AVIATION SAFETY

FAA’s Efforts to Implement 

Recommendations to 

Improve Certification and 

Regulatory Consistency 

Face Some Challenges

Statement of Gerald L. Dillingham, Ph.D. 

Director, Physical Infrastructure Issues

Testimony 

Before the Subcommittee on Aviation, 

Committee on Transportation and 

Infrastructure, House of 

Representatives

For Release on Delivery 

Expected at 10:00 a.m. ET

Wednesday, July 23, 2014

GAO-14-728T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-728T, a testimony 

before the Subcommittee on Aviation, 

Committee on Transportation and 

Infrastructure, House of Representatives

July 23, 2014

AVIATION SAFETY

FAA's Efforts to Implement Recommendations to 

Improve Certification and Regulatory Consistency

Face Some Challenges

Why GAO Did This Study

Among its responsibilities for aviation 

safety, FAA issues certificates for new 

aircraft and parts, and grants approvals 

for changes to air operations and 

aircraft, based on federal aviation 

regulations. Various studies, GAO’s 

prior work, and industry stakeholders 

have raised questions about the 

efficiency of FAA’s certification and 

approval processes, as well as the 

consistency of its staff in interpreting 

aviation regulations. Over time, FAA 

has implemented efforts to address 

these issues, but they persist as FAA 

faces greater industry demand and its 

overall workload has increased. The 

2012 FAA Modernization and Reform 

Act required FAA to work with industry 

to resolve these issues. In response, 

FAA chartered two committees—one 

to address certification and approval 

processes and another to address 

regulatory consistency—which 

recommended improvements in 2012. 

In 2013, FAA published an 

implementation plan for addressing the

certification and approval process 

recommendations and promised to 

publish an implementation plan for 

addressing the regulatory consistency 

recommendations at a later date.

This testimony provides information on 

FAA’s progress in implementing the (1) 

certification and approval process 

recommendations and (2) regulatory 

consistency recommendations. It also 

discusses future challenges industry

stakeholders believe FAA will face in 

implementing these recommendations. 

This testimony is based on GAO 

products issued from 2010 to 2014, 

updated in July 2014 through reviews 

of recent FAA and industry documents 

and interviews of FAA officials and 

industry representatives. 

What GAO Found

The Federal Aviation Administration’s (FAA) Aircraft Certification Service (Aircraft 

Certification) is responsible for addressing the certification and approval process 

recommendations, and has made progress. Aircraft Certification is implementing 

and has set milestones for completing 14 initiatives, several of which were 

originally begun as part of earlier certification process improvement efforts. The 

initiatives range from developing a comprehensive road map for major change 

initiatives, to improving Aircraft Certification’s process for prioritizing requests for 

certifications and approvals (project sequencing), to reorganizing the small 

aircraft certification regulation. According to an update prepared by FAA in May 

2014, one initiative has been completed and most are on track to be completed 

within 3 years. However, according to this update, two initiatives will not meet 

planned milestones, including the one for improving FAA’s program for 

delegating authority to organizations to carry out some certification activities. 

Also, a third initiative for improving consistency of regulatory interpretation was at 

risk of not meeting planned milestones. Two additional initiatives, while on track 

for meeting planned milestones in May 2014, faced challenges because of 

opposition by FAA’s labor unions, including one for improving Aircraft 

Certification’s project sequencing process. GAO found in October 2013 that 

Aircraft Certification continued to lack performance measures for many of these

initiatives, a condition that persists. In 2010, GAO had previously recommended 

that FAA develop a continuous evaluative process with performance goals and 

measures. FAA agreed but has not yet fully addressed the recommendation. 

Aircraft Certification officials discussed plans to develop metrics in three phases, 

beginning in July 2014 and in the future, for measuring (1) the progress of 

implementing the initiatives throughout FAA, (2) the outcomes of each initiative, 

and (3) the return on investment for FAA and the industry resulting from 

implementing the initiatives as a whole.

FAA’s Flight Standards Service (Flight Standards) is responsible for addressing 

the regulatory consistency recommendations, is finalizing plans to do so. FAA

has not published a detailed plan with milestones and performance metrics, and

officials told GAO that they intend to publish a plan by August 2014. Flight 

Standards officials said they were making progress in addressing the 

committee’s top priority recommendation—mapping all FAA policy and guidance 

to relevant federal aviation regulations and developing an electronic system that

maintains this information and that is accessible by FAA and industry users. As 

part of this effort, officials told GAO that Flight Standards has begun eliminating 

obsolete guidance and linking existing policy and guidance to the regulations.

Going forward, Aircraft Certification’s and Flight Standards’ efforts may face

challenges that could affect successful implementation of the committees’ 

recommendations. Many of these recommendations represent a significant shift 

in how FAA normally conducts business, and if the workforce is reluctant to 

implement such changes, FAA’s planned initiatives for addressing the 

recommendations could be delayed. Also, the fact that FAA has not yet 

implemented performance measures for most of the initiatives is a concern for

both GAO and the industry. As GAO concluded in October 2013, without 

performance measures, FAA will be unable to gather the appropriate data to 

evaluate the success of current and future initiatives.

View GAO-14-728T. For more information, 

contact Gerald L. Dillingham, Ph. D. at (202) 

512-2834 or dillinghamg@gao.gov.
 

Page 1 GAO-14-728T 

Chairman LoBiondo, Ranking Member Larsen, and Members of the 

Subcommittee:

I appreciate the opportunity to testify today on the status of the Federal 

Aviation Administration’s (FAA) efforts to improve its certification and 

approval processes. As you know, FAA is responsible for aviation safety, 

and part of this responsibility entails issuing certificates for new aircraft 

and aircraft parts and equipment and granting approvals for such things 

as changes to air operations and aircraft, based on federal aviation 

regulations. FAA’s current efforts to improve these processes are aimed 

at (1) improving its decision-making process for issuing certificates and 

approvals, (2) keeping pace with emerging technology, and (3) enabling 

industry growth and innovation. Studies published since 1980,1 our prior 

work,2 industry stakeholders, and experts have long raised questions 

about the efficiency of FAA’s certification and approval processes and 

varying interpretations and applications of its regulations in making 

certification and approval decisions. More recently, several aviation 

industry groups have asserted that these issues persist, resulting in 

delays and higher costs for their members. These delays have been 

generally attributed to heavy staff workloads and a lack of staff resources 

to begin new work on certifications and approvals. With greater industry 

demand and the introduction of new aircraft, equipment, and technology 

into the national aviation system, FAA’s workload has increased and is 

expected to grow further over the next decade. We previously concluded 

that it will be critical for FAA to follow through with reforms to its 

certification and approval processes to meet industry’s future needs.3

 

1

See National Academy of Sciences, Improving Aircraft Safety: FAA Certification of 

Commercial Passenger Aircraft, National Research Council, Committee on FAA 

Airworthiness Certification Procedures (Washington, D.C.: June 1980); Booz Allen & 

Hamilton, Challenge 1000: Recommendations for Future Aviation Safety Regulations

(McLean, VA: Apr. 19, 1996); RTCA Task Force 4, Final Report of the RTCA Task Force 

4 “Certification” (Washington, D.C.: Feb. 26, 1999; and Independent Review Team 

Appointed by Secretary of Transportation Mary E. Peters, Managing Risks in Civil 

Aviation: A Review of FAA’s Approach to Safety (Washington, D.C.: Sept. 2, 2008).

2

See GAO, Aviation Safety: Certification and Approval Processes Are Generally Viewed 

as Working Well, but Better Evaluative Information Needed to Improve Efficiency, 

GAO-11-14 (Washington, D.C.: Oct. 7, 2010) and GAO, Aircraft Certification: New FAA 

Approach Needed to Meet Challenges of Advanced Technology, GAO/RCED-93-155 

(Washington, D.C.: Sept. 1993).

3

GAO, Aviation Safety: Status of Recommendations to Improve FAA’s Certification and 

Approval Processes. GAO-14-142T (Washington, D.C.: Oct. 30, 2013).
 

Page 2 GAO-14-728T 

Over time, FAA has initiated various efforts and initiatives to improve its 

certification and approval processes and interpret regulations more 

consistently, including efforts in response to findings and 

recommendations we made in 2010.4 However, to bring further attention 

to these issues and spur additional action, Congress included the 

following requirements for FAA in the FAA Modernization and Reform Act 

of 2012:5 (1) work with the industry to assess and recommend 

improvements to the certification and approval processes (Section 312) 

and (2) address the findings from our 2010 report related to FAA 

interpreting regulations more consistently (Section 313). To meet these 

requirements, FAA chartered two aviation rulemaking committees in April 

2012—the Aircraft Certification Process Review and Reform Aviation 

Rulemaking Committee (Certification Process Committee) and the 

Consistency of Regulatory Interpretation Aviation Rulemaking Committee

(Regulatory Consistency Committee)—which made recommendations to 

FAA in May 2012 and November 2012, respectively. In an October 2013 

statement, we made preliminary assessments of the two committees’ 

recommendations and FAA’s responses,6 finding that both FAA-chartered 

committees took reasonable approaches in their work and made relevant, 

clear, and actionable recommendations to FAA. However, we also 

discussed challenges to making further improvements to the certification 

and approval processes, most notably that FAA has not developed 

performance metrics for measuring the outcomes of the initiatives.7

 

4

In 

2010, GAO made two recommendations requiring, among other things, 

that FAA develop a continuous evaluative process with performance 

goals and measures for assessing its actions to improve the efficiency of 

GAO-11-14. 

5

Pub. L. No. 112-95, §§ 312 and 313, 126 Stat. 11, 66 and 67 (2012).

6

GAO-14-142T. 

7

GAO-14-142T. 
 

Page 3 GAO-14-728T 

its certification and approval processes, and a method to track 

submission approvals.8

This testimony discusses FAA’s continuing efforts related to its 

certification and approval processes. More specifically, it provides 

information on (1) FAA’s progress in implementing the Certification 

Process Committee recommendations, (2) its progress in implementing 

the Regulatory Consistency Committee recommendations, and (3) future 

challenges that others and we identified that FAA faces in implementing 

these recommendations. This statement is primarily drawn from several 

GAO products issued since 2010.9

 

8

We have updated the information in 

July 2014 related to our previous work on the certification and approval 

processes through a review of more recent FAA and industry documents, 

including the committees’ reports to FAA, FAA’s reports to Congress in 

response to the committees’ recommendations as well as additional 

government and industry documents and reports related to this topic. This 

review included the May 2012 Certification Process Committee’s and the 

November 2012 Regulatory Consistency Committee’s report to FAA; 

FAA’s August 2012 and July 2013 reports to Congress on the results and 

plan for implementing recommendations made; and FAA’s 

implementation plans to address the committees’ recommendations. We 

also conducted interviews with FAA officials and industry stakeholders—

including Boeing, the largest U.S. aircraft manufacturer—and 

representatives from all eight trade associations that participated in the 

two aviation rulemaking committees. Related GAO products are footnoted 

throughout the statement. The reports and testimonies cited in this 

statement contain detailed explanations of the methods used to conduct 

GAO-11-14. Specifically, we recommended that FAA develop a continuous evaluative 

process and use it to create measurable performance goals for the actions, track 

performance toward those goals, and determine appropriate process changes. We also 

recommended that FAA develop and implement a process in Flight Standards to track 

how long certification and approval submissions are wait-listed, the reasons for wait-listing 

them, and the factors that eventually allowed initiation of the certification process. FAA 

partially addressed the first recommendation and fully addressed the other.

9

GAO-11-14; GAO, Aviation Safety: Additional FAA Efforts Could Enhance Safety Risk 

Management, GAO-12-898 (Washington, D.C.: Sept. 12, 2012); GAO, Aviation: Status of 

DOT’s Actions to Address the Future of Aviation Advisory Committee’s 

Recommendations, GAO-13-657 (Washington, D.C.: July 25, 2013); GAO-142T; GAO, 

FAA Reauthorization Act: Progress and Challenges Implementing Various Provisions of 

the 2012 Act, GAO-14-285T (Washington, D.C.: Feb. 5, 2014); and GAO, Aviation Safety: 

Additional Oversight Planning by FAA Could Enhance Safety Risk Management, 

GAO-14-516 (Washington, D.C.: June 25, 2014).
 

Page 4 GAO-14-728T 

our prior work. We provided a draft of the new information contained in 

this statement to the Department of Transportation (DOT) for technical 

review and addressed its views in the body of our statement where 

appropriate.

The work upon which this testimony is based was conducted in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Located in FAA’s Office of Aviation Safety (Aviation Safety), the Aircraft 

Certification Service (Aircraft Certification) and Flight Standards Service 

(Flight Standards) issue certificates and approvals for new aviation 

products to be used in the national airspace system as well as for new 

operators in the system, such as air carriers, based on federal aviation 

regulations (see fig. 1 below). FAA inspectors and engineers interpret and 

implement these regulations governing certificates and approvals through 

FAA policies and guidance, including orders, notices, and advisory 

circulars. Additionally, FAA also has the authority to use private 

individuals and organizational entities, known as designees, to carry out 

many certification activities on behalf of the FAA Administrator in order to 

enable FAA to better concentrate its limited staff resources on safetycritical functions.10

 

10Administered under 14 C.F.R. Part 183, FAA has the authority to designate private 

individuals to act as representatives of the agency for examining, inspecting, and testing 

persons and aircraft for the purpose of issuing certificates. In 2005, FAA established the 

organization designation authorization program to consolidate all existing organizational 

delegation types into this single program. 70 Fed. Reg. 59946, Oct. 13, 2005.

Background
 

Page 5 GAO-14-728T 

Figure 1: Federal Aviation Administration’s Organizational Structure for Processing Certificates and Approvals

Note: The Flight Standards Service’s oversight responsibilities include air operators (e.g., air carriers 

and air taxi services) and air agencies (e.g., flight schools and repair stations).

In Aircraft Certification, approximately 880 engineers and inspectors issue 

certifications and approvals to the designers and manufacturers of new 

aircraft and aircraft engines, propellers, parts, and equipment, including 

the avionics and other equipment required for modernizing the air traffic 

control system under the Next Generation Air Transportation System 

(NextGen).11

 

11NextGen is a federal effort to transform the U.S. national airspace system from a 

ground-based system of air traffic control to a satellite-based system of air traffic 

management.

Since 2005, Aircraft Certification has used a project 

sequencing system to nationally prioritize certification submissions on the 

basis of available resources. In fiscal year 2013, Aircraft Certification 

issued 3,496 design approvals, 57 production approvals, and 536 

airworthiness certificates.
 

Page 6 GAO-14-728T 

In Flight Standards, approximately 4,000 inspectors issue certificates and 

approvals allowing individuals and entities to operate in the national 

airspace system. These include certificates to commercial air carriers, 

operators of smaller commercial aircraft, repair stations, and flight training 

schools and training centers. Flight Standards field office managers in 

over 100 field offices initiate certification projects within their offices on a 

first-come, first served basis. In fiscal year 2013, Flight Standards issued 

259 air operator certificates and 159 air agency certificates.

When FAA receives aviation industry submissions for certificates and 

approvals, it must determine whether or not resources are available to 

begin the project. According to FAA, the agency considers its highest 

priority to be overseeing the continued operational safety of the people 

and products already operating within the national airspace system. The 

same staff that provide this oversight are also tasked with other oversight 

activities, such as processing new certifications and approvals that FAA 

considers to be lower priority. FAA wait-lists new certification and 

approval projects when resources are not available to begin the work. 

Flight Standards, in particular, has historically had difficulty keeping up 

with its certification workload across its regions and offices, a problem 

that persists.12 FAA has considered ways to supplement its annual budget 

by expanding its sources of funding to deal with its increasing workload 

and staff shortages. However, FAA has limited options as it cannot levy 

fees on its customers for most of the services it provides to industry, 

including aviation product certifications and approvals.13

Attempts have been made to provide FAA with additional funding from 

industry stakeholders for processing certifications and approvals. In 2007, 

the administration submitted a reauthorization proposal to Congress that 

called for major changes to FAA’s funding and budget structure. These 

changes were intended to provide a more stable, reliable basis for 

funding in the long term, in part by allowing FAA to impose fees on 

 

12According to a recent DOT’s Office of Inspector General (OIG) report, as of October 

2013, Flight Standards faced a significant backlog of aviation certification applications, 

with 138 applicants wait-listed for more than 3 years. See DOT OIG, Weak Processes 

Have Led to A Backlog of Flight Standards Certification Applications, Federal Aviation 

Administration, Report Number AV-2014-056 (Washington, D.C.: June 12, 2014).

13Congress has historically prohibited FAA from collecting additional funding through the 

implementation of new aviation user fees. The latest prohibition is contained in the 

Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, 128 Stat. 5, 578 (2014).
 

Page 7 GAO-14-728T 

manufacturers for the various activities and costs related to aircraft 

certification and approval. Congress has previously authorized other 

agencies to charge these types of “user fees” for services rendered for 

processing product certification and approval. For example, the Medical 

Device User Fee and Modernization Act of 2002 authorized the Food and 

Drug Administration (FDA) to charge and retain a fee for providing 

services related to reviewing medical device products.14 However, this 

broad authority has not been granted to FAA.

In May 2012, the Certification Process Committee made six 

recommendations to Aircraft Certification to streamline and reengineer 

the product certification and approval processes, improve efficiency and 

effectiveness within Aircraft Certification, and redirect resources for 

support of certification. The Certification Process Committee further 

recommended that FAA develop measures of effectiveness for its 

activities and a means of tracking its progress. In August 2012, FAA 

reported its plan to Congress for addressing the Certification Process 

Committee’s recommendations, and, in July 2013, the agency issued an 

implementation plan with 14 initiatives. FAA updated this plan in January 

2014 and plans to issue further updates on the status of the initiatives 

periodically.15

Since the January update, Aircraft Certification has continued its efforts to 

address the recommendations to improve its certification and approval 

processes and is implementing the 14 initiatives. These initiatives touch 

on various aspects of Aircraft Certification’s work and, according to FAA 

several predate the committee’s recommendations and were part of ongoing continuous efforts to address long-standing certification issues and 

to improve the certification process. The initiatives range from developing 

a comprehensive road map for major change initiatives, to improving the 

 

14FDA reviews applications from manufacturers that wish to market medical devices in the 

United States. To facilitate prompt approval of new devices and clearance of devices that 

are substantially equivalent to those legally on the market, Congress passed the Act to 

authorize FDA to collect user fees from manufacturers. In return, the Act requires FDA to 

meet performance goals tied to the agency’s review process. Pub. L. No. 107-250, 116 

Stat. 1588 (2002).

15FAA, Detailed Implementation Plan for the Federal Aviation Administration 

Modernization and Reform Act of 2012, Pub. L. No. 112-95, Section 312, Jan. 31, 2014. 

Most FAA Initiatives 

to Improve Its Aircraft 

Certification and 

Approval Process Are 

on Track

Most Initiatives Are on 

Track for Meeting Planned 

Completion Milestones
 

Page 8 GAO-14-728T 

project sequencing process, to reorganizing the small aircraft certification 

regulation.16

 

1614 C.F.R. Part 23. In June 2013, a joint FAA-industry committee recommended to FAA 

changes to part 23. According to FAA officials, FAA will devise a plan to implement the 

recommendations and initiate new rulemaking for part 23 in 2015.

Figure 2, based on an interim May 2014 update that FAA 

provided to us, summarizes FAA’s determination of the status of the 14

initiatives.
 

Page 9 GAO-14-728T 

Figure 2: Status of the Federal Aviation Administration’s Certification Process Initiatives (Section 312), as of May 2014

Note: Future completion shown in the figure indicates when an initiative is planned to be completed.

a

FAA delegates authority to organizations under the organization designation authorization program 

to carry out certain functions on behalf of the agency.

b

Instructions for continued airworthiness include such things as maintenance manuals and inspection 

programs for maintaining operational safety of aviation products.

c

14 C.F.R. Part 21 is the regulation under which aircraft products and parts are certificated.

d

The validation process is a form of certification to establish compliance for airplanes designed 

outside their countries in order to issue a type certificate for these airplanes.

e

No due date has been assigned to this initiative.
 

Page 10 GAO-14-728T 

f

14 C.F.R. Part 23 is the regulation under which small airplanes are certificated.

g

According to the May 2014 update that FAA provided to us, 1 of the 14 

initiatives has been completed, and 10 initiatives are on track for 

completion within planned time frames. FAA deployed a tracking system 

to monitor the implementation of the initiatives in June 2013, but the 

agency indicated it is still finalizing the mechanisms for authorizing staff 

with the appropriate level of review and approval rights in the system. 

Also, ten of the initiatives were on track for meeting their planned 

completion milestones. For example, the initiatives to expand the 

authority for approving aircraft emissions data and noise compliance 

under the organization designation authorization (ODA) program are on 

track to be completed in 2015.

This initiative is on hold until issuance of the implementation plan for addressing recommendations to 

improve regulatory consistency.

17 In addition, the initiative to expedite 

rulemaking by, among other things, adopting a rulemaking prioritization 

tool to update airworthiness standards for special conditions is scheduled 

to be completed in September of this year.18

Although most initiatives are on track, according to FAA’s May 2014 

interim update, 2 of the 14 initiatives will not meet planned milestones:

Further, three of the 

initiatives were in danger of getting off track between 2011 and 2013 and 

are now back on schedule.

• Improve effectiveness of the ODA program: FAA and two aviation 

industry groups—the Aerospace Industries Association and General 

Aviation Manufacturers Association19

 

17FAA grants ODAs for several types of certifications and approvals, including production 

certificates, parts manufacturer approvals, and type certificates. Some companies, such 

as Boeing, are granted ODA status for more than one type of certification or approval.

—developed a plan to improve 

the effectiveness of the ODA process, which is used to authorize 

organizations to act on behalf of FAA in conducting some safety 

certification work. In conjunction with the plan, FAA revised the order 

18FAA issues special conditions to address new and novel design features during the 

aircraft certification process.

19The Aerospace Industries Association represents major U.S. aerospace and defense 

manufacturers and suppliers, and the General Aviation Manufacturers Association 

represents leading global manufacturers of general aviation airplanes and rotorcraft, 

engines, avionics, and components.

Some Initiatives Will Not 

Meet or Are at Risk of Not 

Meeting Planned 

Milestones
 

Page 11 GAO-14-728T 

that outlines the new ODA procedures.20 However, this initiative was 

purposely delayed to provide industry with additional time to adapt to 

the changes in the ODA procedures. Representatives of three 

industry associations we interviewed for this testimony supported the 

use and expansion of ODA by FAA. In contrast, while the Professional 

Aviation Safety Specialists (PASS) agrees with the concept of ODA, it 

has concerns related to expanding the program because 

representatives contend that oversight of the program requires 

significant FAA resources.21 PASS also contends that due to current 

staffing shortages and increased workload, FAA does not have 

enough inspectors and engineers to provide the proper surveillance of 

the designees who would be granted this additional delegation 

authority. On May 14, 2014, the DOT OIG announced a review of 

FAA’s oversight of the ODA program. The OIG plans to assess FAA’s 

(1) process for determining staffing levels for ODA oversight and (2) 

oversight of delegated organizations’ program controls.

• Update 14 C.F.R. Part 21: FAA chartered another aviation rulemaking 

committee in October 2012 to evaluate improvements to the 

effectiveness and efficiency of certification procedures for aircraft 

products and parts,22 along with incorporating new safety 

management system (SMS) concepts into the design and 

manufacturing environment.23

 

20FAA Order 8100.15B, change 1, Organization Designation Authorization Procedures, 

Feb. 3, 2014.

The committee submitted its report to 

FAA in July 2014. FAA indicated that the government shutdown in 

October 2013 delayed some of the actions that the agency had 

planned to move this effort into the rulemaking process, including 

submission of the application for rulemaking. According to FAA, 

21PASS is the labor union that represents some of FAA’s inspector workforce, among 

others.

22Title 14 of the Code of Federal Regulations Part 21, Certification Procedures for 

Products and Parts, is the basis for evaluating and certifying aircraft, engines, and 

propellers. The steps in the certification process include the applicant’s conceptual design, 

the application for design approval, definition of the design standards, plans to 

demonstrate the design meets those standards, generation and substantiation of 

compliance data, determination of compliance, and issuance of the type certificate.

23SMS is a formalized process that involves collecting and analyzing data on aviation 

operations to identify emerging safety problems, determining risk severity, and mitigating 

that risk to an acceptable level. This approach to aviation safety is becoming the standard 

throughout global aviation industry. See GAO-14-516 and GAO-12-898. 
 

Page 12 GAO-14-728T 

however, this delay will have no effect on completion of the final rule, 

which is planned for 2017.

According to FAA’s May 2014 update, 1 of the 14 initiatives was at risk of 

not meeting planned milestones, which increases the risk that FAA will 

miss its established implementation time frames for the initiative for 

addressing its associated recommendation.

• Improve consistency of regulatory interpretations: The May 2014 

interim update also indicated that the initiative for improving the 

consistency of regulatory interpretation is at risk of getting off track or 

off schedule. This initiative responds to the Regulatory Consistency 

Committee’s recommendations for improving the consistency of 

regulatory interpretation within both Aircraft Certification and Flight 

Standards. However, Aircraft Certification is relying on Flight 

Standards to complete the implementation plan for addressing the 

recommendations. Therefore, Aircraft Certification has placed this 

initiative on hold. (The next section of this statement discusses in 

more detail FAA’s response to the Regulatory Consistency 

Committee’s recommendations.)

In addition, FAA officials told us that implementation of 2 of the 14 

initiatives, while shown as being on track for meeting planned milestones 

in the May 2014 interim update, face challenges because of opposition by 

FAA labor unions:

• Improve project sequencing process:24

 

24As previously mentioned, Aircraft Certification instituted a sequencing program in 2005 

to prioritize the processing of all new certification and approval applications based on the 

availability of its resources.

According to the interim May 

2014 update that FAA provided to us, this initiative was listed as on 

track. However, FAA officials told us the status for this initiative will 

change to “will not meet planned milestone” in the next revision of the 

implementation plan expected in July 2014. They explained the 

change in status is a result of their not expecting to obtain 

concurrence from the National Air Traffic Controllers Association 

(NATCA), which represents Aircraft Certification’s engineers, among 

others, on the proposed process changes until December of this year. 

NATCA has expressed concerns about FAA’s plans to change the 

project sequencing process. The group recommended to FAA that 

instead of continuing with project sequencing, it should institute a 
 

Page 13 GAO-14-728T 

system that manages projects locally on a first-come first-served 

basis, except for projects that fix an unsafe condition. FAA plans to 

implement the new process, assess its effectiveness, and modify as 

necessary, and issue the order for all Aircraft Certification offices’ 

project sequencing by December 2016.

• Expand delegation authority for approving instructions for continued 

airworthiness (ICA)25 to ODA: Similarly, in May 2014, FAA 

characterized the initiative as on track for meeting the planned 

milestones, but FAA officials told us this initiative may face challenges 

as well. The Certification Process Committee noted that the volume of 

ICAs is rapidly increasing and that ICA delegation is underutilized, 

and recommended that FAA delegate some ICA review activity to 

improve and streamline the certification process. However, in 

December 2013, PASS presented a white paper to FAA that outlined 

its concerns and reasons it considers this to be a high-risk area that is 

critical to maintaining adequate safety and aircraft maintenance. 

PASS strongly disagreed with FAA’s plan to expand delegation of 

ICAs and the Certification Process Committee’s decision for making 

this recommendation. In response, in April 2014, FAA sent a 

memorandum to PASS to address the concerns and questions 

contained in the PASS white paper, as well as justify moving forward 

on the initiative. A PASS representative we interviewed for this 

testimony told us that PASS continues to have concerns about FAA’S

expansion of the ODA program. FAA considers this issue to be 

resolved with PASS and has decided to go forward with the initiative.

As of May 2014, FAA had not developed metrics for measuring the 

effectiveness of 9 of the 14 initiatives it has undertaken, nor has it 

determined metrics to measure the effectiveness of its actions as a 

whole. According to FAA officials, they plan to develop these metrics in 

three phases. For the first phase, to be included in the July 2014 update 

of its implementation plan, FAA will include metrics to measure the 

progress of the implementation of the initiatives. For the second phase, 

FAA plans to subsequently develop metrics for measuring the outcomes 

of each initiative. For the third phase, working with the Aerospace 

Industries Association, FAA plans to develop metrics for measuring the 

 

25ICAs include such things as maintenance manuals and inspection programs that are 

necessary for maintaining the continued operational safety of aviation products, such as 

aircraft, and aircraft parts and equipment.

Most Certification Process 

Improvement Initiatives 

Lack Measures of 

Effectiveness
 

Page 14 GAO-14-728T 

global return on investment in implementing all of the initiatives, to the 

extent that such measurement is possible. We believe that this plan for 

establishing performance measures is reasonable.

Unlike FAA’s efforts to improve the certification process, although FAA 

has made some progress towards addressing the regulatory consistency 

recommendations, the details remain unclear about how FAA will 

structure its efforts. In November 2012, the Regulatory Consistency 

Committee made six recommendations to Aircraft Certification and Flight 

Standards to improve (1) the consistency in how regulations are applied 

and (2) communications between FAA and industry stakeholders. In July 

2013, FAA reported to Congress on its plans for addressing the 

regulatory consistency recommendations, and included its preliminary 

plan for determining the feasibility of implementing these 

recommendations. The report also indicated that FAA would develop a 

detailed implementation plan that would include an implementation 

strategy, assign responsibilities to offices and staff, establish milestones, 

and measure effectiveness for tracking purposes. We found in February 

2014 that FAA expected to publish such a detailed implementation plan 

by late June 2014, more than 6 months after its initial target date of 

December 2013.

26

Until this detailed plan is released, the specific initiatives for addressing 

the recommendations are unknown; thus, we cannot analyze information 

on the status of any planned efforts similar to the information we provided 

above for the certification process initiatives. Further, FAA’s July 2013 

preliminary plan does not specify how FAA plans to measure the 

effectiveness of the initiatives. FAA indicated that “although there may not 

be any baseline for each recommendation against which to compare 

improvements, FAA intends to consider: (1) identifying metrics, (2) 

gathering and developing baseline data, and (3) periodically measuring 

any changes, positive or negative, in rates of completion.” FAA officials 

provided the following information on how the agency is planning to 

respond to the six recommendations.

In June 2014, FAA officials told us that the 

implementation plan was under review within FAA and estimated that the 

agency would issue its detailed plan in August 2014.

 

26GAO-14-285T. 

FAA Has Made Some 

Progress in 

Addressing 

Recommendations to

Improve the 

Consistency of Its 

Regulatory 

Interpretations, but 

Details Are Unclear
 

Page 15 GAO-14-728T 

The Regulatory Consistency Committee recommended that Aircraft 

Certification and Flight Standards (1) review all guidance documents and 

interpretations to identify and cancel outdated material and electronically 

link the remaining materials to its applicable rule, and (2) to consolidate 

Aircraft Certification’s and Flight Standards’ electronic guidance libraries

into a master source guidance system, organized by rule, to allow FAA 

and industry users access to relevant rules and all active and superseded 

guidance material and related documents. This recommendation for 

creating the master source guidance system is the top priority of the 

Regulatory Consistency Committee. FAA officials indicated that 

establishing this system will require two main components:

• As a first step, for linking (mapping) all relevant guidance materials to 

the regulations, FAA plans to determine which "guidance" documents 

exist across regional and field offices—including orders, notices, and 

advisory circulars—outside FAA’s electronic guidance libraries, which

are being used to answer questions, interpret or analyze regulations, 

and provide guidance on regulatory matters. In December 2013, Flight 

Standards sent out a memorandum requesting that staff discontinue 

using any guidance documents outside those found in the guidance 

libraries, to be effective January 15, 2014. The memorandum also 

asked for the staff to submit any unofficial guidance worth preserving 

to FAA for review. Flight Standards then conducted a review to 

determine which of the unofficial guidance documents submitted 

should be added to the guidance libraries. Several members of the 

Regulatory Consistency Committee responded in an e-mail to FAA to 

express serious concerns about this approach and stated that the 

committee did not envision the cancellation of any guidance before 

FAA developed a methodology to include or exclude such guidance. 

The committee members further noted that FAA’s memorandum 

provided no method to allow existing certificate holders to retain 

certifications that were based on any applied guidance that had been 

cancelled. Further, these members requested that FAA either 

withdraw the memorandum or address the issues they raised and 

extend the date for FAA staff to comply with the memorandum. 

However, two other Regulatory Consistency Committee members we 

interviewed considered FAA’s actions to get staff to discontinue the 

use of unofficial guidance in the field to be an appropriate first step.

• Second, FAA plans to develop a master source guidance system with 

the capability to consolidate information from Aircraft Certification’s 

and Flight Standards’ electronic guidance libraries as well as legal 

interpretations from the Office of Chief Counsel into a master 

guidance system to allow FAA and industry users access. Specifically, 

A Master Source Guidance 

System
 

Page 16 GAO-14-728T 

the Regulatory Consistency Committee recommended that this 

system be searchable so that FAA and industry users can easily 

access relevant rules and find the relevant guidance for the rule. FAA 

officials assessed the possibility of using the existing Aviation Safety 

Information Management System, but determined that it is not 

adequate because (1) users cannot search for guidance by word and 

(2) it is not compatible with other FAA data systems. According to 

FAA officials, with about $750,000 in approved funding for this project, 

FAA’s information technology division is in the process of developing 

a dynamic regulatory system that should provide the needed 

capabilities. Officials indicated that when users conduct a search for a 

particular topic in this system, the search results should bring up 

multiple entries for specific guidance. Initially, Flight Standards plans 

to use an Excel spreadsheet for storing the guidance and then 

transition to the new system once it is deployed. Flight Standards 

hopes to test out a first version of this system within calendar year 

2014. However, the officials were unsure of the total cost of 

developing and deploying the system.

Representatives from four of the committee stakeholders we interviewed 

for this testimony acknowledged that creating this system is a major effort 

for FAA because of the volume of FAA guidance that potentially exists 

across regional and field offices, some of which may not be in Aircraft 

Certification’s and Flight Standards’ electronic guidance libraries. 

Representatives of five industry stakeholders we interviewed provided 

insights on how FAA might devise a plan for creating and populating this 

system. Three of these noted that FAA will need to ensure that the 

various types of guidance—such as orders, notices, and advisory 

circulars—include links to the original federal aviation regulations. One of 

these stakeholders recommended that FAA develop the system to allow a 

user looking at FAA guidance to also see all relevant background 

information on related decisions, and the past actions related to the 

guidance in question and their relation to the original regulation. Because 

of the large volume of FAA guidance, some stakeholders also suggested 

that FAA begin by first choosing a starting date for which any new rules or 

other new guidance it issues would include links to the relevant original 

regulations. However, one stakeholder we interviewed noted that FAA 

should consider prioritizing its effort by first mapping the guidance 

materials for specific key regulations and then the guidance for less 

significant regulations.
 

Page 17 GAO-14-728T 

The Regulatory Consistency Committee noted multiple instances where 

FAA guidance appeared to have created inconsistent interpretation and 

application, and confusion; the Consistency Committee recommended 

that FAA develop a standardized decision-making methodology for the 

development of all policy and guidance material to ensure such 

documents are consistent with adopted regulations. In interviews for this 

testimony, FAA officials also provided some updates on how the agency 

will respond to the recommendation to develop instructional tools for its 

policy staff. FAA officials told us they had not initiated any efforts yet to 

address this recommendation, but would begin by focusing on developing 

instructions for policy staff to use for populating the master source 

guidance system. In August 2014, FAA plans to form an internal work 

group to establish a document management framework and work 

processes that can be used by Aircraft Certification’s and Flight 

Standards’ policy division staffs as they map existing guidance 

documents to applicable source regulations in the master source 

guidance system. The officials expected the work group would issue an 

internal directive for FAA personnel on work processes to be used in 

populating the guidance system by June of 2015.

The Regulatory Consistency Committee recommended that FAA, in 

consultation with industry stakeholders, review and revise its regulatory 

training for applicable agency personnel and make the curriculum 

available to industry. FAA officials told us that FAA has begun to develop 

improved training for its field staff—the third recommendation of the 

Regulatory Consistency Committee—so that field inspector staffs are 

better equipped to answer routine compliance-related questions 

confidently and in a consistent manner. In addition, the officials told us 

starting in 2015, FAA plans to conduct a gap analysis of existing training 

for all FAA staff who are responsible for interpreting and applying 

certification and approval regulations. For this analysis, FAA plans to 

assess whether existing training can be modified to sufficiently address 

any gaps. FAA also plans to coordinate with industry to share the results 

of this review and analysis by the end of 2015.

The Regulatory Consistency Committee made two similar 

recommendations for FAA to consider: (1) establish a Regulatory 

Consistency Communications Board comprising various FAA 

representatives that would provide clarification on questions from FAA 

and industry stakeholders related to the application of regulations and (2) 

Instructional Tools for FAA 

Personnel for Applying Policy 

and Guidance

FAA and Industry Training 

Priorities and Curriculums

Regulatory Consistency 

Communications Board
 

Page 18 GAO-14-728T 

determine the feasibility of establishing a full-time Regulatory Operations 

Communication Center27

As we found in 2010, resolution through the CSI can be a lengthy 

process, with the total length of the process depending on how many 

levels of appeal the industry stakeholder chooses.

as a centralized support center to provide realtime guidance to FAA personnel and industry certificate/approval holders 

and applicants. FAA officials also discussed the agency’s conceptual 

approach and plans for establishing a board—likely by the end of 

calendar year 2014—to address these two recommendations. The 

purpose of the board would be to provide a neutral and centralized 

mechanism with a standardized process for addressing and resolving 

regulatory compliance issues between FAA and industry. According to the 

committee, this board would be comprised of representatives from the 

relevant headquarters policy divisions in FAA to help answer complex 

regulatory interpretation issues that arise between FAA inspectors and 

engineers, and industry during the certification and approval processes. 

FAA officials told us the board’s process, once established, would use a 

modified version of the agency’s current Consistency and Standardization 

Initiative (CSI), a process established as a means for industry to appeal

FAA decisions and actions.

28

 

27Under this operations center concept, FAA would establish a 24-hour/7-day operations 

center staffed (virtually) by policy and/or legal personnel trained and experienced in the 

regulations, policy and guidance associated with flight operations, aircraft maintenance, 

aircraft certification and aircraft production.

However, as we also 

found, industry stakeholders have generally been reluctant to use CSI for 

initiating appeals and raising concerns with the local field office for fear of 

retribution. FAA officials told us in interviews that the modified process 

would help address the retribution issue, because it would rely instead on 

multiple sources to raise issues—not just solely on industry—and would 

be the final arbiter for FAA and industry in disagreements on certification 

and approval decisions. According to FAA officials, the board could also 

serve the function of the proposed operations center recommended by 

the committee to be a resource for assisting FAA personnel and industry 

stakeholders with interpretation queries and establishing consistency in 

regulatory application. FAA officials indicated that the agency had 

decided not to establish the communications center because (1) the 

28GAO-11-14. 
 

Page 19 GAO-14-728T 

board could serve a similar function and (2) FAA has limited resources 

available to staff a communications center.

Several industry stakeholders we spoke with told us they support FAA’s 

preliminary plans to establish the board and modify the CSI process as 

part of this effort. For example, several stakeholders told us that they 

support FAA’s plans to modify the current CSI process. One of these 

stakeholders noted that a modified process would be more effective if it 

allowed for industry stakeholders to raise issues anonymously. Also, 

another stakeholder noted the board would not be beneficial until after 

FAA has established the master source guidance system because the 

board should be able to refer to that guidance in demonstrating how it 

makes decisions.

The Regulatory Consistency Committee recommended that FAA improve 

the clarity of its final rules by ensuring that each final rule contains a 

comprehensive explanation of the rule’s purpose and how it will increase 

safety. FAA officials told us that this recommendation has been 

addressed through the work of the Aviation Rulemaking Advisory 

Committee’s Rulemaking Prioritization Working Group.29 The officials told 

us that, as a result of this effort, all final rules, are now well-vetted across 

FAA. The industry representatives we interviewed had mixed opinions 

about whether FAA had addressed this recommendation as intended. For 

example, two stakeholders were in agreement with FAA that the agency 

had addressed it while two other stakeholders noted that FAA’s new rules 

are still not as clear as they should be. Two stakeholders also said that it 

is often not the final rules but the guidance that accompanies or follows 

the final rules that is unclear and contributes to inconsistent interpretation 

and application among FAA staff.

 

29Specifically, in January 2013, FAA accepted the recommendation of the Rulemaking 

Prioritization Working Group that FAA should adopt a prioritization model across its lines 

of business for prioritizing rulemaking projects. In response, as we reported in prior work, 

FAA developed a tool that provides a standardized basis for evaluating and prioritizing 

potential rulemaking projects to be used by each line of business. See GAO-13-657. 

Clarity in Final Rules
 

Page 20 GAO-14-728T 

In our previous work on organizational transformations, we noted that 

implementing large-scale change management initiatives—like those the 

committees tasked FAA with—are not simple endeavors and require the 

concentrated efforts of both leadership and employees to realize intended 

synergies and accomplish new organizational goals.30 People are at the 

center of any serious change management initiative because people 

define the organization’s culture, drive its performance, and embody its 

knowledge base. The best approach for these types of initiatives depends 

upon a variety of factors specific to each context, but there has been 

some general agreement on a number of key practices that have 

consistently been found at the center of successful change management 

initiatives. These include, among other things, securing organizational 

support at all levels, developing clear principles and priorities to help 

change the culture, communicating frequently with partners, and setting 

performance measures to evaluate progress.31 In this final section of this 

testimony, we discuss challenges for FAA in implementing the 

committees’ certification and approval and regulatory consistency 

recommendations that relate to these key practices.

FAA officials and industry representatives we spoke to noted that shifting 

priorities as well as declining resources may prohibit FAA from devoting 

the time and resources needed for completing the initiatives in the 

planned time frames. They agreed that a primary challenge for FAA will 

be having the dedicated resources that will be needed to successfully 

implement the committees’ recommendations. We have previously found 

that successful organizational transformations and cultural changes

require several years of focused attention from the agency’s senior 

leadership.32

 

30GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers and 

Organizational Transformations, 

This lesson is consistent with our previous work on 

organizational transformation, which indicates that support from top 

leadership is indispensable for fundamental change. Top leadership’s 

clear and personal involvement in the transformation represents stability 

GAO-03-669 (Washington, D.C: July 2, 2003).

31GAO-03-669, and GAO, VA Health Care: Additional Efforts to Better Assess Joint 

Ventures Needed, GAO-08-399 (Washington, D.C.: Mar. 28, 2008).

32GAO, National Airspace System: Transformation Will Require Cultural Change, 

Balanced Funding Priorities, and Use of All Available Management Tools, GAO-06-154 

(Washington, D.C.: Oct. 14, 2005).

Challenges that 

Could Affect 

Successful 

Implementation of the 

Committees’ 

Recommendations

Organizational Support
 

Page 21 GAO-14-728T 

for both the organization’s employees and its external partners. Top 

leadership must set the direction, pace, and tone for the transformation. 

Additionally, buy-in and acceptance among the workforce will be critical to 

successful implementation of the initiatives to address the two 

committees’ recommendations.

Additionally, as we described in our 2010 report, FAA prioritizes ensuring 

the continued operational safety of the people and products already 

operating in the national airspace system over processing new 

certifications and approvals. We reported in the 2010 report that Flight 

Standards staff had little or no incentive to perform certification work 

under the system in which their pay grades are established and 

maintained.33 Other than inspectors involved with overseeing air carriers, 

Flight Standards inspectors are typically responsible for a variety of types 

of certificate holders. Each certificate is allocated a point value based on 

the complexity of the certificate or operation, and the combined point 

value for each inspector’s oversight responsibilities must meet or exceed 

the points allocated for the inspector’s grade. However, not all of the 

inspectors’ duties—including certification work—receive points in this 

system, and inspectors are subject to a downgrade if entities in their 

portfolio relocate or go out of business.

FAA and industry representatives also cited FAA’s organizational culture 

as a primary challenge for FAA in successfully implementing these 

initiatives. They noted that many of the certification process and 

regulatory consistency initiatives FAA is attempting to implement

represent cultural shifts for FAA staff in how regulations, policy, and 

guidance are applied, and ultimately how certification and approval 

decisions are made. As we have previously found, the implementation of 

recommendations that require a cultural shift for employees can be 

delayed if the workforce is reluctant in accepting such change.34

Further, industry representatives have identified the lack of 

communication with and involvement of stakeholders as a primary 

challenge for FAA in implementing the committees’ recommendations, 

 

33GAO-11-14. 

34GAO-14-142T. 

Commitment to Cultural 

Change

Communication with 

Stakeholders
 

Page 22 GAO-14-728T 

particularly the regulatory consistency recommendations. Successful 

agencies we have studied based their strategic planning, to a large 

extent, on the interests and expectations of their stakeholders, and 

stakeholder involvement is important to ensure agencies’ efforts and 

resources are targeted at the highest priorities.35 However, 

representatives of two industry organizations we interviewed told us that 

FAA did not provide the opportunity for early input and that outreach is 

low regarding the certification process recommendations, and 

representatives of four industry organizations indicated that FAA has not 

sought their input in responding to the regulatory consistency 

recommendations. They reported that FAA had neither kept in contact 

with or advised them of its plans nor engaged the Regulatory Consistency 

Committee participants in the drafting of the detailed implementation plan 

that is expected to be published in August. As an example, as previously 

discussed, when Flight Standards published a memo in December 2013 

calling for the cancellation of non-official guidance, several members of 

the Regulatory Consistency Committee were unaware of the change and 

expressed surprise and dissatisfaction with the action and offered their 

assistance. Representatives of one industry group noted that FAA sought 

their input on addressing the Certification Process Committee’s

recommendations for subsequent revisions of its implementation plan.

FAA has not fully developed performance metrics to ensure that any 

initiatives it implements are achieving their intended outcomes. We have 

previously found that agencies that have been successful in assessing 

performance use measures that demonstrate results and provide useful 

information for decision making.36

• FAA had developed performance measures for 5 of the 14 

certification process initiatives as of May 2014 and plans to further 

develop measures in three phases. In addition, most of the initiatives 

are scheduled to be implemented by 2017. Although we have 

Earlier in this testimony, we reported 

that FAA had not completed developing performance measures for either 

the certification improvement or the regulatory consistency initiatives:

 

35GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1, 1996).

36GAO, NextGen Air Transportation System: FAA’s Metrics Can be Used to Report on 

Status of Individual Programs, but Not of Overall NextGen Implementation or Outcomes, 

GAO-10-629 (Washington, D.C.: July 27, 2010).

Setting Performance 

Measures
 

Page 23 GAO-14-728T 

assessed FAA’s plan for developing these metrics as reasonable, the 

agency may miss an opportunity to gather early data for evaluating 

the effectiveness of its actions and making any needed corrections.

• There is no detailed plan for implementing initiatives addressing the 

consistency of regulatory interpretation recommendations and 

measuring their outcomes. In recent meetings, FAA officials told us 

they have had difficulty in determining how to measure the outcomes 

of its regulatory consistency initiatives and have not been able to 

determine what specific performance metrics could be used.

Going forward, it is critically important that FAA develop outcome-based 

performance measures to determine what is actually being achieved 

through the current and future initiatives, thereby making it easier to 

determine the overall outcomes of each of the initiatives and to hold 

FAA’s field and headquarters offices and employees accountable for the 

results. We are not making any new recommendations because the 

recommendation we made in 2010 for FAA to develop outcome-based 

performance measures and a continuous evaluative process continue to 

have merit related to this issue. To its credit, FAA has initiated some 

efforts and sound planning for addressing the committees’ 

recommendations. However, it will be critical for FAA to follow through 

with its initiatives and plans for developing performance metrics to 

achieve the intended efficiencies and consistencies. As we noted in our 

October 2013 statement, however, some improvements to the 

certification and approval processes, will likely take years to implement 

and, therefore, will require a sustained commitment as well as 

congressional oversight.37

Chairman LoBiondo, Ranking Member Larsen, and Members of the 

Subcommittee, this completes my prepared statement. I would be 

pleased to respond to any questions at this time.

For further information on this testimony, please contact Gerald L. 

Dillingham, Ph.D., at (202) 512-2834 or dillinghamg@gao.gov. In 

addition, contact points for our Offices of Congressional Relations and 

Public Affairs may be found on the last page of this statement. Individuals 

 

37GAO-14-142T. 

GAO Contact and 

Staff 

Acknowledgments
 

Page 24 GAO-14-728T 

making key contributions to this testimony statement include Vashun 

Cole, Assistant Director; Andrew Von Ah, Assistant Director; Jessica 

Bryant-Bertail; Jim Geibel; Josh Ormond; Amy Rosewarne; and Pamela 

Vines. The following individuals made key contributions to the prior GAO 

work: Teresa Spisak, Assistant Director; Melissa Bodeau, Sharon Dyer, 

Bess Eisenstadt, Amy Frazier, Brandon Haller, Dave Hooper, Sara Ann 

Moessbauer, and Michael Silver.

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