis - FSS Future Architecture Workgroup" in response to the work group's report on their conclusions and recommendations.
We believe the collective effort of the work group was well intended, but that the conclusions lack sufficient forethought, planning and operational analysis of the impact to aviation that the group's proposed changes would create. In particular, we strongly oppose the work group recommendation to consolidate the existing system of 61 Automated Flight Service Stations to between 25 and 35 facilities.
In preparing this report, we lacked possession of the final report from the Architecture Workgroup. As we were working from their draft report, a few minor inconsistencies could exist between our analysis and their final document. Although none should be substantive, we nonetheless regret this inconvenience. If you have any questions, please do not hesitate to call us.
Yours very truly,
| Ron Dawson | Walter W. Pike |
| NAATS Work Group Representative | Chief Executive Officer |
MINORITY OPINION AND ANALYSIS -
FSS FUTURE ARCHITECTURE WORKGROUP
Prepared for:
Associate Administrator for Air Traffic Services
Federal Aviation Administration
Associate Administrator for Research and Acquisition
Federal Aviation Administration
by:
Table of Contents
WORK GROUP OBJECTIVES AND APPROACH
NAATS ANALYSIS OF WORK GROUP EFFORT
MINORITY CONCLUSION
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ABSTRACT
The conclusions and recommendation of this latest work group are based on little or no meaningful study on the operational impact that would result from carrying out the consolidation plan. There is no analysis of whether it is humanly possible to safely expand the required knowledge base and areas of responsibilities implied with consolidation of facilities or functions. The National Association of Air Traffic Specialists strongly feels that safety would suffer greatly if such a consolidation plan was actually done. Therefore, we do not endorse the work group's recommendation.
The effort concentrated mainly on the technical and logistical aspects of service and personnel movement and retention. It largely ignored the operational impact to service delivery and availability. The details in the work group report describing equipment limitations and possibilities, building structural limitations and capacities, service reconfiguration and area realignments were created by considered best guess. The limited operational analyses leading to the work group's conclusions came from a management perspective far removed by bureaucratic layers from the realities of delivering flight services in today's environment.
Union involvement in the work group's deliberations were confined to the very early stages. During this time, there were no decisions made other than internal work group structural concerns. As a result, employee participation was limited mostly monitoring the group as it progressed through limited brainstorming and data gathering exercises.
We believe it premature at this point, given its incompleteness and the
inaccuracies contained in the work group's study, for the Agency to arrive at any
conclusive decision to change the current AFSS architecture without meaningful and
complete joint analysis by the FAA and NAATS of the current AFSS Program, and an agreement
on what alternatives may be explored if change is needed.
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EXECUTIVE SUMMARY
To those in FAA leadership and the aviation industry who share our concern for safety, it should come to no surprise that we oppose most of the conclusions and recommendations of the FSS Future Architecture Workgroup. Upon reading our response to the Architecture Report it becomes apparent that a well-intended project assignment has gone awry. The group was tasked with assessing identified objectives of its predecessor, the Flight Service Architecture Workgroup, and to provide a range of alternatives and a recommended course of action. These objectives included several subsets, but the overall thrust was planning for the provisioning of flight services in the future.
This minority opinion report describes our analysis of the work group product from an operational perspective - a perspective that appears to be seriously lacking in the work group's report. We found in the document little meaningful assessment of cost benefit other than equipment and facility housing concerns, and no analysis of safety impact.
The recommendation to consolidate the current system of 61 AFSS's to 25 to 35 Flight Service facilities would not adequately or safely satisfy customer demand. To expand and realign Inflight service areas with Enroute Center boundaries would debase Flight Service personnel's expert knowledge of weather patterns, terrain influences, and their unique body of knowledge about the flight plan area. The work group's strategy for matching resources to service demand largely ignores the imminent short term and the long range impact workforce attrition will have on aviation access to flight services. Their estimate for hiring needed replacement AFSS controllers lacks the proper timing to avert personnel insufficiencies.
We believe the FAA should not approve the recommendations of the FSS
Future Architecture Workgroup. Considering any of the various facility reduction
alternatives offered in the work group report would be premature until the FAA and NAATS
agree on methods to accurately measure both customer demand and Flight Service personnel
productivity and capabilities, with safety - not budget - as the overriding concern.
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INTRODUCTION
The National Association of Air Traffic Specialists (NAATS), representing the controllers performing the front-line operations of the Flight Service portion of the National Airspace System, offers this statement in opposition to the conclusions and recommendations set forth by the Federal Aviation Administration's FSS Future Architecture Workgroup. We at NAATS do so reluctantly, as it was our hope that this work group effort would have produced more positive and responsible results that did its predecessor, the Flight Services Architecture Workgroup. Unfortunately, this did not happen.
Union participation on the work group was limited to only the first meeting in September, as the December meeting conflicted with a previously scheduled NAATS Board of Directors' meeting. Our plea to the work group leader to move forward or postpone the second meeting was dismissed. This denial is representative of the work group authority's disregard for the valuable employee input that would have been possible with full inclusion.
Also, there was no concurrent interface with system users or meaningful analysis of their needs. In fact, during the entire Architecture Workgroups' processes, user groups were consulted only once (a one day meeting during the earlier work group effort). It is our opinion that even then, the user groups demand for needed service expansion and enhancements were largely ignored (or not planned for) in both work groups' final recommendations.
For example, the premise from which the entire consolidation plan stems is that pilots will become more "self-reliant." All cost, service demand and personnel requirement projections in the report were derived from this unproven assumption. Here the work group puts all its eggs into one basket. In contrast to this premise, feedback from pilots through the AFSS workforce leads us to the overwhelming conclusion that our customers have high regard for "one-on-one briefings", believes them superior to any other information source, and that they would be greatly distressed if we were not readily accessible. The "self-reliant" prophecy may come to pass, but only as a self-fulfilling one (of Agency design) by restricting pilot access through planned workforce reductions.
We believe the current group's methodology to be so flawed as to render
their conclusion of drastic change invalid. It is our recommendation that the Agency not
approve this plan. NAATS remains willing to engage in meaningful discussions that lead to
service enhancements and efficiencies. However, the fruits of these discussions must not
be obtained at the expense of aviation safety or the experienced, dedicated workforce that
provides our crucial services.
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BACKGROUND
NAATS had also participated on the preceding work group, but found it necessary to withdraw our participation because the group was working outside its charter by insisting on seriously discussing various options for privatizing the Flight Service system. Our action exposed the ruse to management. Its attempts to refocus the group were fruitless. After Union withdrawal, the work group nonetheless concluded on a general theme of gradual privatization of flight services throughout the nation, excepting Alaska. The privatization theme was cleverly disguised within the group's recommendation. New methods for the provisioning of flight services were portrayed with concepts such as "de-emphasize one-on-one briefings", "emphasize direct access" and "self-reliant pilots." Tactics such as these force pilots to fend for themselves and are detrimental to air safety.
Upon withdrawal from participation in the Flight Services Architecture Workgroup, we went on record by letter to the work group's air traffic lead representative as being opposed to the group's imminent recommendations, and reserved all bargaining rights on any proposals stemming from them. Subsequently in June 1996, we learned of the follow-on activity planned under the name of FSS Future Architecture Workgroup. We guardedly accepted the invitation from the Air Traffic Service Director to join the new group.
We were told in June that this new group was to begin work very soon, as
it was on a tight schedule with an end of fiscal year target for conclusion. Therefore, we
were surprised to learn that the group's first meeting wasn't planned until the week of
September 23. It met just twice, with the only statistical work done between the meetings
confined to the logistical aspect of consolidating buildings and equipment, a group
opinion poll on guessing proper traffic count per specialists, and a brainstorming
exercise to come up with a Flight Service "vision." Somehow magically from these
shallow data gathering exercises, the conference week of December 2-6 produced an enormous
and risky consolidation scheme.
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WORK GROUP
OBJECTIVES AND APPROACH
Group Purpose
The work group is using the "Future Flight Services Operational
Concept" developed by the FSS Issues Workgroup, and the results and recommendations
from the Flight Services Architecture Workgroup to define and assess their identified
objectives, providing a range of alternatives for each issue and recommended actions for
each.
Scope
Architecture assessment to include: operational concepts, personnel staffing and workload distribution considerations, and all components of the supporting infrastructure.
Minimum factors to be evaluated:
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Objectives
1. Identify optimum number of facilities (or range of alternatives) with assessment of
a. Operational and technical feasibility
b. Cost versus benefit analysis
2. Develop concept for matching resources to service demand and a strategic approach implementation
3. Complete assessment of operational and technical feasibility of aligning Inflight service areas with ARTCC boundaries and a conceptual approach for implementation
4. Identify a flight plan area for installation of commercial, kiosk-type equipment, and identify a process to determine usage patterns and benefits
5. Define the capability of M1FC and lCSS to support functional and/or facility consolidation
6. Analyze advantages/disadvantages and feasibility of establishing a
Flight Services Network (FSN) in conjunction with the common national aeronautical
information and weather database. Could be used for internal FAA data movement and for
other user access.
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NAATS ANALYSIS OF WORK GROUP EFFORT
Work Group Objectives
It should be noted that the objectives assume that a reduction in the number of facilities is appropriate. While the work group is not to be criticized for its focus, it must be noted that the work group's charge was extremely limited. There was no room for analysis of appropriate increases in the number of facilities or services provided to the public.
Vision
While NAATS can agree with certain premises identified in the Future FSS Architecture Workgroup's "vision", we disagree with others.
It is important to note our agreement with a key part of the "vision" of the report: system user demand for quality aviation weather products will increase into the next century. We do not concur with the "vision" that a reduced number of AFSSs will continue to provide the service; if demand is increasing, the FAA should be enhancing Flight Service capacities, not reducing them.
Second, the "vision" assumes that the user community will become more "self reliant" and that direct involvement of Flight Service personnel will diminish. We have seen no facts which support this vision.
We do however support the concept of enhancing the functionalities of Flight Service personnel, and we are pleased that the report acknowledges a key role for Flight Service personnel in providing aeronautical and weather information. Actually, we applaud the work group's general theme of flight service specialists being the nation's aviation weather experts.
Incidentally, in contrast to their statement of a future evolution into that role, NAATS confidently feels its bargaining unit attained that status many years ago, and that there is no other group anywhere that approaches our level of experience and knowledge of aviation weather and its hazards.
But it is mere speculation that planned new technologies will significantly reduce the need for contact with an AFSS. Quite the contrary is that which was told at the previous work group's meeting with pilot user groups. Representatives of the Aircraft Operators and Pilots Association (AOPA), the Experimental Aircraft Association (EAA) and the National Business Aircraft Association (NBAA) expressed their belief that even more AFSS personnel would be needed in the future for the Agency to provide much needed improved services. These include Flight Service use of radar, Global Positioning System (GPS) or similar type of aircraft situation display (ASD) coupled with weather radar displays to safely route aviation traffic around hazardous weather conditions. On behalf of their memberships, the pilot representatives also expressed a strong desire to have the capability to interact with a AFSS controller, while simultaneously viewing identical data when obtaining DUAT-type weather and NOTAM information.
Lastly, there is a striking contradiction between the first and second paragraphs of this vision. The work group first speaks of reduced numbers of AFSS locations. The second paragraph then follows with its goal of Flight Service assuming additional functions: Center Weather Service Unit (CWSU) and traffic management activities. Given the group's stated desire to allow workforce attrition to continue, they should be questioned on how these new assignments could be accomplished with sharply reduced personnel.
Factors Considered
We note that a critical element not considered is a methodology for the determination of staffing level requirements based on an accurate understanding of Flight Service personnel activities.
Another critical factor which does not appear to have been included is the fact that our society is undergoing a communications revolution. The extent to which communication costs will be reduced through greater competition, new methodologies (Internet, fiber optic cable, etc.) and other as yet unanticipated techniques will be immense. The opportunities provided by significant reductions in communication expenses need to be taken into account in terms of acquisition of equipment (hardware and software), staffing levels, number of facilities, etc.
We are pleased that the work group supports interactive DUATS within the proposed OASIS system; this is a measure which we have endorsed and requested for many years.
Optimum Number of Facilities
Essentially, the work group was directed to come up with ways and means to reduce the number of Flight Service facilities. Several of their assumptions and conclusions should be addressed here.
Service Demand
According to the work group report, the number of flight services has declined. The report's assumption appears to be that this reduction is due to enhanced "self reliance" by the customer, through DUATS or via other means. We respectfully disagree. In fact, the number of flight service personnel who actually answer 1-800-WXBRlEF lines has declined through attrition and through the consolidation process. The real truth is: access to Flight Service has declined. If access had not been limited, the number of services would not have diminished.
The theory implying a popular DUATS is slowly taking over the preflight and flight planning traffic is skewed. While it is true that many pilots who own or have access to personal computers use the DUAT services, it is likewise true that the majority seem to follow up with contacts to an AFSS. A survey of pilots at the 1995 Experimental Aircraft Association's Fly-In at Oshkosh, Wisconsin revealed to NAATS that which we had long suspected (and confirms the Architecture Workgroup's conclusion about dual AFSS/DUAT use): of the 350 surveyed pilots who answered that they regularly use DUATS, well over half (196) stated that they either always or frequently contact Flight Service after obtaining their DUATS data.
We believe that the majority of those who do not, are either a few very seasoned professional pilots with extensive weather knowledge, are pilots that only fly in excellent weather, or are pilots who check weather for other reason and have no intention of flying. Some newer pilots have incorrectly been taught that a DUATS weather transaction is the same thing as a preflight briefing from an AFSS. What this survey reveals is that while they do receive weather data, there is very little comfort level derived by most pilots from DUATS, and because Flight Service personnel interpret, advise and counsel they contact us anyway to obtain a complete weather picture.
The group also appears to be making assumptions about future general aviation activity that may not be realized. To use activity patterns over the last decade to indicate future trends is to assume the future will be a reflection of the past. The reported decline in general aviation activity (if accurate) was likely caused be a combination of many factors. Foremost is the product liability and tort consequences that wildly drove up the cost of flying an aircraft. The general decline in the early I 990s of personal wealth in real dollars, the mass restructuring of corporate entities (creating the new phenomena of high income worker unemployment), and the low consumer confidence that plagued the nation early in the decade certainly had negative effects on general aviation travel. Also, our nation's economy (like all others) operates in cycles. There are highs and lows every several years. Currently though employment has stabilized, consumer confidence and spending is high, business is reporting record profits in a strong economy, and reforms in the product liability arena have caused small aircraft manufacturers to resume production. The likelihood of a resurgence in aviation activity should not be ignored in future planning.
Workforce Erosion
The report assumes that there will be no new hires into the Flight Service workforce through 2005. Other FAA task forces and work groups assume that replacement employees will begin training in FY 1999. If the workforce will continue to shrink through attrition, the appropriate question to be asked is not how we can reduce facilities, but rather whether the reduced workforce is sufficient to meet the anticipated need.
Generally, it is a mistake to make statistical assumptions with respect to retirement trends. It may be true that in past years somewhat steady attrition occurred. There is no guarantee that this trend will continue. One factor to consider is the large number of those hired during the I 970s, compared to earlier and later years. This has resulted in an inordinately large percentage of employees in the workforce that will soon retire.
There are many factors that one considers when contemplating retirement. A factor that the workgroup seem not to be considering is the effect of working conditions on the decision. Because of the already significant erosion over time of the Flight Service bargaining unit (with its resulting negative effects on job satisfaction and morale) it is very likely that, given the increased workload and responsibilities suggested by the workgroup recommendations, those eligibles currently in place when dramatic changes occur may en mass decide to retire, rather than assume the additional stress associated with job retraining and workplace transitions. Accordingly, now is the time for the FAA to start the hiring process for a pipeline of AFSS controllers to replace the aging workforce. General aviation pilots are not going away (as the AFSS workforce now is.) Training to full performance level does not happen overnight.
Traffic Count
Besides not proving the theory about declines in service demand, the work group cannot dispute one historical perspective: Before the FSS consolidations of the late 1980s, traffic count was higher overall because there were more facilities and specialists to receive requests from pilots (and log contacts and briefings.) For example we'll use a cross country flight from Dalhart (in the panhandle of Texas) to Dallas (in north-central Texas.) Prior to consolidation, an airborne pilot who periodically checked weather ahead likely would have contacted as many as five FSS facilities for briefings: Dalhart, Amarillo, Wichita Falls, Fort Worth and Dallas. This would have resulted in five briefings and at least five contacts separately being logged in the nation's daily traffic count. Today, that entire route is covered by only one facility - Fort Worth AFSS. If the pilot were today to make the same radio calls (now to only one Inflight specialist working the entire airspace), only one briefing could be logged, according to FAA directive. As one learns from this example, historical views of traffic count prior to and during the consolidation years of 1985 to the present, and trend projections resulting from such, are hardly apples to apples comparisons.
The flaw in employing current traffic count methods for arriving at staffing needs is that it does not include a massive amount of work performed by AFSS controllers. Some of the many services performed but not included in today's traffic count are: civil and military flight data movement, administrative messages, aircraft accident notifications, hazardous weather and overdue aircraft broadcasts, recorded briefings for mass dissemination, processing and validation of Notams, emergency lost aircraft orientations, search and rescue activities, maintenance of graphical weather displays, official weather observations, and U 5 Customs aircraft handling and notifications.
Staffing
The work group used the existing traffic count and technology for determining the current and projected staffing requirements. There is no question - either with NAATS or with the FAA - that the current staffing standard is inadequate, inappropriate, and not much more than a haphazard estimate. We see this as a serious problem needing immediate attention. The FAA and NAATS should be working together now to reevaluate the current staffing standard, instead of prematurely devoting resources to develop future plans that use as their basis obsolete productivity formulas.
Contrary to Executive Branch direction to trim government largess, the work group seems content to maintain, if not increase the current ratio of overhead to operational positions when consolidating facilities. It leaves one to wonder if FAA management will allow AFSS controller staffing to dwindle to next to nothing before realizing facility staffing is top heavy. Many facilities are already critically staffed (in operations). In recent years, some facility permanent supervisory and staff positions were eliminated. To compensate,. facilities then filled the offices with temporary staff positions. But the effects of attrition have now made this luxury one we can no longer afford. To continue this practice is neither responsible nor consistent with the FAA safety mission.
The work group re-port notes that staff positions being filled by detail of FPL's do not count as overhead, and that they remain pad of the FPL count. Were this representative of a handful of individuals, we would not point it out. However, because the number of FPL's on detail is large - and considered pad of the bargaining unit workforce - the number of services per specialist is substantially understated, regardless of whether the "count" properly measures actual Flight Service work levels, which it does not. The work group recognizes the limitations of using this data, but then proceeds to use it anyway. They attempt to "balance" this by arguing that bargaining unit specialists get credit for flight services performed by first line supervisors and staff during their monthly proficiency training. No where are there any statistics (or arguments) to show that the limited number of proficiency hours required for currency equate to any real work (flight services) being performed, nor do these hours equate in any relevant manner to the number of hours lost by having FPL's detailed to these positions. To argue that flight services per specialist "may actually be lower than the calculated average" is patently untenable, given the failure to recognize the actual work lost by detailing FPL's out of the bargaining unit.
The essential basis of the work group recommendation is defining a number of flight services per specialist and then doing simple arithmetic to figure out a reasonable number of facilities. When the basis (the number of specialists producing flight services) is unknown, the fact that a series of mathematical steps are undertaken does not make the result more valid. Simply stated, "garbage in, garbage out."
Another step in the work group process is to assume productivity enhancements through the deployment of OASIS. We have yet to see any estimates - from any source whatsoever - that OASIS would result in the ability of Flight Service personnel to undertake a greater number of flight services per specialist than is presently the case. However, it may be true that a new system offering less down time could provide more opportunity to provide service.
Faculties
Optimum number of facilities was analyzed from a equipment and space available perspective by surveying facilities' current equipment and building capacities. The emphasis here was on how many equipment racks, work stations, etc. could be moved into already limited space. It was from this study the conclusion was drawn that consolidation opportunities near term are limited, but that a major consolidation would be possible with the coming equipment upgrades. This idea was based on estimated new equipment capacities and the presumption that new workstations would take up less space than that now occupying AFSSs. Incidentally, the work group conclusion that limited Inflight relocation could facilitate facility part-timing is not germane to the question of "optimum number of facilities," as pad-timing does nothing to change the number of facilities.
The work group's analysis of the number of facilities needed to support specialists is based on the ability of a specialist to perform an arbitrarily predetermined number of flight services, and then by idealizing this number by placing 65 specialists in each of 31 facilities that are 10,000 square feet in size or larger. In this case, the assumptions explicitly used betray the fact that the outcomes of the work group were preordained: there is the assumption that facilities which are identified as difficult to staff or maintain will be closed, and that only larger facilities would be maintained. In fact, larger facilities offer very little increase in operational functionality; they do however offer increased administrative space for increased staff and management.
The assumption that a certain number of flight services per specialist can be idealized and identified as fact (even when an earlier section of the report acknowledges its limitations), and that OASIS will offer significant productivity enhancements, is obviously flawed. Additionally assuming the demand for service is directly proportional to the number of specialists and that normal attrition will align with the demand, evidence the group's predisposition to consolidation rather than service and safety.
Consolidation
The work group states its conclusion precisely: "As a result of the declining demand for one on one Flight Services which is matched by a steadily declining workforce, there is no need to maintain 61 facilities." This conclusion is doubly inaccurate: it assumes (without proof) that demand will diminish, and it assumes (also without proof) that a smaller workforce is appropriate.
It cannot be disputed that two critical facts would clarify the matter: a valid measurement of flight service activity, and a valid measurement of customer demand. Neither measurement tool exists. In effect, the work group is attempting to design a shoe machine without knowing how fast the employees can make shoes, how well the shoes need to be made, or how many pairs of shoes are needed by the public! As a result, the basic assumption that it is appropriate to reduce personnel and facilities becomes a self fulfilling one; the reasoning is circular and invalid.
Possibly the most disconcerting conclusion used to determine an "optimum" number of facilities is the workgroup's "consensus" that 20,000 flight services per specialist is attainable with significant loss of quality, but that a number 10% less (18,000 flight services per specialist) may be palatable. Also, the fear of litigation, rather than the interest of public safety was given as the factor precluding use of the 20,000 figure as a goal. To set the record straight: there was no consensus - the Union was not present during these discussions and would never agree to any initiative that would compromise safety by reducing the quality of the product we deliver. More importantly though, is the work group's willingness to impact safety by targeting 18,000 flight services/specialist to maximize the consolidation outcome.
Cost Benefit Assessment
Throughout the report, costs only are measured. Since these costs are based on untested personnel assumptions, the analysis is another example of garbage in/garbage out. Expressing some of the estimated "savings" in figures of six particular digits is a specific example of mathematical hubris.
Realigning Inflight Service Areas With ARTCC Boundaries
From a lay perspective, this may seem plausible. And why not, one might argue: Enroute Flight Advisory Service (EFAS) areas are already aligned with ARTCC boundaries. The hypothesis may be well-intended, but is unworkable.
Operational Impact
The implied assumption here is that the newly expanded service area of the receiving facility would require little or no additional staffing. This assumption is incorrect: ARTCC geographical areas of responsibility are much larger than those of an AFSS. EFAS operations can safely be conducted in areas the size of an ARTCC because EFAS personnel deal only with the weather aspect of the area. With the Inflight position however, the rules dramatically change. Not only must Inflight personnel be responsible (in a smaller area) for weather concerns, but for every other aspect of flight too. Area knowledge and responsibilities are the same as for preflight duties. Along with weather, this includes continuous maintenance of familiarity with airport status and many other dynamic aeronautical concerns. In an ARTCC, the airspace is divided into specialties, and sectors within those specialties. The expansion of an AFSS area would likewise require specialties or sectors. Obviously, functional consolidation would necessitate staffing increases to compensate both for specialized knowledge limitations and for facility traffic increases.
Equipment
The temptation to decommission Inflight frequencies as a means to facilitate functional realignment, if acted upon, would result in nothing less than a curtailment of service to airborne aircraft. Ironically, this is suggested by the same group that is attempting to shift the primary AFSS role from Preflight to Inflight services, in which case adequate frequency coverage would be even more important.
The idea that replacement of 1055 and the OASIS system will enable service realignment and consolidation is operationally flawed. An new 1055 system with more frequency capacity may facilitate equipment relocation, but OASIS will do little to help. Equipment is merely the tool that is used to do the job. It is not the job itself. The OASIS system is needed immediately to preclude further service degradation caused by a poorly designed and now crippled Model-IFC. Initially, the new system offers to the specialist only that which is already available (albeit a little faster.) Planned later improvements to the system may turn out to be actual efficiencies. These may improve the quantity and quality of information exchanges (thereby enhancing safety), but will likely not shorten the time spent relaying information.
We fully support the proposition that all flight service personnel should have access to not only graphical displays of weather locations, but also aircraft positions. This combination would greatly enhance both safety and efficiency. We disagree that this needs to be located within the ARTCC.
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Flight Watch
The work group concludes that with Inflight relocation comes the ability to relocate Flight Watch. We fail to see the connection. These are two separate and distinct services that require different operating methods and training. As there presently is only one AFSS facility per ARTCC area containing EFAS, what advantage could there be to relocating them? The report also states that the realignment could make Flight Watch available 24 hours per day. This obviously would require more EFAS specialists.
Matching Resources to Service Demand
In this section of the report, the work group alludes to inconsistencies in both staffing estimates and actual counts. It then identifies as a solution for an "accurate picture of activity per specialist" monthly data compilations and an accounting of staff and supervisory productivity, even though admittedly it cannot be done cost effectively. If so, where is the solution?
Traffic cascading is not a new idea. It currently is being done through various agreements between NAATS and the FAA throughout the country. Overall, we question its effectiveness from a safety and efficiency standpoint. Where the cascading is limited to reasonably adjacent areas it lessens negative impact to some degree.
The concept of "facility partnerships", while a novel idea, would not work well. Cross training of personnel for seasonal work defies the FAA's own currency and proficiency standards. Notwithstanding the fact that traffic count in an AFSS does not accurately measure total work product, the work group is attempting here to draw a conclusion about seasonal trends that cannot be substantiated. The argument of seasonal traffic swings is based on generalizations at best, and likely drawn from workgroup member opinion, and not from meaningful analysis.
Part Time Operations
The group's basis assumption of service availability with pad time facility operations being "equal to the service available today" sounds curiously similar to the failed promise to pilots of "equal or better service" during the earlier FSS consolidation. Given the credibility gap with general aviation that still lingers from this past blunder, the "equal to assumption is somewhat hollow and will be hard to sell (much less attain.) It is our hope that FAA's management will remember its past mistakes, learn from them, and not be maneuvered into repeating them with this new claim.
Preflight Services
We are pleased to agree that in the shod term, any significant off loading of preflight activities would require additional equipment and operational quarters. We add that it would also require additional personnel in many instances.
Beyond the short term, the work group justifies feasibility only in terms of equipment and available positions. The report fails to consider additional personnel required to service off-loaded calls. And, while it is true that some facilities (mainly in the Eastern United States) routinely route calls to adjacent facilities, it is tolerated only because demand has overcome the ability to provide service. Safety concerns are somewhat mitigated, but only by smaller flight plan areas and similar terrain and weather patterns than in the West.
Conversely, the flight plan areas in the Western U.S. are much larger, with more diverse weather effects and abrupt terrain influences. Call routing in these areas should be confined mostly to emergency situations in order to avoid unsafe situations resulting from AFSS controller unfamiliarity to weather peculiarities and terrain.
Inflight Services
These conclusions contain some refreshingly appropriate acknowledgment that Flight Service plays a key role in that segment of GA activity which is other than pleasure flights: critical mail, banking, cargo, and connecting flights to UPS and Federal Express, as well as military, air cargo and air taxi users when many towers and approach controls are closed.
As stated earlier, we are seriously opposed to reducing the number of available frequencies until such time as it can be demonstrated that frequencies can be reduced without any negative impact on safety considerations.
Staffing
In the discussion of pad timing facilities, the work group's report reiterates a fact of which we are all aware: that some facilities are more difficult to staff than others. The suggestion that new hires be directed towards these facilities is dismissed out of hand. We believe such a suggestion should be explored more thoroughly.
We are curious to know what criteria the work group used in labeling a facility "hard to staff'. How did the group determine the presumed causes? We agree that many facilities are staffed below adequate levels. However, the work group's report misleads the discussion by stating that factors that make locations "undesirable" are beyond the agency's control. True, the agency cannot control the desirability of a location, but it can and has controlled the locations of facilities. AFSSs have become hard to staff because of the poor planning done during the site selections for the 61 facilities. Over union objections at the time, FAA placed some facilities in high cost of living areas and others in geographically undesirable locations, or both. This is what has caused the employees' perceived "poor quality of life."
The reason a facility remains difficult to staff is the lack of a pipeline of new people. Hiring would solve the problems associated with both attrition and difficult to staff facilities. Actually, the combined effects of no pipeline and attrition will eventually create staffing problems in even the most desirable locations.
Cost Benefit Assessment
There is no assessment in the report of the harm to the aviation community when services are lost by transferring calls to other facilities. Without corresponding staffing increases in facilities receiving the traffic, calls will go unanswered. Many pilots will give up trying to obtain a briefing. Many will depart without one. And sadly, some of these will not reach their destinations. The FAA has a long history of compiling statistics on aviation accidents. What is not known is the number of weather related aircraft accidents averted because the pilot followed the advise of a Flight Service controller. We believe that of the 35 million flight services provided annually by our workforce, there are many "saves" hidden within those statistics. This intangible must be included in any assessment of cost benefit.
Commercial Service Providers - Deployment of Kiosks Type
Equipment
We agree with the conclusion that Kiosks are not a viable alternative. No benefit to aviation could possibly be identified that would justify the expense of this equipment.
Flight Services Network and Common Database
After analyzing this question, the workgroup identified many concerns that we share, and took note in their report of our problem with security of data. We feel it likely that any future need for this type of data base could be met by inclusion and access through the OASIS platform.
Work Group Conclusions and Alternatives
We agree with the workgroup's conclusion that M1FC and ICSS would not support consolidation. But we disagree with the workgroup's theory that either OASIS or a new ICSS system somehow makes consolidation and functional realignment practical. Neither of these two proposed systems address human operational limitations.
The report states that part-timing is the answer to problems associated with facilities that operate at or above funded staffing levels. It is this type of argument that highlights the point we have been trying to make: safety is no longer paramount, budget is. For some time now, service demand has not been the primary concern in funded staffing level determinations. Because there is no pipeline of replacement employees, attrition creates an automatic adjustment of on-board employees. The effect is that on-board staffing becomes authorized, and what authorized is what is funded. Left untreated, this symptom will soon reach alarming levels in many locations, and the ability to service demand will diminish as there are no longer facilities with any excess capacity.
The opinion that "61 AFSS buildings are not required to provide flight services" appears to be the conclusion predicating all others. Since none of the theoretical premises fundamental to this implementation plan have been proven or are timely, it would be irresponsible to rely on their accuracy when planning for the future. A pragmatic review of how the work group arrived at its conclusions reveals that the viability of the alternatives offered to our present AFSS system is speculative. A more prudent and less risky approach to would be to periodically assess information derived from proven and meaningful trend analyses, and not fall victim to endorsing preconceived plans employing conjecture and hyperbole.
Work Group Recommended Alternative
From a safety of operations standpoint, the recommended evolution to 25 to 35 Inflight facilities and 10 to 15 Preflight facilities is illogical. A glaring fact not addressed in the report is the safety degradations associated with expanding geographical responsibilities. Losses in specialists' familiarity with peculiar weather and terrain influences would occur. It is a well accepted physiological fact that lack of repetitive use brings loss of memorized details. Likewise, expansion of general knowledge bases (and the resulting increases in knowledge responsibilities) causes a somewhat proportional loss of specific and detailed memory. The effect on employees is somewhat benign: they become more "generalists." For the pilots who rely on our guidance, it can be much more serious.
Aviation safety risks are further compounded in the central and western pads of the United States. There, weather observations are sparse and terrain is abrupt. Interestingly, these geographical concerns were prime factors in the earlier architecture work group's wise decision not to recommend any consolidation of Alaska's facilities. Throughout the nation though there are hundreds of locations where various weather systems will cause different aviation hazards during different times of the year: theoretically identical storm systems impacting the same locations at different times can have radically different effects on aircraft operations. Slight variances of temperature contrast, wind direction, moisture or upper air movement can cause an entirely different effect on what should be expected on different days with seemingly identical storm systems. Storm systems often change characteristics as they move. Add the variety of terrain influences, and the possibilities seem endless.
The best alternative at this time is to maintain facility status quo,
pending further analysis of all pertinent influencing factors. This would require the
immediate hiring of personnel so as to not further degrade the system. All others
alternatives progressively deteriorate both the quality and the quantity of flight
services to our customers. The flying public suffered enough service degradation with the
last FSS consolidation. Since then, AFSS controllers have lost some of their expert
perspective on these weather nuances. The digression in expertise can be minimized, but
not with further consolidations.
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MINORITY CONCLUSION
We have addressed in this report our concerns with the product of the FSS Future Architecture Workgroup. In any study of this magnitude, there is a plethora of issues that neither can justly be addressed in brevity, nor lend themselves well to written form. We are on record as being in favor of participating in meaningful and objective discussions aimed toward streamlining FAA services to obtain increases in efficiency. We are truly disappointed that the importance of our role in providing employee input to this workgroup was apparently lightly viewed by agency leadership. As the conclusions and recommendations of the group became apparent, our suspicions that the FSS Architecture effort existed solely as a means to justify an already identified end were confirmed. It is now very evident the conclusions were precognitive, apparently orchestrated by some ill-informed and misguided faction within FAA Headquarters. The veiled purpose of the Flight Service Architecture effort is to lend credibility to the systematic self-extinction of the Flight Service Option, without regard for the safety of the general aviation user within the national airspace system.
It is not yet too late to avert a potential irreversibly damaged relationship between the Agency and the public it serves. FAA management must realize that Flight Service controllers have always been its ambassadors to the flying taxpayer. We have existed and nurtured aviation since the dawn of scheduled flight. For pilots of today, we bring a calm, personal humanity into an otherwise cold and authoritarian air traffic system. We are the protectors of that delicate thread connecting a highly visible agency with an increasingly wrathful public.
Our Address:
NAATS 11303 Amherst Avenue Suite 4 Wheaton, MD 20902 301/933-6228 301/933-3902 fax Walter W. Pike, Chief Executive Officer
