DECLARATION OF KENNETH R. STULTZ

My name is Kenneth R. Stultz, I am currently employed as an FAA Flight Service Specialist in St. Petersburg, Florida, However, the majority of my career with the FAA has been in the terminal or Tower option. Hence, I am able to discuss the similarities and differences between these two positions.

I began my FAA career in 1979, in the Center option. Over the next 23 years, I worked at Chicago Center, Quincy Flight Service, Illinois, Janesville Wisconsin ATCT, and Madison Wisconsin ATCT before transferring to the Flight Service option and being assigned to St. Petersburg. In my 13 years in the Tower option, my duties included trainee, FPL, OJT instructor, Quality Assurance Specialist, Training Specialist, and Acting ATCT manager. In the Flight Service option, I have been a trainee, OJT instructor, and an FPL.

The FAA acknowledges many similarities between these two options, for example, by mandating identical medical, administrative, and substance abuse regulations to both.

In both options the trainee has an area rating. In the Tower option, the Controller must have a general knowledge of the National Airspace System and home state, and detailed knowledge concerning the terminal approach area, namely a 40-mite radius of the airport in the radar environment, and a 5-mile radius of the immediate airport in terms of physical or topographical characteristics. This includes airport names, approaches, and frequencies. This phase of training is generally completed in 2-4 weeks depending on the complexity of the airspace.

In the Flight Service option, the rating is much more extensive. It not only requires detailed knowledge of the National Airspace System, but also a detailed knowledge of the flight plan area for which any given AFSS is responsible, routinely a several hundred mile radius from the AFSS where one is stationed, including physical terrain or topography, all public and private airports (including routine and emergency services available at each, law enforcement information relative to each, length of runways, etc), navigational aids, airways, frequencies, and weather reporting stations. Typically, Flight Service time for completion in this phase is 6-8 weeks. By comparison, the Tower Controller need only master specific information for one airport.

Controllers in both options must obtain their area rating prior to entering training on position. Both options place the highest priority on safety, while training on position. Trainees are taught to prioritize, evaluate each situation and perform the duties required for that situation. The range of situations handled by Flight Service is, however, much greater.

The most difficult aspect of the Tower option training is learning to think three-dimensionally. In the Flight Service option, in addition to mastering an overwhelming volume of information, one must learn to recognize and react rapidly to changing weather situations, and social situations.

Tower Controllers merely give cryptic instructions, mostly to professional pilots. Flight Service Controllers provide critical guidance not only to experienced pilots flying commercial aircraft, but to inexperienced pilots flying all sorts of aircraft. Every conversation is different, depending on the personality and experience of the pilot, type of aircraft, nationality, location, and weather. Learning to size up each caller and then provide customized and appropriate information to each in a professional manner is a critical art-form that every Flight Service Controller must master.

In sum, the Tower trainee learns what s/he needs to know for a discrete and limited area, along with a sense of timing and ability to think three-dimensionally. The Flight Service trainee must master the same detailed knowledge, but instead for scores, sometimes hundreds of airports in a much larger geographic area, and then master communication skills necessary to evaluate each customer, access appropriate resources, and provide critical information depending on each individual situation that vary greatly over the course of a workday.

The two options have, in my opinion, 2 positions in common. The flight data and in-flight/local control positions. At the flight data position, both are responsible for coordination with other facilities, both are responsible for the gathering and dissemination of information, and both are involved in search and rescue procedures. In the Tower option, coordination is limited to facilities and operations in and around the home airport. Search and rescue is restricted to receiving information requests from outside the facility and then to search for an aircraft on the airport premises. In the radar environment, Tower Controllers may provide search agencies with the last known position of the subject aircraft and perhaps help to guide search aircraft.

In the Flight Service environment, the Controller is much more involved and responsible for search and rescue operations. S/he initiates search and rescue procedures on all visual flight rule aircraft within the flight plan area of his or her AFSS facility. In addition, s/he coordinates overlying centers, all towers, approach controls, military installations, and other flight service stations nationwide, law enforcement agencies, emergency services agencies and individual fixed based operations within the flight plan area. The Controller also performs the Clearance Delivery function for aircraft wishing to depart from uncontrolled airports.

In the Tower option, the Controller is either a stand-alone position or combined with the duties of the ground controller. Flight Service Controllers also have to perform this important function in addition to their many other duties.

Search and Rescue procedures for overdue aircraft is a time-consuming and difficult task which is the primary responsibility of Flight Service Controllers; I compare it to the task of a homicide detective. These operations are often initiated by concerned family members assuming the worst. We must analyze all clues such as where the aircraft was supposed to go. We sort through and identify the good, reliable leads and, through the process of elimination, narrow the search. Sometimes, the aircraft can be located with a single phone call, such as when a pilot has failed to report in and confirm that he has safely landed. Other times it involves separately contacting every airport 50 miles on either side of the route of flight, which can require hundreds of calls not only to large and small airfields, but also to the Coast Guard, and numerous law
enforcement agencies. The operation can take several days spanning the entire country.

The in-flight/local control positions in both options are responsible for radio contacts initiated by pilots with the facility. Also, at night, many Towers are unmanned and the Flight Service Controllers must perform essentially the same function as Tower Controllers in terms of the safe and expeditious movement of aircraft into and out of the airport, on a first come first serve basis. However, the Flight Service Controller must perform this function without the benefit of windows, radar, or the ability to use control instructions.

When we provide Local Airport Advisories to pilots, the ability to obtain and issue accurate position reports from involved aircraft and the ability to mentally visualize what is occurring are our only tools.

The Flight Service Controller has as much liability as the Tower Controller, but s/he only possesses half the tools. Despite these handicaps, hundreds of Flight Service Specialists provide this service every night, reliably and with precision. In fact, we are performing this function so well that the FAA is planning to expand the service to remote airports located within the AFSS' flight plan area.

Flight Service Controllers not only spend a great deal of time on the telephone, they also talk with in-flight pilots (both general aviation and commercial) via radio and furnish position and critical real time weather information that Center, Tower, and approach controllers are not equipped or trained to provide.

Both Flight Service and Tower Controllers provide lost aircraft orientations. In absence of radar, both are trained to perform VOR orientations. Both Controllers provide whatever emergency services are necessary or obtain sightings from any available resource, including other aircraft. But Flight Service is the only option that has direction finding equipment which is often the only means by which a lost or disoriented aircraft can be located. This equipment can also serve as an extremely effective aid in assisting the local approach controller to spot an aircraft transmitting in the blind.

When I chose to change options after 13 years in the Tower option, I was hunting for a new and more challenging career. I have not been disappointed. I can tell you from first hand experience that training, mastering, and performing the responsibilities of a Flight Service Specialist has far and away exceeded the challenge I had envisioned for myself.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Dated: July 16, 2002