•J/ 

ToddC. IZmcrson, #8175 

444 South River Road 

Si. George, Utah, 84790 

Telephone: (435)634-3530 

Facsnnile: (435)634-3505 

Bmail: temerson@sky\vest.com 

- and -

Michael L. Dworkin ^64047 

465 California Street, Suite 210 

San Francisco, California 94104 

Telephone:(415) 421-02500 

Facsimile: (415)421-2560 

Email: law@avialex.com 

AUornevs for SkvWest Airlines. Inc. 

:CEfVED 

DEC 2 2 2011 

r r ; 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

en 

en 

In the Matter of: 

SkyWest Airlines, Inc. 

FAA Case No. 2011NM060033 

DMSNo. FAA-201 1-0680 

SKYWEST AIRLINES, INC.'S 

SUPPLEMENTAL AND AMENDED 

RESPONSES TO COMPLAINANT'S 

INITIAL DISCOVERY REQUEST 

Judge: The Honorable Richard C. Goodv/in 

SKYVVFST AIRLINES, INC. (hereinafter referred lo as "SKYWEST"), by and 

through its undersigned counsel, supplements and amends its Responses to Complainant's Initial 

Discovery Request and Production of Documents, previously filed and served on October 11, 
2011. 

INTRODUCTION AND GENERAL OBJECTIONS 

SKYWEST adopts and incorporates as iffully set forth herein, its objections and 

responses made in SKYWEST's Response to Complainant's Initial Discovery Request 

referenced above. 

SKYWEST's investigation is ongoing and continuing and SKYWES'f reserves the right 

to further supplement or amend its responses and objections as its investigation proceeds up 

through the time of hearing. Accordingly, these Supplemental and Amended Responses should 

be considered tentative at best. 

• Finally, SKYWEST, in its Answer and Affirmative Defenses ("Answer") dated July 15, 

2011, and in its First Amended Answer and Affimiative Defenses, filed concurrently with its 

initial Discover)' Response on October 11, 2011. has asserted numerous affirmative defenses and 

reserves the right to assert additionally affimiaiive defenses as they arise. Notwithstanding any 

response or admission contained herein, SKYWEST reasserts each and ever>' affirmative defense 

contained in its Answer, which SKYWES'f incorporates herein by this reference as iffully set 

forth herein. 

INTERROGATORIES 

The objections set forth above are hereby incorporated herein in their entirety. 

Notwithstanding these objections, SKYWEST, based on its information and belief, responds to 

the (ntcrrogatorics as follows: 

2011NM060033/DMS No. FAAO-2011-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Page 2 
Interrogator;' No. 1: Identify by name, address and telephone number all persons whom you 

know to have personal knowledge of the matters alleged in the Complaint. 

Supplemental and Amended Response: 

In addition to those persons previously identified in SKYWEST's previously filed and 

served objections and responses: 

21. Andrew Aycrs, Aviation Safety Inspector, FAA SkyWest CMO; and 

22. Chris Brown, SKYWEST's then-Director of Flight Operations (currently 

Director Aircraft Operations). 444 South River Road, St. George, UT 84790, (435) 634-3000. 

SKYWEST's investigation and discovery are ongoing and continuing, and SKYWEST 

reserves the right to amend and/or supplement these responses up through the date of hearing. 

lntcrrogator>' No. 2: Identify by title, date, author, present custodian, and content, all 

documents, including correspondence, obtained by you or in your 

possession, relating to the assertions in the Complaint, your appeal, your 

answer, and any affirmative defenses which you anticipate raising in this 

matter. See Request for Production No. i. 

Supplemental and Amended Response: 

In addition to those documents previously identified and/or provided in SKY*WEST's 

previously filed and served objections and responses: 

19. Letter dated March 2, 2011, from Chris Brown. Director of Flight Operations 

to Andrew Avers. FAA CMO; 

2011NM060033/DMS No. FAAO-2011-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Paue 3 
20. Letter dated March 4, 2011, from Chris Brown, Director of Flight Operations 

to Andrew Ayers, FAA CMO; 

21. Letter dated May 17, 2011, from Andrew Ayers, CMO to Chris Brown; 

22. Human Factors Policy, FAA Order 9550.8A, Revised August 10. 2005; and 

23. Delta Airlines Flight Operations Manual, 5.6.10-11, Flight Planning—Weight 

Data Record. 

Investigation and discovery are ongoing and continuing, and SKYWEST reser\'es the 

right to amend and/or supplement these responses up through the date of hearing. Finally, 

SKYWEST reserves the right lo utilize at hearing any document not listed above for purposes of 

impeachment. 

Interrogatory' No. 3: Identify by name, address and telephone number, all persons whom you 

intend to have testify as a factual or expert witness in your defense at the 

hearing in this matter, and for factual witnesses, provide a detailed 

summary of each person's anticipated testimony. 

Supplemental and Amended Response: 

Response to Interrogatory No. 3 is amended as follows: 

5. Jeremy Barclay, SKYWEST Director of Safety Evaluation and Security. Mr. 

Barkley will testify as to SKYWEST's investigation ol'the alleged discrepancies, his conduct of 

system-wide audits and SKYWEST's corrective actions, including the expenditure of substantial 

resources in its good faith efforts to prevent recurrent of similar incidents. 

2011NM060033/DMS No. FAAO-2011-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Page 4 
and to add: 

14. Chris Brown will testify that SKYWEST had been in communications with 

its CMO and had requested the CMO for an amendment to its Approved Weight and Balance 

Program, consistent with FAA Order 9550.8A and the Delta Airlines Flight Operations Manual; 

SKYWEST's basis for requesting the amendment; the documents, materials and evidence upon 

which SKYWEST relied in making this request and the CMO's refusal lo permit this amendment 

and the ostensible reasons therefor. 

SKYWES'f further reserves the right to call as its witnesses any persons identified in 

Complainant's EIR's, any persons now or hereinafter identified by Complainant as its witnesses 

and any persons who may be called to testify by Complainant in this matter. 

Investigation and discovery are ongoing and continuing, and SKYWEST reserves the 

right lo amend and/or supplement these responses up through the date of hearing. 

Interroaatory No. 4: [deniify by title, date, author, present custodian, and content, all 

documents which you anticipate offering into evidence at the hearing in 

this matter, and iluough which witness or witnesses. See Request for 

Production No. 2. 

Supplemental and Amended Response: 

Response to Interrogatory No. 4 is amended lo add: 

19. Letter dated March 2, 2011, from Chris Brown, Director of Flight Operations to 

Andrew Ayers, FAA CMO; 

2011NM060033/DMS No. FAAO-2011-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Pas-e 5 
20. Letter dated March 4, 2011. from Chris Brown. Director of Flight Operations to 

Andrew Ayers. FAA CMO; 

21. Letter dated May 17, 2011, from Andrew Ayers, CMO to Chris Brown; 

22. Human Faciors Policy, FAA Order 9550.8A, Revised August 10, 2005; and 

23. Delta Airlines Flight Operations Manual, 5.6.10-11, Flight Planning—Weight 

Data Record. 

In addition, SKYWEST reserves the right to utilize at hearing any documents, records, 

information or materials contained in Complainant's EIR, or any documents, records, 

information or materials introduced into evidence, or sought to be introduced into evidence, by 

Complainant. 

Investigation and discover)' are ongoing and continuing, and SKYWEST reserves the 

right to amend and/or supplement these responses up through the dale of hearing. 

Finally, SKYWEST reserves the right to utilize at hearing any document not listed above 

for purposes of impeachment. 

Interrogatory No. 7: Describe with specificity all of the facts which you anticipate presenting in 

the course of the hearing in this matter pertaining to the avoidance or 

mitigation of the sanction sought by the FAA in this case. 

Supplemental and Amended Response: 

Response to Interrogatory No. 7 is amended to add: 

8. SKYWEST had reasonably requested an amendment to its Approved Weight and 

201 1NM060033/DMS No. FAAO-201 1-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Page 6 
Balance Program, consistent with Complainant's Human Factors Policy, as annunciated in FAA 

Order 9550.8A. and consistent with what Complainant had approved for at least one other air 

carrier, but Complainant unreasonably, arbitrarily and capriciously refused to approve that 

amendment; and SKYWEST's acts, as complained of by Complainant, are mitigable, consistent 

with Complainant's Human Factors Policy: and 

9. SKYWEST's efforts in investigating and preventing recunence of the alleged 

discrepancies and like incidents have been conducted in good faith and at a substantial 

expenditure of resources. 

Investigation and discover)' are ongoing and continuing, and SKYWEST reser\'es the 

right to amend and/or supplement these responses up through the date of hearing. 

Interrogatorv No. 9: Describe with specificity all facts or evidence you intend to rely upon in 

support of any affirmative defenses raised in any Answer to the 

Complaint, lo include identifying the specific FAA policy you claim is 

violated by the proposed penalty in these cases. See Request for 

Production No. 3. 

Supplemental and Amended Response: 

Please see SKYWEST's Responses to Interrogator)' No 7, which SKYWEST adopts and 

incorporates at is responses to Interrogatory No. 9, as iffully set forth herein. In addition see 

FAA AC I20-27E and FAA Orders 2150.3B and 9550.8A. 

Investigation and discovery are ongoing and continuing, and SKYWEST reserves the 

201INM060033/DMS No. FAAO-201 1-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Paae7 
right to amend and/or supplement these responses up ihrough the date of hearing. 

REQUESTS FOR PRODUCTION 

In addition to those documents previously described and produced by SKYWEST in its 

Production of Documents, filed and ser\'ed on October i I, 2011, SKYWEST is producing the 

following responsive documents: 

EXHIBIT DESCRIPTION 

G) Letter dated March 2, 2011, from Chris Brown, Director of Flight 

Operations to Andrew Aycrs, FAA CMO; 

H) Letter dated March 4, 2011, from Chris Brown, Director of Flight 

Operations to Andrew Ayers, FAA CMO; 

I) Letter dated May 17, 2011, from Andrew Aycrs. CMO lo Chris 

Brown; and 

J) Human Faciors Policy, FAA Order 9550.8A, Revised August 10, 

2005. 

With respect lo Delta Airlines Flight Operations Manual, 5.6.10-11, Flight 

Planning—Weight Data Record, said document is proprietary to Delta Airlines. SKYWEST wil 

produce and utilize said document upon Complainant's agreement to a protective order to 

prevent disclosure of said document to any third party(ies) and the Administrative Law Judge's 

issuance of an appropriate order redacting said document from the public record in this matter. 

Investigation and discovery arc ongoing and continuing, and SKYWEST reserves the 

201 1NM060033/DMS No. FAA0-20n-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discover)' 

Paae8 
right to amend and/or supplement these responses up through the dale of hearing. Finally, 

SKYWEST reserves the right to utilize at hearing any document not listed above for purposes of 

impeachment. 

Dated thi.is s (JO^ ^ day of December, 2011. 

MICHAEL L. DWORKIN 

Co-Counsel for SkyWest Airlines 

201INM060033/DMS No. FAAO-201 1-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Page 9 
CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on this c3fy day of December, 2011, a true and 

correct copy of the foregoing SKYWEST'S SUPPLEMENTAL AND AMENDED 

RESPONSE TO COMPLAINANT'S INITIAL DISCOVERY REQUEST was served as 

follows: 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room E12-

320 

Washington, D.C. 20590 

{Federal Express} 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2WIOO0 

{Federal Express J 

Jeffrey M. Ilarpcr 

Federal Aviation Administration 

Northwest Mountain Region, ANM-7 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

FAX (425) 227-1007 

{Facsimile and Federal Express} 

OKSANAZHARZHA^S 

2011NM060033/DMS No. FAAO-2011-0680 

SkyWest's Supplemental and Amended Responses to Complainant's Discovery 

Page 10 
EXHIBIT 19 

Letter dated March 2, 2011, from Chris Brown, Director of Flight 

Operations to Andrew Ayers, FAA CMO 
SMMssf 

March 2, 2011 

Andrew Ayers 

Aviation Safety Inspector - Air Canier Operations 

Federal Aviation Administration 

SkyWest Certificate Management Office 

1020 North Ffyer Way 

Salt Lake Otv,t/T 84116 

RE: Amendment to SkyWest Weight and Balance Program 

Dear Mr. Ayers: 

Hiis letter rs a request for consideration of the enclosed amendment to the SieyWest Airlines Approved 

We^ t and Balance Program. Included is ttie original document with the inclusion of an amendment 

containing Human Factors documentation and FAA Order 95S0.8A, Human Factors Policy. The addition 

of the Human Factors amendment brings the proposal full drde and includes SMS practices based on 

the Four Components of Safety Management Systems. 

While SkyWest recognizes the goal of ensuring safety through CLR accuracy, a Human Factors 

consideration is necessary, SkyWest seeks to employ known Human Factors methods to accomplish the 

ultimate goal of operational safety. Thank you for your consideration. 

Sincerely, 

Chris Brown 

Director of Flight Operations 

cc: Chip Diilds 

Wen Brooks 

Edward Rubottom 

Cari Salamone 

444 South Rh/er Road 

St. George. UT84790 

435.6343000 

www.skywest com 
AIRLINES ® 

Weight and Balance Program 

Amendment Proposal 

March 2, 2011 
This document is a formal request for an alteration to tfie SkyWest Approved Weight and Balance 

Program. This request is designed to address the numerous cargo weight errors that have been 

identified in recent Letters of Investigation (LOI) from the SkyWest Certificate Management Office. 

Internal audits of the weight and balance process reveal that while there is the possibility for a gross 

cargo weight error, most errors result from a miscount of one or two pieces of cargo. 

The SkyWest Flight Operations, Customer Service, and Safety departments have made great strides in 

the construction and Implementation of procedures designed to mitigate gross errors. However, the 

nature of human factors makes the elimination of errors in their entirety an impossible undertaking. In 

this request, SkyWest woukJ like to plan proactivety for small errors in cargo weight by Implementing a 

self imposed limitation on the capabilities of its aircraft. The purpose of this proposal is not to alk^w for 

error, but to account for the inherent limitations of human performance and ensure operational safety 

is held paramount at all times. 

Specifically, this request consists of artificially adding a specified amount of wveight to the Basic 

Operating Weight (BOW) of each aircraft In doing so, all performance calculations will be performed as 

if the weight was physically on board the aircraft, even though in most cases the weight will not be 

physically present The aircraft operating envelope will t>e curtailed in such a way that for small 

miscounts, the SkyWest weight and balance program will ensure that the aircraft will always remain 

within the manufacturer's operating envelope. 

SkyWest has implemented several self Imposed limitations in the past. This proposed limitation is 

similar in nature to these previously approved limitations: 

• The ASAP program recommerided pilots descend immediately upon receiving a crossing 

restriction within 4000* of the current aircraft altitude. By Instructing flight crews to Initiate a 

descent upon receipt of dearar>ce, SkyWest sacrifices additional fuel savings in order to 

minimize missed crossing restrictions. 

• Restricting maximum altitude of aircraft operation to FL370 for the CRJ-200 and FL390 for the 

CRl-700/900. Restricting tfre maximum altitude of CRJ series aircraft provides additional stall 

protection at high altitudes. 

• Amending the maximum takeoff we^trt of the assigned Delta Airitne CR700 aircraft to 74,999. 

Based on the size of ttw aircraft, this proposal adds between 30 and 90 lbs. of additional weight to each 

aircraft BOW. Specifically, adding: 

• EMB 120 = 30 lbs. or 1 standard checked bag 

• CR)-200 = 60 lbs. or 2 standard checked bags 

• CRJ-700= 90 lbs. or 3 standard cfiecked bags 

• CRJ-900= 90 lbs. or 3 standard checked bags 

CRJ 200 Specifics 
The additional 60 lbs. will be artificially added Into tfie BOW at the BOW center of gravity. By adding the 

weight at this location, the additional planned weight will not affect the BOW center of gravity. In the 

event that the planned weight is rwt physically present in the cargo bin, the only performance 

modification is that the aircraft has been planned to be 60 lbs. heavier than the actual weight. In terms 

of performance, the aircraft wiH perform better than planned in all cases (i.e. lower fuel bum, lower stall 

sp)eed, shorter takeoff ar>d landing distances, etc.) and will remain within all manufacturers limitations at 

all times. 

Because the additional weight was planned at the BOW center of gravity, the lack of physical preserice 

will have no effect on aircraft CG or trim settings. 

In the event of a miscount and the additional 60 lbs. of cargo is accidentally present In the cargo bin, the 

additional weight has already been accounted for in the BOW and the only correction required is to 

ensure the additional weight does not cause the aircraft center of gravity to fall outside of 

manufacturer's operating envelope. To guarantee that the CG remains within the operating envelope at 

all times, the aft center of gravity limit will be artificially curtailed forward to compensate for an extra 60 

lbs. in the aft cargo bin. 

Using the formula presented in Figure 1 below, an additional 60 lbs. of cargo in the aft cargo bin will 

shift the index aft by 0.44. 

(Bin XArm - 366.42) x Weight 

= Index Shift 10000 

(687 - 520) X 60 

= 0.44 

23000 

Figure 1: CRJ200 Index Shift Calculations 

To compensate for this possible index shift, the aft operating envek)pe limit will be curtailed forward by 

an index adjustment of 0.44, thus ensuring that regardless of tfie physical presence of the extra 60 lbs., 

the aircraft operational center of gravity will always remain within the manufacturer's operating 

envelope. 

EMB 120 Spedfks 

The calculations for the EMB 120 are very similar to the CRJ 200 t>ecause the EMB has a single cargo 

compartment. The inclusion of an addittonaf 30 fbs. of cargo will cause the aircraft CG to shift the index 

aft by 0.63. To compensate for this possible shift, the aft operating envelope limit will be curtailed 

forward by an Irwiex adjustment of 0.63. 
{Bin XArm - 366.42) x Weight 

— - Index Shift 10000 

(578 - 366.42) x 30 

= 0.63 

lOOOO 

Figura 2: EMB120 index Shift Calculation 

CRJ700/900Spcdfics 

The CRJ 700 and CRJ 900 are dissimilar fi^om the CRJ 200 and EMB 120 because the CRJ700 and CRJ900 

are both equipped with multiple cargo compartments. In order to compensate for multiple 

compartments, both the aft and forward limits will be curtailed by the most adverse bading 

configurations. The tables below show that depending on the placement of additional weight, the net 

index shift is either forward or aft. To compensate for the unknown location of the 90 lbs. additional 

weight, both the forward and aft CG limits will need to be curtailed by the maximum Index deviation. In 

the case of the CRJ 700, tfie forward operating envelope limit will need to be shifted aft by an index 

adjustment of 0.48 while the aft operatirig envek}pe limit will need to be shifted forward by arx! index 

adjustment of 0.60. In the case of the CRJ 900, the forward operating envelope limit wvill need to be 

shifted aft by an ir>dex adjustment of 0.75 while the aft operating envelope limit will need to be shifted 

forward by and index adjustment of 0.74. 

The formulas and loading configurations are given in the tables and figures t>etow. 
(Bin XArm - 860) x Weight 

- Index Shift 

40000 

Figure 3: OUTOO Index Shift Cakulation 

OU700 

FWD Cargo Bin (lbs.) 

0 

30 

60 

90 

FWD Index Shift 

0.00 

-0.16 

-0.32 

-0.48 

AFT Cargo Bin (lbs.) 

90 

60 

30 

0 

Aft Index Shift 

0.60 

0.40 

0.20 

0.00 

Total Index Shift 

0.60 

0.24 

-0.12 

-0.48 

Table 1: CRJ 700 Index Shift Calculations 

{Bin XArm - 771) X Weight 

= Index Shift 

40000 

Figure 4: CIU900 index Shift Calculation 

CRJ 900 

FWD 

0 

0 

0 

0 

30 

30 

30 

60 

60 

90 

FWD Shift 

0.00 

0.00 

0.00 

0.00 

-0.25 

-0.25 

-0.25 

-0.50 

-0.50 

-0.75 

Center 

0 

30 

60 

90 

0 

30 

60 

0 

30 

0 

Center Shift 

0.00 

-0.14 

-0.27 

-0.41 

0.00 

-0.14 

-0.27 

0.00 

-0-14 

0.00 

AFT 

90 

60 

30 

0 

60 

30 

0 

30 

0 

0 

Aft Shift 

0.74 

0.49 

0.25 

0.00 

0.49 

0.25 

0.00 

0.25 

0.00 

0.00 

Total Shift 

0.74 

0.35 

-0.03 

0.41 

0.24 

-0.14 

-0.52 

-0.25 

-0.64 

-0.75 

Table 2: CRJ 900 Index Shift Calculations 
SkyWest would like to reiterate that the purpose of this program is not to alksw for error. It will, 

however, ensure that operational safety is maintained in any small miscount situations caused by the 

limitations of human performarKC. A similar program has already been put in place at Delta Airiines. 

The SkyWest phlk>sophy has been and remains Safety first, with tf\at In mlr>d it Is our hope for rapid 

consideration and approval of this request 
Human Factors Appendix to Weight and Balance Proposal 

The above proposal involves a modification to the SkyWest Weight and Balance program and Is designed 

to account for limitations on human pertormarKe. In order to fully understand the moth/atk>n and 

reasoning t>ehind such a proposal, it Is Important to Investigate tire Human Factors prirKHples driving this 

request. 

Human Factors is a term used to describe the study of any system that irwJudes a human irrterface. This 

interface can indude all 'psychohjgical, social, physical, biok>gical and safety characteristics' (1) that 

may affect the manner in which a human interacts %vith a system. 

Human Factors is defined as "A multidisoplinary effort to generate arxJ compile infonnation about 

human capabilities and limitatiorts and apply that information to equipment, systems, facilities, 

procedures, jobs, environments, training, staffing, and personr»el management for safe, comfortable, 

and effective human performarKe". (2) 

This proposal investigates the susceptibility for error In the SkyWest Airiines weight and balarnze 

processes, artd proposes to mitigate the risk of any small mtsoount errors through the use of a built in 

weight tolerance- In order to fully understand the risk associated with the current weight and balance 

process, we need to analyze the working environment on the aircraft ramp area. 

The aJriine ramp area contains many factors having the potential to negatively impact ramp worker 

performance. The task in question Is the ramp worker's ability to accurately report the quantity and 

type of items loaded into the aircraft cargo bin(s). SkyWest aircraft are equipped with up to three 

separate cargo bins, each requiring an individual inventory. The ramp worker is tasked with the 

responsibility of accounting for each item as it is loaded onto the aircraft. In Human Factors studies, this 

type of task Is referred as a "Vigilance" task, whereas Xbe human operator is asked to maintain "ctose 

and continuous attention to a field of stimulation for a period of time, watchful for any particular 

changing circumstances" (3). In this case, the partkular stimulation Is the items loaded into the aircraft 

cargo bin. Human Factors research has shown that environmental stressors may negatively impaa 

human vigilarKC performance. Environmental stressors affecting ramp vigilance performarKe indude: 

ambient temperature, ambient noise, level of illumination, air quality, and current weather conditions. 

The result of these factors is that the ramp agent working on a sixty degree, sunny day in Los Angeles 

will likely perform at a higher level than the ramp agent working a co\d, snowy, night in Chicago. In the 

airline buslr>ess, a difficult working erwlronment Is sometimes unavoidable, and the system must be 

desigf»ed in a way that will mitigate this risk and prevent error. 

The use of automation is well documented in Human Factors research as a successful error prevention 

strategy. AltfKHigh current techrwbjgy exists to aid in aircraft load manifest error prevention, it is rwt 

feasible for implementation In the SkyWest system. SkyWest does not control the parent polkJes and 

procedures cor»structing ttie ftarT>ework of the cargo process. These policies and procedures are 

managed by SkyWest's major alriine partners (I.e. Delta Airiines, United Alrllr>es) and the introduction of 

automation woukJ require global cftanges at all levels of the major airiine's operation. 
Without the use of automation, the alternative is to investigate error prevention and / or mitigation 

strategies. Any human interface encompasses a liat>ility for error. As an example, "many headlinehitting disasters of the last 15 years have involved human error In the operation of complex 

techrwlogtcal systems. Hollnagel [5L for example, estimates tfiat the irKiidence of human error 

contributing to accidents has risen from about 20% in the igSCs to about 80% in 1990' (4). As systems 

in general t)ecome more complex and become more mechanically reliable, the portion of risk 

attributable to human error also increases. This position has led many researchers to advocate the 

need for what has been referred to as Designing for Human Error [16 J" (4), These systems are 'designed 

with the understanding tfiat human operators are inherently fallible, but careful system design can often 

allow them to catch and recover their own errors, or 'trap" the error so that it is not propagated to 

create an accident" (5), SkyWest Airiines Is limiting the capabilities of its aircraft in order to design a 

more robust system that will "trap" an error and mitigate the consequerKes of a small miscount error, 

should or>e occur. 

The FAA has accepted ar>d embraced the idea that Human Factors plays a key part In system design. 

FAA Order 9550.8A outlines the responsibility of all FAA oi^anizations to 'Implement error prevention 

and mitigation strategies to emphasize human error reduction' (2). The appendix to FAA Order 9550.aA 

even recommends the study of human error and gives the following guidance regarding human error: 

[Examine] design and contextual conditions (including supervisory and organizational 

influences) as causal factors contributing to human error, and [consider] objectives for 

error tolerance, error prevention, and error correction/recovery. (2) 

The FAA incorporates this concept in Safety Management System (SMS) design. One of the four pillars 

of SMS Is Safety Risk Management (SRM). As defined by the FAA, SRM is a formal process within the 

SMS composed of (7): 

• Describing the system 

• Identifying the hazards 

• Assessing the risk 

• Analyzing the risk 

• Controllir^ the risk 

In this proposal, SkyWest has followed the safety risk management process and plans to control risk 

through the design of a human error tolerant system. The use of an error tolerant system is also already 

in place at other U.S, air carriers. Delta Airlines currently uses a 600 lb. tolerarKe to account for "last 

minute bag change flexibilitV (6). In the DAL program, 'If the number of additional bags kaaded after 

the initial [Weight Data Record] is less than 20, there will be no up-dated (Weight Data Record] 

gerrerated and the crew will not be informed* (6). SkyWest is proposing a 30, 60, or 90 lb. tolerance, 

which Is five to fifteen percent of the tolerance afforded to Delta Airiines. SkyWest does not plan to use 

the tolerance for bag change flexibility. Instead, SkyWest plans to use the tolerance to compensate for 

small miscount situations caused by limitations on human performance. 
These small miscounts may be reflected In one of two ways. The error may be either a physical 

miscount or a documentation error. In either event, the design of this error tolerant system 

encompasses known Human Factors prirKiples designed to 'trap" the error. This ensures that any 

errors are caught before they t>ecome contributing fartors to an aircraft incident or accident. 

Incorporating Human Factors principles in system design is a key factor in successful air carrier safety 

management Through the approval of this proposal, SkyWest seeks to increase the safety of all 

operations. 
References 

1. Adams, Chris. "Human Factors.' About.com, n.d. Web. 1 Mar 2011. 

<http ://ergor>om ics.a bout .com/od/gkjssary/g/defh umanfactors-htm >. 

2. Human Factors Policy FAA Order 9550.8A., 2005. Web. 1 Mar 2011. 

<http://www.hf.faa.gov/docs/508/docs/HForder.pdf>. 

3. "Vigilance." SKYbrary, n.d. Web. 1 Mar 2011. <http://www.skvtM"ary.aero/index.php/Vigrlance>. 

4. Fields, R.E., P.C Wright, and M.D. Harrison. "A Task Centered Approach to Analysing Human 

Error Tolerance Requirements." BAe Dependable Computing Systems Centre and Human 

Computer Interaction Group, n.d. Web. 1 Mar 2011. 

<http://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.57.4219&rep=repl&type=pdf>. 

5. Wickens, Christopher D., John D. Lee, Yill Liu, and Sallie E. Gordon Becker. An Introduction to 

Human Factors Engineering. 2nd ed. Upper Saddle River, New Jersey: Prentice Hall, 2004. Print. 

6. "Delta Airiirres Flight Operations Manual. 

7. "Safety Management System -Components." FAA.gov. FAA, 12 Nov 2009. Web. 2 Mar 2011. 

<http://www. faa. gov/a bout/I nibatives/sm s/expla ined/com pen ents/ffsa fety_ri sk_m3 nagement> 

10 
EXHIBIT 20 

Letter dated March 4, 2011, from Chris Brown, Director of Flight 

Operations to Andrew Ayers, FAA CMO 
March 4, 2011 

Andrew Ayers 

Aviation Safety Inspector-Air Carrier Operations 

Federal Aviation Administration 

SkyWest Certificate Management Office 

1020 North Flyer Way 

Salt Lake City, UT 84116 

Re: 14 CFR §121.693 

Dear Mr Ayers: 

Thank you for taking the time to meet with our group yesterday afternoon. We have reviewed 

14 CFR §121.693 and believe the requested tolerance will not, in fact, violate the intent of this 

regulation. As discussed, this request is not an attempt to subvert the regulation; rather, it is an 

effort to build in an additional layer of safety. SkyWest is proposing to self-limit the capacity of its 

fleet; a point we feel must be emphasized during the course of these discussions. 

While the intent of 14 CFR §121.693 is to assure safety through accuracy, we feel strongly there 

should also be a path to account for human error and mitigate risk caused by such error. 

On average, SkyWest handles an estimated 23,000,000 bags per year. This volume elevates 

the risk of a small miscount. The efforts to control risk are ongoing and remain a top priority. 

While we strive for accuracy, the sheer volume of manually-handled items makes it impossible 

to assure a£»so/t;te accuracy. 

This proposal is not a substitute for new and enhanced Customer Service procedures. Rather, 

it is designed to augment other procedures via the addition of an additional layer of defense. 

We provide the following brief explanation to § 121.693 (comments highlighted in red): 

§ 121.693 Load manifest: All certificate holders. 

The load manifest must contain the following information regarding aircraft loading at takeoff 

time: 

(a) The weight of the aircraft, fuel and oil, cargo and baggage, passengers and crewmembers. 

A load manifest error is never intentional. When a designated loading agent signs and 

submits the CLR to the flight deck crew, it is his or her belief the document is accurate. Any 

inaccuracy is due to human error; certainly, there is no intent of falsification. 

(b) The maximum allowable weight for that flight that must not exceed the least of the following 

weights: 
Andrew Ayers 

March 4, 2011 

Page 2 

(1) Maximum allowable takeoff weight for the runway intended to be used (including 

corrections for altitude and gradient, and wind and temperature conditions existing at the 

takeoff time). 

(2) Maximum takeoff weight considering anticipated fuel and oil consumption that allows 

compliance with applicable en route performance limitations. 

(3) Maximum takeoff weight considering anticipated fuel and oil consumption that allows 

compliance with the maximum authorized design landing weight limitations on arrival at 

the destination airport. 

(4) Maximum takeoff weight considering anticipated fuel and oil consumption that allows 

compliance with landing distance limitations on arrival at the destination and alternate 

airports. 

In the event of error within the weight tolerance, the BOW adjustment will ensure these 

limitations are not exceeded. 

(c) The total weight computed under approved procedures: 

The SkyWest Weight and Balance Manual contains approved procedures for computing 

aircraft weight. This proposal makes no changes to the manner in which aircraft weight is 

calculated. 

(d) Evidence that the aircraft is loaded according to an approved schedule that ensures the 

center of gravity is within approved limits. 

The curtailment associated with this proposal will ensure that, even in the event of human 

error, the aircraft's center of gravity will always remain within limits. 

(e) Names of passengers, unless such information is maintained by other means by the 

certificate holder. 

No change 

We appreciate your continued effort in assisting SkyWest to appropriately meet or exceed 

required regulations and guidelines. Feel free to contact me if I can provide additional 

information. 

Sincerely, 

Chris Brown 

Director 

Flight Operations 
EXHIBIT 21 

Letter dated May 17, 2011, from Andrew Ayers, CMO to Chris Brown 
& 

USDepartmem 

c^ Thonsponarion 

F*d«ral Aviation 

AdmtnfstTQtton 

Northwect Mountain Region 

Cotorado, Idaho, Montane, 

Oregon, Utah, Washington, 

W>oniing 

SkyWest Certificate Management Office 

1020 ^^orth^yef Way 

Sart Lake Ctty, Utah 84116-2959 

801-257-5100. 600-332-2795 

Fax; 801-257-5138 

May 17, 2011 Tracking Number: 2352 

Christopher C. Brown 

Director of Aircraft Operations 

SkyWest Airlines, Inc. 

444 South River Road 

St. George, Utah 84790-2086 

Dear Mr. Brown: 

The SkyWest Certificate Management Office (CMO) has reviewed your proposal for 

an amendment to SkyWest's approved weight and balance program. We recognize 

and appreciate the time and effort spent in developing new strategies to address and 

reduce the documented issues with aircraft loading and documentation accuracy. 

Through collaborative review with Federal Aviation Administration (FAA), Northwest 

Mountain regional specialists, as well as FAA headquarters groups, we have 

identified the following issues: 

1) Title 14 of the Code of Federal Regulations (14 CFR) § 121.693(a) requires 

the load manifest to contain the weight of the aircraft, as well as cargo and 

baggage. Under SkyWest's proposal, the load manifest would not comply with 

14 CFR § 121.693(a), even rf the airplane were loaded conreclly, because of 

the built-in "error". Additionally, 14 CFR § 121,665 states, in part, that the 

certificate holder is responsible for the accuracy of the load manifest form 

before each takeoff. Therefore, the preparation of the load manifest cannot 

begin with a pre-existing error, making it impossible to achieve accuracy. 

2) Current FAA guidance does not address the concept of baggage count or 

weight tolerances. Latitude is already given in FAA Advisory Circular 120-27E 

for the use of average bag and passenger weights. These weights are 

designed to create a baseline standard and establish safe operating 

procedures in the event of small variances in weights. The concept of an 

additional tolerance would likely require SkyWest to revert first, to using actual 

bag and passenger weights, or using higher average weights to remove the 

additional small variances that exist with the current statistically derived FAAapproved average weights. 
3) SkyWest's proposai does not address the underlying issue of inacx:urate 

performance by Ground Service Agents handling SkyWest flights. Absent 

other mitigating strategies, SkyWest Airiines' proposal would not reduce the 

errors previously identified by the SkyWest CMO. SkyWest's proposal, as it 

stands, is not a human factor mitigation strategy, but a human factor 

compensation strategy. 

Additional FAA surveii\ance data, as well as various voluntary program data, 

continue to show errors well outside the scope of tolerance that SkyWest has 

proposed. As such, SkyWest's proposal does not show a significant improvement 

in the safety of current weight and balance-related operations. Therefore, the 

CMO cannot approve SkyWesf s proposed amendment at this time. 

Sincerely, 

- ^ Andrew J. Ayers 

Principal Operations Inspector 

cc: Klen P. Brooks, Vice President of Flight Operations 
Q 

USDepanment 

c'lransporfcrriofi 

F«<torQl Avkmon 

Administration 

Norttiwest Mountain Region 

Cotorado, (daho, Montana, 

Oregon, Utah, Washtngton, 

W>omng 

SkyWest Certfflcate Management Offloe 

1020 North Flyer Way 

Saft Lake Ctty. Utah 84116-2959 

801-257-5100. 800-332-2795 

Fax; 801-257-5138 

May 17, 2011 Tracking Number; 2352 

Christopher C. Brown 

Director of Aircraft Operations 

SkyWest Airlines, (nc. 

444 South River Road 

St. George, Utah 84790-2086 

Dear Mr. Brown: 

The SkyWest Certificate Management Office (CMO) has reviewed your proposal for 

an amendment to SkyWest's approved weight and balance program. We recognize 

and appreciate the time and effort spent in developing new strategies to address and 

reduce the documented issues with aircraft loading and documentation accuracy. 

Through collaborative review with Federal Aviation Administration (FAA), Northwest 

Mountain regional specialists, as well as FAA headquarters groups, we have 

identified the following issues: 

1) Title 14 of the Code of Federal Regulations (14 CFR) § 121.693(a) requires 

the load manifest to contain the weight of the aircraft, as well as cargo and 

baggage. Under SkyWesfs proposal, the load manifest would not comp(y wrth 

14 CFR § 121.693(a), even rf the airplane were loaded correctly, because of 

the built-in "error^. Additionally, 14 CFR § 121.665 states, in part, that the 

certificate holder is responsible for the accuracy of the load manifest form 

before each takeoff. Therefore, the preparation of the load manifest cannot 

begin with a pre-existing error, making it impossible to achieve accuracy. 

2) Current FAA guidance does not address the concept of baggage count or 

weight tolerances. Latitude is already given in FAA Advisory Circular 120-27E 

for the use of average bag and passenger weights. These weights are 

designed to create a baseline standard and establish safe operating 

procedures in the event of small variances in weights. The concept of an 

additional tolerance would likely require SkyWest to revert first, to using actual 

bag and passenger weights, or using higher average weights to remove the 

additional small variances that exist with the current statistically derived FAAapproved average weights. 
3) SkyWest's proposal does not address the underlying issue of inaccurate 

performance by Ground Service Agents handling SkyWest flights. Absent 

other mitigating strategies, SkyWest Airlines' proposal would not reduce the 

errors previously identified by the SkyWest CMO. SkyWest's proposal, as it 

stands, is not a human factor mitigation strategy, but a human factor 

compensation strategy. 

Additional FAA surveillance data, as well as various voluntary program data, 

continue to sfiow errors well outside the scope of tolerance that SkyWest has 

proposed. As such, SkyWest's proposal does not show a significant improvement 

in the safety of current weight and balance-related operations. Therefore, the 

CMO cannot approve SkyWesf s proposed amendment at this time. 

Sincerely, 

^^ Andrew J. Ayers 

Principal Operations Inspector 

cc: Klen P. Brooks, Vice President of Flight Operations 
Human 

EXHIBIT 22 

factors yoUc},'^'^ 
Human Factors Policy 

FAA Order 9550.8A 

[Rev: August 10, 2005J 

1. PURPOSE, This order establishes policy, procedures, and responsibilities for incorporating 

and coordinating human factoR considerations in Federal Aviation Administration (FAA) programs 

and activities to enhance aviation safety, capability, efficiency, and productivity. 

2. DISTRIBUTION. This order is distributed to the division level in Washington, regions, 

and centers with a liniiled distribution to all field offices and facilities. 

3. CANCELLATIONS. This order supercedes FAA Order 9550.8 dated October 27, i 993, 

which is canceled. 

4. EXPLANATION OF CHANGES. This order clarifies the meaning of human factors 

considerations, provides the background for the human factors approach, and establishes basic 

policy and responsibilities for incorporating human factors in agency functions. 

5. DEFINfTIONS. 

a. Human Factors. Within the FAA, human factors entails a muUidisciplinaiy effort to 

generate and compile infonnation about human capabilities and limitations and apply that 

information to equipment, systems, facilities, procedures, jobs, environments, training, staffing, and 

personnel management for safe, comfortable, and effective human performance. 

b. Appendix 1, Human Factors Study Areas, provides a list of elements that fijrther 

identify the scope of hiunan fectors considerations for study, analysis, and resolution. 

c. Appendix 2, Definitions, provides descriptions of other key terms used in this order. 

6. BACKGROUND. 

a. The human factor has been widely recognized as critical to aviation safety and 

effectiveness. In the July 1988 report entitled "Safe Skies for Tomorrow," the U.S. Congress Office 

of Technology Assessment concluded that long-term improvements in aviation safety will come 

primarily from human factors solutions. Further, such solutions will be established through 

consistent, long-term support for human factors research and development, analysts, and the 

application of human factoid infonnation. Subsequent to the Office of Technology Assessment 

report. Congress enacted the Aviation Safety Research Act of 1988 (PL 100-591) calling for the 

FAA to augment its research effort in human fartors and ensure cooniination with other agencies 

performing such research. These assessments and directions resulted in the FAA's emphasizing 

new and coordinated efforts in the area of human factors with the National Aeronautics and Space 

Administration, Department of Defense, and a multitude of professional aviation and technical 

groups whose members include pilot and controller unions, airfiramc and parts raanufacturcrs, as 

well as major airiines. One product of such efforts includes the "National Plan for Civil Aviation 

Human Factors" which outlined a coherent national agenda aimed at achieving progress toward 

safety and productivity goals, increased coordination, funding, aiul long-term, high level 

Page 1 
management support in government and industry. Subsequent to establishing the National Plan, the 

application of human factors research and engineering has gained continued attention and emphasis 

in aviation certification, regulation, operations, and acquisitions. 

b. Benefits derived from ttiis systematic approach to human factors research and 

engineering include; 

1) hicreascd persormel efficiency, effectiveness, and productivity; 

2) Improved system performance and usability; 

3) Reduced operations and maintenance costs; 

4) Increased availability of objective data in formulating FAA policies, standards, 

regulations, and business case and investment decisions; and 

5) Enhanced aviation safety. 

7. SCOPE: This order establishes a policy to foster an integrated human factors program that 

meets FAA Itw^ and short range needs covering both research and engineering applications. The FAA 

Human Factors Policy Order supports regulation and operation of the National Airspace System by 

providing an agenda for the conduct and irtstitutionalization of human factors activities relative to 

achieving regulatory goals and objectives, executing research and development programs, facilitating 

Capital Investment Plan acquisitions, and responding to operational mission performance requirements. 

8. OBJECTIVES, The human factory-oriented approach is to: 

a. Conduct the planning, reviewing, prioritization, coordination, generation, and 

updating of valid and timely human factors information to support agency r>eeds; 

b. Develop and institutionalize formal procedures that systematically incorporate 

human factors considerations into agency activiu'es; and 

c. Establish and maintain organizational infrastructure that provides the necessary 

human factors expertise to agency programs and activities. 

9. HUMAN FACTORS COORDINATING COMMITTEE. This oMcr prescribes the 

organization, composition, functions, and responsibilities of an intra-FAA committee to coordinate 

the generation, distribution and explication of human faciors infontution through a representative 

Human Factors Coordinating Committee as stated in Appendix 3, Human Factors Coordinating 

Committee. The committee will serve to enhance the identification of human factors requirements, 

facilitate the integration of human factors into activities within the agency, promote the 

improvement of existing policies and processes, and monitor the efficacy of human factors efforts 

within FAA. 

10. HUMAN FACTORS POLICY. Human factors shall be systematically integrated into the 

planning and execution of the functions of all FAA organizational elements and activities associated 

with National Airspace System ac:quisitions and operations. 

FAA organizations shall emphasize human factors and usability considerations to enhance system 

performance and capitalize upon the relative strengths of people and machines. These 

considerarions shall l>e integrated at the earliest phases of FAA projects and incorporated within the 

processes for fulfilling OMB Exhibit 300 requirements. The FAA's Human Factors Policy Order is 

Page 2 
achieved through a human-eentcred emphasis in operations^ research, applications, and infiastnicturc 

siq^wrt resulting in safe and effective human-system interfaces. Program managers shall employ 

human factors research and engineering best practices to acquire systems that require minimal 

stafTmg, provide cost-effective training, allow efficient operation and maintenance, and are 

operationally suitable within the intended environment. 

Human performance shall be integrated into procedure development, system performance 

evaluation, rulemaking, system acquisitions (including business and administrative systems), 

architecture engineering, and other activities within the agency. 

Human factors considerations and human-system performance data shall be an integral element of 

and incorporated into activities aj>d decisions related to mission analyses and mission need 

statements, performance baselines and measures, safety risk management analyses, investment 

analyses and reports, requirements documents, program plans, source selection criteria, design 

reviews, test and evaluation plans and reports, implementation plans, and post-deployment 

assessment plans and reviews. 

FAA organizations shall cause to be available for their programs the essential information required to 

integrate human factors considerations aj^ropriately and successfully, inter alia: 

• How human factors research and engineering is organized and accomplished (e.g., personnel 

and funding resources; organization, roles, and relationships; human factors plans or road 

map; roles, content, and purpose of human factors working groups) 

• (Quantitative human performance measures and criteria 

" Human factors risks and means/methods to mitigate them 

• Life cycle costs and benefits including staffing and training 

• Analytical methods and technical tools to conduct human &ctors activities 

• Conventions, guidelines, and standards needed to apply human factors 

* Measures, databases, and related information on human-in-the-loop operational performance 

• Results from human-in-thc-kx>p analyses, modeling, simulations, demonstrations, and 

• Lessons learned about addressing human factors in FAA programs (e.g., in requirements, 

investment analysis, research, analysis, design, specifications, statements of work, source 

selection criteria, test and evaluation, post-deployment assessment) 

for research and engineering programs and applications. 

11. RESPONSIBILITIES. 

ILI All FAA Organizations: 

To ensure that human factors are systematically included in FAA endeavors. Assistant and 

Associate Administrators, Executive Directors, and Air Traffic Organization Vice Presidents shall 

establish and assign responsibilities to accomplish the policy and objectives cited in Paragraphs 8 

(Objectives) and 10 (Human Factors Policy) within their organizational purview, to include; 

a. Execution. Conduct activities to: 

• Apply human fectors information and methods to FAA system acquisitions, operations. 

Page 3 
ccrtificaiioo, and regulatory activities in the promotion of civil aviatiorL 

Ensure operational human performance constraints and enhaiKemcnts are routinely 

irK»rporatcd in missi<m analysis and capability/requirements determination processes, life 

cycle cost aiKl beoefit analyses, risk assessments, system operational performance 

specificaticms, system baseline measurements, solicitation package preparation and source 

evaluation, system critical operational issues and criteria (as well as measures of 

effectiveness and measures of performance), operational test and evaluation plans, program 

reviews, post-contract activities, program implementation, arxl post-deployment 

assessments. 

• Acquire necessary human performance information by means of the research, 

engineering, and development processes. 

• Assess the supportability and affordability of human resource requirements (e.g., staffing 

and training) to meet plans for the future NAS architecture and systems. 

• Implement error [wevention and mitigation strategies to emphasize hiunan error reduction. 

- Integrate human factors into fault tree analyses and other risk management techniques for 

(^>eration and maintenance activities. 

• Assess and report on usability so as to identify and enable resolution of human factors 

issues throughout a product's lifecycle, to include coordinating with appropriate 

authorities on issues related to accessibility and accommodation for people with 

disabilities and special needs. 

b. Human Factors Coordinator. Designate a Human Factors Coordinator who will 

perform, direct, or assist in: 

• Serving as the organization's representative to the Human Faciors Coordinating 

Committee 

• Defining human factors risks and mitigation plans during mission analysis, investment 

analysis, and requirements determination. 

• Identifying himian-system interfaces and computer-human interfaces for market surveys, 

trade studies, and prototypes. 

• Preparing and updating human factors portions of acquisition and engineering 

managen>ent plans, procurement packages, test and evaluation plans, performance 

measures and criteria, and data collection efforts. 

Developing and analyzing operational scenarios, human-system modeling, and hiunanin-the-loop simulations for operators and maintainers. 

• Reviewing and assessing human factors concepts and designs (e.g., in requirements 

reviews, system reviews, product reviews, change proposals). 

Coordinating human factors engineering efforts and user working group activities. 

Coordinating human factors in training development, integrated logistics support, safety, 

configuration management, and other system engineering fimctions. 

C System EngiQeering. Establish mechanisms to incorporate human factors risk 

considerations in system engineering plans, products, functions, and activities at the product, 

service area, and National Airspace System architecture level. 

d. Safety Management System. Include human factors considerations in safety 

management system plans, programs, projects, fimctions, activities, and risk assessments. The 

Page A 
necessary components to incorporate human factors into the definition, development, 

implementation, and monitoring of safety management system risks irulude: 

• The scope of human factors areas of interest 

• Tools and techniques used, aiKl thcrr frequency of use 

• Data arid databases used, and their quality and availability 

• Metrics and measures used, and how they arc scored 

• Standards and conventions used, and compliance with them 

• Principles and guidelines applied, and bow widely they are followed 

• Policy ar>d processes implemented, and to what degree they are executed 

• Lessons learned and best practices followed, and how consistently they arc employed 

e. Program Performance Measurement Establish mechanisms by which to continuously 

improve the human factors program across the stakeholders, customers, internal business processes, 

and learning and growth perspectives using program performance tneasurcs and tools such as the 

human factors balanced scorecard approach. 

t Processes and Procedures. Establish arul apply: 

Processes and procedures that systematically identify the human factors expertise essential 

to applying human &ctors to acquisition, operations, oertificaticm, and regulatory activities. 

• Mechanisms by which agency long range planning initiatives incorporate forecasts with a 

human dimension. 

g. Education and Tnuning. Support, participate in, and conduct 

• Managerial and executive level awareness training for human factors. 

Program management team and engineering staff technical training for management of 

human factors in acquisition and operations. 

Operational level human factors familiarization training. 

Academic-Industry-Govemmcnt coordination and technology transfer on the application of 

human factors. 

Professional training and education for human factors coordinators and support employees 

on topics and issues related to the human factors discipline. 

h. Staffing, Facilities, and Funding. Plan and conduct resource activities to ensure: 

• Accessibility of human Victors specialists for analysis, design, evaluation, and 

implementation activities throu^rout the agency. 

Availability of human factors quality control persormel for oversight, direction, and support 

Adequate hmding for human factors technical support 

• Sufficiency of funding for human performance research, engineering, and data collection 

projects. 

• Availability of sufficient research subjects and access to facilities so as to ensure the 

scientific validity of a^^Hoved research and studies. 

1 1 ^ Human Factors Research and Engineering Division. The Human Factors Research and 

Engineering Division enhances the safety and efficiency of the NationaJ Airspace System by 

managing human factors aviation research for the agency, coordinating activities for the human 

factors "community of practice" across the agency, and providing hum^i factors support to research 

Page 5 
and engineering activities within the Air Traffic Organization Operations Planning service area and 

other organizational elements as appropriate. The Program Director for Human Fetors serves as 

the principal advisor on human factors research and engineering to the Administrator, the Air 

Traffic Organization Chief Operating Officer, and the Federal Acquisition Executive. The 

functions of the Human Factors Research and Engineering Division arc organized as follows: 

. Principal advisor and focal point to the FAA Administrator, Air Traffic Organization Chief 

Operating Officer, and the Federal Acquisition Executive on human factors agency research and air 

i 

Operating 

traffic management engineering. 

a. Acts as the human factors focal point within and outside the agency for FAA human factors 

research management human factors policy, and broad Air Traffic Organization human fetors 

engineering applicatioas. 

b. Provides recommendations and advice on human factors research and engineering to the FAA 

Administrator, Air Traffic Organization Chief Operating Officer, and Federal Acquisition 

Executive as rcquired. 

c. Provides human factors guidaiKC, direction, sponsorship, and representation to internal and 

external, national and international FAA work groups, committees, symposia, and conferences. 

d. Ensures human factors are integrated in other FAA organizations' activities as appropriate. 

n. Manages FAA Human Factors Research, Engineering, and Development Program. 

e. Serves as Human Factors Research Program Manager and provides strategic, budgetary, and 

technical direction for agency resource Research, Engineering, & Development planning and 

executiorL 

f Performs technical quality assurance for human factors research. 

g. Ensures coordination and integration between research and application areas (Le., acquisition, 

certification, regulation, and standards). 

h. Serves as [wimary inlerfece on human factors for Research, Engineering, & Development air traffic 

management and safety programs with domestic and international agCTcies such as Department of 

Defense, National Aeronautical Space Administration, and Eurocontrol. 

i. Serves as the Designated Federal Official for the Research and Development Advisory Committee 

Sutjcommittce on Human Factors. Also, provides human factors programmatic su{^K>rt to Research 

and Development Advisory Committee Subcommittee on Aircraft Safety, and SufxxMnmittee on Air 

Traffic Services. 

111. Conducts support activities for the human factors ''community of practice" across the agency. 

j . Cl^airs, directs, and orchestrates activities of the FAA Human Factors Coordinating Committee 

as set forth under Appendix 3 (Human Faciors Coordinating Committee) of this order. 

Page 6 
k. Coordinates for the aget>cy the communication, evaluation, advice, and support for the human 

factors community of (wacrice on strategic planning, risk management, and organizational 

infrastructurc requirements arxl capabilities for human factors activities and expertise. 

1. Supports education, training, and professional development programs to meet the human factors 

community of practice needs. 

m. Advises and provides research and engineering assistance, consultatiort, or augmentation to 

agency programs for human factors products and services. 

n. For Air Traffic Organization, assesses and supports development of quantitative measures, 

analytical methods, conventions aitd guidelines, technical tools, data aiKl database availability, 

human performarKe criteria, life cycle cost*;, human-in-tbe-bop analyses, and "lessons leamod" for 

human Actors research and engineering applications. 

o. For Air Traffic Organization, serves as clearinghouse, quality assurance, and document control for 

hunmn Victors policy and standards. 

IV. Provides human factors research and engineering support to activities within the Air Traffic 

Organization Ot>crations Planning (ATO-P) service area and other organizational elements as 

appropriate. 

p. Serve as a inember of the ATO-P sponsored System Engineering Council to ensure 

incorporation of human factors considerations in NAS Enterprise Architecture developments 

and nx)difications and to enhance human-system integration in other system engineering 

crxleavors. 

q. Ensures human factors is coordinated and integrated in Air Traffic Organization Operations 

Planning service area planning, analysis, development, and implementation activities. 

r. Provides human factors research and engineering support to Air Traffic Organization 

Operations Planning activities. 

s. Provides human factors leadership arnl services in support of other Air Traffic Organizations as 

required. 

113 Checklist for Huaiaa Factors Research and Engiaeering. Appendix 2, Organizational 

Checklist for Human Factors Research, Applications, and In&asiructure Support provides an 

outline of key items for tailoring and review within all FAA organizations. 

Administrator 

Page 7 
APPENDIX I 

HUMAN FACTORS STUDY AREAS 

1. Allocation of Function: Assigning those roles/functions/tasks for which the human or 

equipment perfonns better while enabling the human to maintain awareness of the operational 

situation. 

2. Anthropometrics and Biomechanics: Accommodating the physical attributes of its user 

population (e.g., from ttw: 1st through 99th percentile levels). 

3. CHI (Computer-Humaa Interactioa): Employing effective and consistent user dialogues, 

interfaces, and procedures across system functions. 

4. Communications and Teamwork: Applying system design considerations to enhance 

required user commimicarions and teamwork. 

5. Culture: Addressing the organizational arul sociological environment into which any change, 

including new technologies and procedures, will be introduced. 

6. Displays and Controls: Designing and arranging displays and controls to be consistent with 

the operator's and maintainer's tasks and actions. 

7. Documentation: Preparing user documentation and tectmical manuals in a suitable format of 

information presentation, at the appropriate reading level, and with the required degree of 

technical sophistication and clarity. 

8. Environment: Accommodating environmental factors (including extremes) to which the 

system will be subjected and understanding the associated effects on human-system 

performance. 

9. Functional Design: Applying hurrwn-centered design for usability and compatibility with 

operational and maintenarKC coiKepts. 

10. Human Error: Examining design and contextual conditions (including supervisory and 

organizational influences) as catLsal factors contributing to human error, and consideration of 

objectives for error tolerance, error prevention, and error correction/recovery. 

11. Information Presentation: Enhancing operator and maintainer performance through the use of 

effective and consistent lat>els, symbols, colors, terms, acronyms, abbreviations, formats, and 

data fields. 

12. Inrormation Requirements: Ensuring the availability and usability of information needed by 

the operator and maintainer for a specific task when it is needed, and in a form that is directly 

usable. 

13. I/O Devices: Selecting input and output (I/O) methods and devices that allow operators or 

maintainers to perform tasks, especially critical tasks, quickly ar>d accurately. 

14. KSAs (Knowledge, Skills, Abilities): Measuring die knowledge, skills, and abilities (KSAs) 

required to perform job-related tasks, and determining appropriate selection requirements for 

users. 

15. Operational Suitabilit>': Ensuring that the system appropriately supports the user in 

performing intended fimctions while maintaining interoperability and consistency with other 

system elements or support systems. 

16. Procedures: Designing operation and maintenance procedures for simplicity, consistency, and 

ease of use. 

17. Safety and Health: Preventing/reducing operator and maintainer exposure to safety and health 

hazards. 

18. Situational Awareness: Enabling operators or maintainers to perceive and understand 

Page 8 
elements of the current situation, and project them to future operational situations. 

19. Special Skills and Tools: Minimizing the need for special or unique operator or maintainer 

skills, abilities, tools, or characteristics. 

20. Stalling; Accommodating constraints and efficiencies for staffing levels and organizational 

structures. 

21. Training: Applying methods to enhance operator or maintainer acquisition of the knowledge 

and skills needed to interface with the system, and designing tfiat system so that these skills 

are easily learned and retained. 

22. Visual/Aaditor^' Alerts: Designing visual and auditory alerts (including ertor messages) to 

invoke the necessary operator and maintainer response. 

23. Workload: Assessing the net demands or impacts upon the physical, cognitive, and decisionmaking resources of an operator or maintainer using objective and subjective performance 

measures. 

24. Work Space: Designing adequate work space for personnel and their tools or equipment and 

providing sufficient space for the movements and actions that personnel perform during 

operational and maintenance tasks under normal, adverse, and emergency conditions. 

Page 9 
APPENDIX 2 

DEFINTIONS 

Human Factors Engineering. Human factors engineering entails the application of human ^tors 

consiffcratiiMis concurrent with <«her engineering disciplines during the analysis, (ksign, development, 

testing, and fielding of a system, service, or fecility in which human performaiKe is essential in meeting 

safety and capability objectives. 

Human Factors Research. Human factors research entails the sciendfic acquisition of information 

ahoul human capabilities arxl limitations related lo hardware, software, facilities, procedures, jobs, 

organizations, environments, training, staffing, errors, situati<Hial awareness, workload, pct^Minel 

nianagcment decision support tools, and other performar>ce implications in which the human is a 

component in n>eeting safety and capability objectives. 

Human -Cen tered. The concept and structured process of concept and requirements definition, 

design, devclofMnent, and implementation that identifies the user as the focal point of the effort for 

which procedures, equipment facilities, and other components serve to support human capabilities 

and compensate for human limitatiotis; sometimes also called "user-centered." 

Hinnan-Svstcm Integration. The concept and processes associated with optimizing total system 

performance via fully incorporating human factors considerations (including manpower levels, 

personnel attributes, traiiung, safety and occupational health, ergonomics and human engineering) 

in program definition, analysis, desigp, development testing, and implerticntation. 

Q M B Exhibit 300 Requirements. The analyses, information, and documentation associated with 

OMB Circular J I, Part 7, Exhibit 300 requirements and all attachments necessary to initiate, 

baseline, develop, and manage a program effectively and efficiently. 

System Acquisitions. System acquisitions encompass functions related to all FAA major and nonmajor acquisitions including developmental items, non-developmcntal items, commercial-off-theshelf procurements, research and technical services, hardware and software acquisitions, and 

facilities. 

System Operations. System operations encompass all functions related to the operation, 

maintenance, and regulation of the National Airspace System under the purview of FAA. 

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APPE\D1X 2 

ORGANIZATIONAL CHECKLIST FOR HUMAN FACTORS RESEARCH, 

APPLICATIONS, AND INFRASTRUCTURE SUPPORT 

The following checkhst items support the implementation and compliance with this order 

For Research: Plan, review, and prioritize human factcH^ research which supports the organization's 

needs. 

• Are human factors efforts responsive and synchrwiized to your organizational needs in a timely 

basis? 

Arc you provided with an adequate strategy to conduct human fact<Ms efforts at the appropriate 

location (e.g., contractor, laboratory)? 

Are human factors efforts communicated and coordinated across other Research, Engineering & 

Development efforts and with organizations outside the FAA to maximize leveraging? 

Does the proper mix exist between short-term vs long-term, in-house vs extra-mural, and contract 

vs university to satisfy specific himian factors requirements? 

Are mechanisms adequate to transfer and apply information generated from human factors 

research to organizatifflial fimctitms? 

For Applications: Develop and institutionalize formal mechanisms that systematically incorporate 

human fectors considCTations into the cw^anization's activities. 

Arc human rescHirce constraints arul human-system performance considerations identified eariy in 

organization program activities? 

Are human resource impacts of the program identified? 

Do system operational performarice specifications (including system integration requirements) 

consider human factors? 

Is human performance for the program/project quantitatively measured? 

Is human performance and usability an explicit item in contiact^veiKlor evaluation criteria and 

contract award? 

Have analyses been dorK and data been made available to address human performance? 

Does user involvement in the program/project follow a structured, performance data-driven 

strategy? 

Do critical operational issues and criteria in requirements and testing reflect human performance 

in operational terms? 

Do life cycle costs reflect total human resource commitments? 

Has the system been stressed to its performance limits (incliKling human-in-the-Io<^ analysis)? 

Do program-'project decisions use human performance data? 

Arc human performance issues and "lessons learned" captured for subsequent applications? 

For Infrastructure Sopport: Establish and maintain the infrastructiue that provides the organization 

with the necessary human faciors expertise and capabilities. 

Arc human factors experts available and involved? 

Is there appropriate representation and coordination of organizational human factors efforts? 

Is there continuity of human factors effort? 

Are there adequate funds for required human factors tasks? 

Arc the aj^ropriate human fectors tools, techniques, and technical capabilities available? 

• Does training provide the proper level of human factors awareness/imderstarKting? 

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Do policies, processes, and procedures enhance the consideration of human performance? 

• Are job aids and practitioner tools available to support and aj^ly human factors considerations? 

For Program Reviews: 

Arc sufficient human factws resources available to ensure the program's success? 

• Is the responsibility for human factors centrally directed for coordination and efficiency? 

Is human factors expertise integral to the team decision making and processes? 

Is human factors integrated into system engineering activities? 

Arc human factors issues regularly raised arxl resolved in program/project deliberations, 

functions, activities, and decisions? 

• Are system requirements, speciflcarions, and evaluations replete with operator and maintainer 

performance parameters? 

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APPENDLX 3 

HUMAN FACTORS COORDINATING COMMITTEE 

The Human Factors Coordinating Committee shall continue in force to facilitate FAA 

human factors endeavors constroctively and enhance the use of human factors 

information. Composition aiKJ functions of the Hiunan Factors Coordinating Committee 

arc as follows: 

1. Organization. The conmiittee shall be organized as a steering and coordinating 

body that is facilitated by temporary or permanent subcommittees or working groups as 

required. 

2. Composition. The committee shall be sponsored and chaired by the FAA Human 

Factors Research and Engineering Program Director. The composition of the Human 

Factors Coordinating Committee will be as deemed necessary to promote and support the 

execution and implementation of human factors best practices within the FAA and to 

ensure the best intercsts of the government. Under the provisions of Paragraph 11 

(Responsibilities) of this order, candidate organizations shall each designate one number 

(or more if necessary) who shall have the authority to represent that organization in 

human factors matters. A recording secretary shall be appointed by the committee for the 

purpose of preparing minutes of the meetings. The Human Factors Cxx>rdinattng 

Committee shall encourage participation in its activities by others with significant human 

fectors responsibilities. Candidate organizations include: 

- Air Traffic Organization Service Areas 

- Associate -Administrator for Aviation Safety 

- Associate Administrator for Airports 

- Associate Administrator f<H" Commercial Space Transportation 

- Assistant Administrator for Information Services 

- Assistant Administrator for Region and Center Operations 

- Research Development & Human Factors Laboratory, William J. Hughes 

Technical Center 

- Human Resources Research Division, Civil Aeromcdical Institute, Office of 

Aerospace Medicine 

- Aeromedical Research Division, Civil Aeromedical Institute, Office of 

Aerospace Medicine 

3. Fimctions. The Human Factors Coordinating Committee shall fiinction as an 

intra-FAA committee to coordinate human factors information, matters, and activities 

among the executives, associate administrators, and assistant administrators and their 

organizations. Specific fimctions of the Human Factors Coordinating Committee are to: 

a. Enhance the identification of human factors research requirements and the 

coordination of research results; 

b. Foster the dissemination and exchange of human factors information 

among agency organizations; 

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c. Facilitate the integration of human factors into procedure development, 

system performance evaluation, rulemaking, system acquisitions, and other activities 

within the agency; 

d. Identify the need for changes to existing policies, processes, research 

programs, regulations, or other human factors-related activities and programs; and 

c. Monitor the efficacy of human factors efforts and programs within FAA. 

4. Administration. The HFCC shall develop internal operating procedures that 

define the frequency of meetings, the structure and relationship of working groups and 

subcommittees, and the processes and procedures by which its activities are to be carried 

out. 

5. Responsibilities. 

a. The Chairperson. The chairperson shall be responsible for: 

(1) Ensuring that the fimctions of the committee are accomplished; 

(2) Establishing agenda, schedules, and locations for meetings; 

(3) Reviewing committee documentation prior to publication or 

distribution; and, 

(4) Ensuring appropriate representation, organization, documentation, 

and administration to support the committee. 

b. Committee Members. Committee members shall be responsible for 

(1) Supporting subcommittees, working groups, and other means of 

coordinating human factors program activities within and across their organizations; 

(2) Supporting their re^xxtive human factors research and 

engineering programs within their organizations; 

(3) Monitoring their respective human factors research requirements 

development processes within their organizations; 

(4) Providing information, briefings, and documentation to the 

committee on human factors matters within their organizations; 

(5) Atterwiing committee meetings or designating an aHemate if 

attendance is not possible; and 

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(6) Participating in committee and other activities such as workshops, 

seminars, and human factors research and engineering program reviews, as appropriate. 

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