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Below please find our response in the format requested, followed by our comments as background information:

OIG Recommendation: Develop a strategy, in conjunction with OASIS deployment, to consolidate the 61 existing Automated Flight Service Stations.

FAA Response: Nonconcur. Even if a comprehensive AFSS consolidation plan could be developed and executed in sufficient time to coincide with Operational and Supportability Implementation System (OASIS) deployment, the concept is not operationally acceptable. Although a consolidation strategy may appear to reap cost savings, a total systems evaluation indicates that any mid-term savings will be outweighed by up-front and long-term costs as well as safety and security risks.

OIG Recommendation: Ensure that consolidation issues are addressed in the current collective bargaining negotiations with NAATS and that provisions of the agreement do not hinder FAA's ability to reduce the specialist workforce.

FAA Response: Concur. Contract agreements should not hinder the possibility of workforce reductions (e.g. part-timing, consolidation) if and when those option(s) are determined desirable and feasible. The "Tentatively Agreed Upon" (TAU) articles of the FAA/NA. ATS contract have been negotiated with the possibility in mind of consolidation and/or part-timing. Negotiations are currently at impasse over pay issues; due to pressing priorities in the aftermath of September 11, further sessions have yet to be scheduled.

Background:

Air traffic control specialists (ATCS) have three certification options: flight service, terminal, and en route. The criticality to the National Airspace System (NAS) of ATCS's serving in the flight service option has become increasingly apparent in the wake of the September 11 events. While flight service ATCS's do not control air traffic, they provide critical support to the control of air traffic. In addition to relaying aeronautical. and weather information to pilots, they provide vital explanations and instruction on the aeronautical, weather, and other critical NAS information. Explanations of airspace restrictions provided by AFSS ATCS's enable two-way exchanges to ensure better understanding by pilots. Pilots on the ground at untowered airfields often rely on flight service station (FSS) or AFSS specialists as the sole means to obtain air traffic control (ATC) clearances. Pilots needing to air-file an instrument flight plan file with an AFSS ATCS, thereby relieving terminal/center controllers from this duty.

Requirements for Direct User Access Terminal Service (DUATS) functionality for the OASIS have not been fully defined, and no date has been established for incorporation of these functions. Improved service to AFSS customers derives from the shared database to which pilots and ATCS's will have simultaneous access, thereby improving pilot/ATCS dialogues. Most DUATS users also contact AFSSs for explanations of information obtained from DUATS.

OASIS does not provide direct pilot access. While the OASIS' ATCS sign-on procedure (access) improves ATCS position flexibility, OASIS has two access levels and provides more options about which the ATCS must be cognizant. The current Model 1 Full Capacity (M1FC) system requires only one sign-on with a predetermined position function, but more limited position flexibility. Rather than a conduit for further consolidation, OASIS is primarily a replacement system for the M1FC system which, due to its age, is unsupportable in both hardware and software. Multiple aspects of information delivery (e.g., Notices to Airmen, Special Use Airspace (SUA) status, Air Traffic Control System Command Center (ATCSCC) Advisories) are inadequately parsed and displayed in the current iteration of OASIS. The FAA is currently pursuing additional methods of disseminating this information.

Although OASIS was designed to permit each AFSS to operate independently, eliminating the need for the current 21 Flight Service Data Processing System (FSDPS) sites and the 2 Aviation Weather Processors (AWP), that independence increases individual facility workload. With the current M1FC architecture, only the 21 FSDPS sites were required to perform software and database loads while with OASIS, each of the 61 sites must perform those functions. Additionally, the database editing functions performed by the two AWPs must be performed at each OASIS site.

Should a decision to consolidate be made today, the OASIS version planned for deployment in June 2002 could not accommodate the complexity and volume of traffic at a consolidated facility. In keeping with FAA's phased deployment approach, the next OASIS version that will be deployed at Anderson, South Carolina, in June 2002 is not the completed version. If the version deployed at Anderson is accepted, it will be deployed to the next 23 sites in the waterfall installation schedule. However, the Anderson version is not designed to meet the needs of more complex, higher activity facilities. After the OASIS completed version is deployed to the 25th site in late 2003, its 6-month In-Service Decision (ISD) assessment will determine its suitability for the remaining AFSSs, and its deployment will begin in mid-2004.

If consolidation were operationally viable, it would take time. The savings figures ($500 million over 7 years) appear to be predicated on unrealistic consolidation timeframes. From concept inception to actual closure of the last CONUS FSS, consolidation to the 61 AFSSs took almost 20 years. Some personnel and equipment costs are complex. Though a large number of AFSS ATCS's are eligible for retirement; many of those eligible have made no commitment to actually retire. Additionally, savings on voice switching contracts may be overridden by the substantial cost of reterminating frequency outlets.

The April 30, 1998, "Flight Service Architecture Core Group Staff Report" was not deemed viable by the Director of Air Traffic. The report did not fully assess the cost of consolidation nor did it assess non-operational ramifications. The report concluded that initial ideas to reduce to 20 sites were not feasible and recommended a phased reduction to a total of 31 AFSSs (26 CONUS air/ground AFSSs plus 5 non-CONUS AFSSs), keeping the remaining AFSSs as preflight facilities, as well as retention of the 14 Alaskan FSSs. The intent was to eventually absorb the preflight facilities into the designated 26 CONUS air/ground facilities. The report also stressed that in order to accomplish this, other actions needed to be accomplished and numerous considerations need resolution.
 

Exhibit B of the "Flight Service Architecture Core Group Staff Report," which lists 20 CONUS AFSS sites with "in-flight responsibilities" could be misleading. All 61 AFSSs have in-flight responsibilities. The 20 listed facilities have additional, dedicated en route advisory service (EFAS) positions (usually equipped with additional weather displays) that are designed to exclusively disseminate and collect real-time weather information. However, ATCS's working in-flight positions at each AFSS provide weather information as well as clearance relay; flight plan acceptance, activation and closure; lost aircraft orientation; and other services. Also, although the report initially designated those 20 "in-flight facilities" to become consolidated facilities, it concluded that 8 of those 20 EFAS facilities would be unsuitable for consolidation due to the condition, age, and size of the facility; lease cost; location in relation to general aviation population; FAA regional affiliation; cost of living; community amenities; amount of air/ground contacts; plus other factors.

The report also recommended to "Identify automation enhancements to support the
training and expanded area knowledge requirements." Prior to beginning position
certification, AFSS ATCS's must pass oral and written exams covering required "Area Knowledge" which include, but are not limited to, idiosyncrasies of weather patterns (due to bodies of water, mountains, etc.), terrain, airport characteristics, law enforcement agencies, airport managers, plus myriad other details specific to an AFSS's defined geographical area of service responsibility. If AFSSs are further consolidated, each AFSS area of responsibility would encompass a much greater region for which an ATCS would need detailed "Area Knowledge." Without the automation to replace the intuitive knowledge that currently resides with the AFSS ATCS, expansion of these areas of responsibility would result in a disservice to the aviation community since an individual would not likely be able to apply the same level of existing detailed "Area Knowledge" for much larger geographical areas. Automation cannot yet replace this ability.