FAA NEEDS TO IMPLEMENT MORE EFFICIENT 

PERFORMANCE-BASED NAVIGATION 

PROCEDURES AND CLARIFY THE ROLE 

OF THIRD PARTIES 

Federal Aviation Administration

Report Number: AV-2011-025

Date Issued: December 10, 2010
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: FAA Needs To Implement More 

Efficient Performance-Based Navigation 

Procedures and Clarify the Role of Third Parties

Federal Aviation Administration

Report Number AV-2011-025

Date: December 10, 2010

From: Jeffrey B. Guzzetti

Assistant Inspector General

for Aviation and Special Program Audits

Reply to 

Attn. of: JA-10

To: Federal Aviation Administrator

The Federal Aviation Administration (FAA) is developing the Next Generation 

Air Transportation System (NextGen) to move today’s ground-based air traffic 

control system to a more efficient one that relies on satellite-based navigation 

systems on-board aircraft. A fundamental building block for NextGen is 

establishing new flight procedures using Area Navigation (RNAV) and Required 

Navigation Performance (RNP) specifications. The potential benefits of RNAV 

and RNP are significant and include shorter, more direct flight paths; improved 

airport arrival rates; enhanced controller productivity; fuel savings; and reduced 

aircraft noise.

While FAA has implemented over 600 RNAV and RNP1

At the request of the Chairman of the House Subcommittee on Aviation, we 

evaluated FAA’s oversight of RNP third-party agreements. The Chairman stated 

that a clear understanding of FAA and third-party processes, roles, and 

responsibilities is needed before any expansion of their role occurs. Accordingly, 

procedures since 2005,

industry representatives have expressed concerns with both their quality and 

timeliness. In 2004, industry representatives asked FAA to allow third parties to 

assist the Agency in developing new procedures. In response, FAA entered into 

agreements in 2007 with two non-governmental third parties to develop and 

implement RNP procedures.

 1 For the purposes of this report, the number of RNAV and RNP procedures represents RNAV Standard Instrument 

Departures (SID), RNAV Standard Terminal Arrivals (STAR), and RNP Authorization Required (AR) approaches. 
2

our audit objectives were to (1) assess the extent to which FAA is relying on third 

parties to develop new procedures and (2) determine whether FAA has sufficient 

mechanisms and staffing to provide safety oversight of third parties’ procedure 

development process.

On July 29, 2009, we testified before the House Subcommittee on Aviation 

regarding the challenges in implementing performance-based navigation in the 

U.S. air transportation system.2

RESULTS IN BRIEF

 We included the results of our work to date on 

third-party agreements and highlighted actions FAA should take to effectively 

implement RNAV/RNP. At that time, FAA had not clarified its role with regard 

to new RNP procedures. Since then, FAA has stated that it will be the primary 

entity designing and implementing RNP procedures for the National Airspace 

System. Therefore, this report focuses on FAA’s implementation strategy going 

forward and the potential role of third parties and formally transmits our 

recommendations to FAA. We conducted this review from March 2009 to 

October 2010 in accordance with generally accepted government auditing 

standards prescribed by the Comptroller General of the United States. Exhibit A 

details our scope and methodology. Exhibit B lists the specific locations we 

visited or contacted. 

FAA has clarified its role in developing new RNP procedures, stating that it will 

primarily rely on its own resources rather than third parties. Therefore, the role of 

the two third parties FAA has approved to develop RNP procedures remains 

unclear, as well as FAA’s strategy for implementing timely, high-value routes

using in-house resources. Thus far, FAA has mostly delivered overlays of existing 

routes that do not provide shorter flight paths to alleviate airspace congestion—a 

major industry concern. This is because FAA has mainly focused on developing a 

targeted number of procedures each year, not measuring user benefits. As a result, 

airlines have not widely used FAA’s RNP procedures and state that third parties 

may provide additional technical expertise to develop the procedures they need. 

FAA contends that it has the technical expertise to deliver more efficient 

procedures without third parties but has yet to assess its in-house skill mix. 

FAA also has not fully established an oversight program for third parties, defined 

the staffing levels needed to oversee them, or finalized key guidance to industry on 

qualifications to become a third-party developer. Such guidance is essential, as 

third parties would perform procedural development and maintenance functions 

historically performed solely by FAA. In 2007, FAA’s Flight Standards Service 

established a third party oversight office, but it will be difficult to determine how 

 2 OIG Testimony Number CC-2009-086, “Challenges in Implementing Performance-Based Navigation in the U.S. Air 

Transportation System,” July 29, 2009. OIG reports and testimonies are available on our website: www.oig.dot.gov.
3

many staff this office will need until FAA better defines the extent of third party 

use. FAA also faces resistance to the third-party program within its Air Traffic 

Organization (ATO) Office of Aviation Systems Standards and organizational 

barriers among various lines of business that could delay new, comprehensive 

oversight policies. Thus far, these problems have impeded FAA’s ability to 

oversee its own procedures, which raises questions as to how effectively FAA can

monitor third parties. Without a coordinated oversight system in place, the 

potential for operational and safety risks increases. 

We are making a series of recommendations to help FAA effectively implement

and coordinate RNAV/RNP procedures and establish an oversight program for

third parties.

BACKGROUND

NextGen will rely on new routes and procedures that primarily use satellite-based 

navigation and on-board aircraft equipment to navigate with greater precision and 

accuracy. These new routes and procedures are commonly referred to as RNAV 

and RNP. For RNAV, pilots can use a combination of Global Positioning System 

(GPS) and other self-contained systems on-board aircraft to fly any desired flight 

path by reducing the limitations imposed by ground-based navigation systems. 

RNP is a form of RNAV that adds monitoring and alerting capabilities to the 

cockpit to alert the pilot when the aircraft cannot meet specified navigation 

performance requirements. RNP has the potential to allow more “lanes” or routes 

in the same airspace, creating additional capacity where needed.

Traditionally, aircraft have been required to fly routes between ground-based 

navigational aids to maintain required navigation accuracy of on-board systems. 

RNAV and RNP can increase airspace efficiency by providing more direct paths 

(see figure below), thereby improving airport arrival rates, enhancing controller 

productivity, saving fuel, and reducing aircraft noise.
4

Figure. Conventional, RNAV, and RNP Navigational Methods

 

Source: FAA

RNP approach procedures can be developed as public or special procedures. 

Public procedures are available to all operators that have been properly trained, 

equipped, and certified. Special RNP procedures are only available to a specific 

operator for whom the procedure was designed but may be authorized for others 

upon request. While FAA allows special RNP procedures, these have historically 

been authorized on a limited basis. Of the 225 existing RNP approach procedures, 

only 35 are specials. Table 1 provides details on the differences between public 

and special procedures.

Table 1. Public and Special RNP Procedures

Requirements Public RNP Procedures Special RNP Procedures

Who Can Use the 

Procedure?

Available to all qualified operators 

that have been properly trained, 

equipped, and certified

Issued to the specific operator for 

which the procedure was designed; 

other operators may request.

Publication/Federal 

Aviation Regulation

Federal Register in accordance 

with 14 C.F.R. Part 97/a

Not Published/Non-Part 97

Number of 

Procedures

190 RNP 35 RNP 

Who Develops and 

Implements?

FAA’s Office of Aviation System 

Standards 

Third parties

FAA’s Office of Aviation System 

Standards and private industry 

procedure developers (airlines and 

third parties)

Who pays? FAA/b Airspace user and FAA/c

/a Standard Instrument Procedures, 14 C.F.R. § 97 (1963). This FAA regulation governs the development of 

standard instrument approach procedures to airports in the United States.

/b Public procedures developed by FAA are offered at no cost to airspace users. However, airlines will be expected 

to pay for public procedures that are developed by third parties.

/c Airspace users usually pay for special procedures, but FAA may provide this service to industry in some cases.
5

In 2004, a joint FAA and industry group3 recommended that FAA begin using 

third parties to develop and speed the adoption of RNP procedures. In response, 

FAA entered into agreements in 2007 with two non-governmental third parties—

Naverus and Jeppesen-Sanderson, a subsidiary of the Boeing Company—to 

design, integrate, test, and validate public RNP procedures. In 2007, FAA also 

established an oversight office within its Flight Standards organization to oversee 

the third party program.4

FAA HAS NOT WIDELY IMPLEMENTED EFFICIENT RNP 

PROCEDURES OR CLARIFIED THE ROLE OF THIRD PARTIES 

On September 25, 2009, the two vendors were certified 

and approved by FAA to design public-use approaches in the U.S. airspace 

system.

FAA has not clearly communicated to Agency personnel and industry how and to 

what extent it will use third parties to implement new flight procedures. While 

FAA has granted authority to two third parties to develop public RNP procedures, 

it plans to primarily rely on its own resources to develop and implement 

RNAV/RNP procedures. However, FAA has yet to widely implement the more 

efficient procedures that provide new benefits to airlines and lacks an effective 

method for deploying procedures that considers how they will impact air traffic 

policies and whether they are working as intended. Until FAA designs and 

implements more efficient procedures, it will continue to expend resources to 

deploy procedures that carriers do not use and therefore do not achieve expected

benefits across the National Airspace System.

FAA’s Goals for Implementing New Flight Procedures Have Not Been 

Well-Targeted, and the Planned Use of Third Parties Will Not Meet 

Industry’s Expectations

FAA’s published strategic plan5

 3 The Air Traffic Management Advisory Committee (ATMAC) is a Federal advisory committee that recommends 

government/industry, consensus-based investment priorities to the Federal Aviation Administration that will improve 

the safety, capacity, or efficiency of the United States air transportation system.

simply states that it will produce 50 RNP 

procedures annually through 2012. There is no mention of how or whether it will 

share development responsibilities with third parties. Although FAA has stated 

that it plans to use its own personnel rather than third party vendors to design and 

implement new flight procedures, it has not performed a detailed assessment of its 

in-house skill mix and expertise to determine whether the Agency can design and 

deliver more efficient routes in a timely manner consistent with industry’s demand 

for high value routes. Given this uncertainty—and FAA’s focus on the quantity of 

4 FAA’s Flight Standards Flight Procedures and Implementation and Oversight Branch (AFS-460) is responsible for 

managing and overseeing the third-party procedure development program. 5 FAA's 2009-2013 Flight Plan.
6

procedures rather than expected benefits—airlines and industry are skeptical of 

FAA’s ability to develop procedures that allow for more efficient arrivals and 

departures. A recent industry report on advancing NextGen stated that FAA lacks 

the resources to design and install new flight procedures in a timely manner and 

specifically recommended that FAA make greater use of third parties.

6

FAA officials have stated that the intent of the third-party initiative was to provide

operators with FAA-qualified vendors who could develop public procedures 

where existing infrastructure was lacking or where there were no complex airspace 

integration issues. However, this approach will not meet airlines’ expectations 

because it would not speed development of new procedures at congested airports, 

which would be a higher priority for major airlines and critical for advancing 

NextGen through improved airspace operations. Further, using third parties to 

develop public procedures may not be practical. Third parties have not developed 

these in the past, and the extent to which air carriers will hire them to do so is

unknown. While public procedures developed by FAA are offered at no cost to 

airspace users, airlines will be expected to pay for those developed by third parties

and would be responsible for procedures that other carriers can use at no cost.

While airlines value the technical expertise that third parties can provide, they may 

not find it cost beneficial to pay for RNP procedures that would benefit their 

competitors. In addition, according to one of the third-party vendors, the 

agreement with FAA is not cost beneficial for them because it specifies that third 

parties will be responsible for maintaining the procedures, which increases their 

liabilities, risks, and overall costs.

 However,

FAA contends that it has sufficient technical expertise and is committed to move

away from the production goal methodology beginning in fiscal year (FY) 2011. 

The Director of Airspace and Aeronautical Information Management told us that 

FAA is currently working with industry lead operators on specific projects in 

which the Agency is developing procedures that offer the more efficient attributes 

requested. 

Therefore, FAA officials are now concerned that air carriers will increasingly 

request third parties to produce special procedures that provide more benefits and 

are tailored to their specific needs, rather than rely on the public procedures. 

Although FAA has had a process in place for years in which third parties have 

developed special procedures as requested by specific operators, FAA approved 

these only on a case-by-case basis. FAA states that an increasing number of 

special procedures will further complicate the workload of air traffic controllers 

and increase the complexity of the current air traffic control system. 

 6 Report by Aerospace Industries Association, “Civil Aviation Growth in the 21st Century: Meeting Capacity and 

Environmental Challenges,” September 2010.
7

FAA’s Overlays of Existing Routes Have Resulted in Limited Benefits

for Enhancing the Flow of Air Traffic

While FAA has met or exceeded its annual RNP production goals, most of the 

RNP procedures it has deployed have been overlays of existing routes. While 

overlaid procedures can be deployed more quickly because they do not have to 

undergo extensive environmental reviews, they do not maximize the benefits that 

can be achieved through RNP procedures, such as new, more direct flight paths.

FAA officials state that overlaid RNP procedures have provided benefits and that 

they were a necessary step for introducing RNP procedures into the National 

Airspace System. However, airline representatives assert that the overlays only 

provide limited benefits. Specifically, the benefits that FAA cites—such as 

serving as a back-up to ground-based navigation aids in case of system failure, 

transitioning from a traditional instrument landing system (ILS)

7

FAA agrees that it needs to move beyond basic overlays to incorporate flight path 

patterns that better address capacity and throughput, improve airport arrivals and 

departures during poor weather conditions, and enable improved and efficient flow 

of traffic. FAA has recently developed new RNP procedures with curved paths in 

a few locations, such as Raleigh-Durham. While FAA is committed to producing 

more efficient procedures going forward, without a detailed assessment of its inhouse resources and training to do so, it is unclear whether the Agency can 

adequately fulfill industry needs in a timely manner or the extent to which it must 

rely on the use of third parties. A joint Government/industry task force charged 

with identifying mid-term actions FAA should take to advance NextGen reported 

in 2009 that the availability of critical expertise at FAA has been a bottleneck in 

the past and that training enough procedure development teams will be a key 

challenge.

airspace to a high 

performance network of procedures, and reducing the time involved in

environmental reviews—do not equate to measurable capacity gains for the 

airlines. Representatives for major airlines that are RNP-equipped want FAA to 

develop RNP routes and procedures that maximize the full benefits of RNP, such 

as curved paths into airports. However, FAA officials told us that developing 

curved approaches may present operational challenges in air traffic environments 

such as New York because of the traffic density and airspace limitations and may 

not be feasible from an operations standpoint.

8

 7 An instrument landing system (ILS) is a ground-based instrument approach system that provides precision guidance 

to an aircraft approaching and landing on a runway.

 

8 Final Report of the RTCA NextGen Mid-Term Implementation Task Force Report, September 9, 2009.
8

FAA Has Not Ensured That Air Traffic Control Policies Allow the Use 

of RNP at Some Congested Airports 

FAA has implemented RNP procedures at airports without ensuring that air traffic 

policies would allow their use. For example, in May 2007, FAA implemented 

10 RNP procedures9

The Atlanta Hartsfield-Jackson International Airport, which is one of the busiest 

airports in the world, has closely spaced parallel runways (less than 2,500 feet 

between parallel runways). Due to high volumes of air traffic during peak hours,

the airport must maintain capacity by allowing parallel landings for aircraft. 

However, current regulations

at Atlanta Hartsfield-Jackson International Airport, but air 

traffic controllers have never cleared an aircraft to land using these procedures 

because current air traffic regulations do not allow their use for simultaneous 

operations at certain airports with parallel runways.

10

FAA recently completed a 4-year safety study to determine whether the 

regulations can safely be updated through a project at George Bush 

Intercontinental Airport (IAH) in Houston. On July 31, 2009, FAA granted a 

waiver to its air traffic regulations allowing IAH controllers to clear aircraft using 

a combination of ILS, RNAV, and RNP for parallel approaches to support its dual 

or triple parallel runways. FAA is now determining whether the regulations can 

be safely updated at other airports.

state that only an aircraft flying an ILS approach,

not RNP, can be used at airports with parallel runways. This restriction also 

affects other high-density airports, such as Miami, Los Angeles, and Dallas/Ft. 

Worth. Allowing approaches based solely on RNP or a combination of ILS, 

RNAV, and RNP for parallel approaches is currently prohibited unless FAA grants 

a waiver. To issue a waiver, FAA must perform a safety study, which can take 

several years to complete. 

Even if FAA updates its policies and determines that RNP can be allowed at 

airports with parallel runways, airline representatives told us that they would not 

use the RNP procedures at Atlanta because they are overlays of existing 

conventional procedures, thus providing little or no added benefits other than a 

backup in the event the ground-based navigation aid shuts down.

FAA Does Not Analyze the Effectiveness of New Procedures in 

Improving Air Traffic Operations

FAA lacks an adequate process for assessing the effectiveness of new flight 

procedures—both before and after their implementation. While FAA has 

 9 These 10 RNP procedures were overlays of existing procedures. 10 FAA Order JO 7110.65 Air Traffic Control Handbook, paragraphs 5-9-6 and 5-9-7 prescribe aircraft separation 

standards required for parallel dependent and simultaneous independent operations. 
9

implemented RNP at sites recommended by a joint FAA and industry group,

11

Unless FAA establishes an approach that relies on benefit analysis from a “beforeand-after” perspective in close coordination with airlines and air traffic control 

facilities, it will continue to expend resources on procedures that carriers do not 

use and do not provide measurable capacity gains. For example, in late 2005, 

FAA designed and implemented a public procedure in Palm Springs; yet, no air 

carrier has used the procedure in the 4 years since it was implemented because its 

design does not provide shorter flight paths or the ability to fly at lower altitudes. 

According to a major airline that uses this airport, FAA did not adequately

coordinate with all stakeholders, including air traffic controllers, before 

implementing this procedure to ensure that the airport would use it and that it 

would provide benefits.

the 

sites were based on priorities established 5 years ago. FAA followed the original 

2005 priority list provided by industry for selecting RNP sites without performing 

updated analyses to identify expected benefits before implementing the new 

procedures. Currently, FAA only does benefit analyses for select, individual 

procedures. In addition, FAA program officials do not track data that would show 

how often airlines use RNP procedures, whether they obtain expected benefits, or 

why they are not using certain procedures. 

An RNP procedure FAA deployed at Reagan Washington National Airport in 

2005 has demonstrated some benefits, but only a few airlines are actually qualified 

to use it. The procedure allows pilots to follow a more precise path—not available 

through conventional or RNAV procedures—along the Potomac River while 

avoiding restricted airspace and obstacles. 

FAA still has much work to do to analyze its in-house expertise and the potential 

role of third parties; however, it must also focus on targeted benefit analysis and 

improved coordination with airport stakeholders for the procedures it is 

implementing now. Otherwise, airlines will be left with little assurance that FAA 

can shift to a more effective approach in the future. 

To its credit, FAA has stated that it is committed to improving its procedure 

implementation process by focusing on measuring and demonstrating benefits of 

new procedures going forward. In addition, in response to the 2009 joint 

Government/industry task force report, FAA initiated a cross-agency project to 

streamline the processes used to request, prioritize, approve, and implement new 

flight procedures. In FY 2011, FAA will begin implementing the review’s 

recommendations and gathering data to perform pre-and post-implementation 

 11 This particular FAA/industry group, known as the Performance-Based Operations Aviation Rulemaking Committee 

(PARC), provides a forum for the U.S aviation community to discuss, prioritize, and resolve issues; provide 

direction for flight operation criteria; and produce U.S. consensus positions for global harmonization. 
10

benefit analysis for all performance-based navigation routes and procedures. FAA 

is also in the early stages of forming joint agency-industry teams to focus on 

deploying enhanced procedures at airports in busy metropolitan areas.

FAA HAS NOT FULLY ESTABLISHED A COORDINATED 

OVERSIGHT FRAMEWORK FOR THIRD PARTIES

FAA has not yet developed an oversight program to ensure third parties properly 

follow FAA design criteria and processes in integrating, validating, and 

maintaining flight procedures. FAA’s Flight Standards office has drafted 

guidance for industry on processes for authorizing third parties. However, FAA 

has not finalized the guidance due to resistance from the ATO, which is 

responsible for designing flight procedures. Yet, the ATO views the draft 

guidance as critically important and wants Flight Standards to resolve its safety 

concerns before publishing the guidance. FAA must also address the fragmented 

efforts between its lines of business responsible for implementing and overseeing 

new flight procedures. Without a coordinated oversight framework, the potential 

for operational problems and safety risks will increase. 

FAA Has Not Developed a Formal Oversight Program or Defined

Agency Staffing Needs 

FAA has not established a plan for how it will oversee and monitor third parties 

once they are qualified. FAA officials performed initial audits to qualify the two 

third-party vendors, Naverus and Jeppesen, and stated their intent to initially 

conduct 100 percent oversight of all the procedures developed by third parties. 

Once third parties have successfully demonstrated that they can develop these 

procedures on their own, FAA plans to schedule reviews every 2 years. However, 

these are only conceptual plans at this point, not a formal oversight program. 

FAA also has not developed a plan specifying which offices will perform safety 

oversight reviews or how it plans to record and track results of the reviews. 

Currently, FAA’s Flight Procedure and Implementation Oversight Branch (AFS460) can perform 100 percent oversight because there are only two procedures that 

are under review. However, if the number of third-party vendors and procedures 

increases, FAA may be unable to monitor them at that level. In addition, it will be 

difficult for FAA to determine oversight staffing needs because the extent that 

airlines will use third parties is unknown. 

FAA officials told us that the 14 personnel in its oversight office were sufficient to 

qualify the 2 vendors to design public procedures; however, the officials were 

unsure whether they had sufficient resources to oversee these vendors once they 

began designing more procedures or additional vendors if the program is 
11

expanded. FAA must closely monitor staffing resources to ensure they keep pace 

with a potentially increasing workload. Moreover, the oversight office will be 

responsible for overseeing all flight validation activities performed by airlines and 

third parties—a key part of the procedure implementation process to ensure that 

the procedures are properly and safely working. 

Representatives from the Flight Standards oversight office stated that they will

leverage resources by using aviation safety inspectors in the Certificate 

Management Offices (CMO) and All Weather Operations (AWO) personnel to 

perform oversight of flight validation in the field.12

FAA Has Been Unable To Establish Safety Oversight Guidance for 

Third Parties Due to ATO Concerns 

 However, some CMO staff we 

interviewed indicated that they did not know enough about RNP to validate work 

performed by third parties. According to the Deputy Assistant Manager, Flight 

Technologies and Procedures Division, CMOs will be trained when the time 

comes for them to flight test procedures produced by third parties. However, it 

will be difficult for FAA to add new duties for safety inspectors given that the 

current inspector workforce already has difficulty completing all basic required 

safety inspections. 

Lack of support from key managers within the ATO has impeded FAA’s efforts to 

effectively establish a third-party oversight program. This resistance dates back to 

at least May 2006 when Flight Standards recommended that third parties, rather 

than FAA, be responsible for implementing all RNAV/RNP procedures (both 

public and special). Due to opposition from the Director of Aviation System 

Standards,

13

The ATO has not approved the guidance due to safety concerns. Specifically, 

ATO managers are concerned about the safety of the policies and procedures third 

parties must follow and the level of support the program will need from FAA. 

ATO managers have also not approved separate guidance that ensures third parties 

use valid computer software in designing new flight procedures due to potential 

safety, security, and cost risks.

the recommendation was not approved. As a result, the third-party 

agreements that FAA entered into with Naverus and Jeppesen over 3 years ago are 

still based on Flight Standards’ draft guidance. 

Under the third-party agreements, third parties are asked to perform functions 

involving the development, implementation, and maintenance of public instrument 

flight procedures—functions that have been solely performed by FAA in the past. 

In response to the draft guidance for qualifying third-party vendors, FAA officials 

 12 CMOs are the Flight Standards field offices responsible for overseeing the safety of each airline. 13 This office is a part of FAA’s Air Traffic Organization responsible for designing and developing public and special 

instrument flight procedures (IFP).
12

in the ATO’s Office of Aviation System Standards expressed strong concerns 

regarding the use and safety oversight of third parties. Specifically, they 

questioned whether third parties will:

• be held to the same level of standards for safety as FAA when developing 

procedures, 

• be able to effectively communicate across FAA’s lines of business to 

coordinate procedure development and integration,

• possess the same level of training and experience required of FAA staff, 

• be able to access FAA databases for procedure development, maintenance and 

Notices to Airman (NOTAM)

14

• be able to determine when full environmental assessments are required, and

publication, 

• properly integrate third party procedures in the National Airspace System. 

Another issue that caused significant delays in implementing oversight guidance 

was ATO’s concern about the third parties’ understanding of their role in 

addressing environmental impacts of procedures they design. ATO did not believe 

that the draft guidance for qualifying third parties provided a clear understanding 

of the regulatory requirements for addressing environmental impacts. Normally, if 

a procedure has been categorized as an overlay of an existing one, then FAA could 

develop it without performing an extensive environmental assessment, which can 

be lengthy and costly. The types of procedures that require no full environmental 

assessment are Categorical Exclusions.

15

 14 Notice to Airmen, or NOTAMS, are created and transmitted by government agencies and filed with an aviation 

authority to alert aircraft pilots of any hazards en route or at specific locations.

Categorical Exclusions are usually 

reviewed, approved, and signed by the applicable FAA regional Flight Procedures

Office manager. However, when the third-party vendors submitted their first 

public RNP procedures, which were overlays of existing conventional procedures,

FAA had a difficult time determining which official would be responsible for 

reviewing and approving them for Categorical Exclusion. Nearly a year after 

these procedures were completed and ready for publication, an FAA ATO 

Headquarters official finally signed the Categorical Exclusions. Until FAA 

clarifies the approval process for environmental reviews for third party 

procedures, this will continue to be a challenge for FAA.

15 Categorical Exclusions are those types of Federal government actions that FAA has found, based on past experience 

with similar actions, do not normally require full environmental reviews because they do not individually or 

cumulatively have a serious effect on the human environment. 
13

Fragmentation and Uncertainty About Roles Among FAA Offices 

Impede FAA’s Efforts To Establish Cohesive Oversight of Flight 

Procedure Development 

FAA has yet to address organizational barriers and fragmented efforts within its 

lines of business that have hindered the Agency’s efforts to establish a coordinated 

oversight framework. As shown in table 2, several offices within FAA’s Aviation 

Safety organization and the ATO play a role in ensuring the safe development and 

integration of new flight procedures into the National Airspace System regardless 

of whether they are implemented by third parties or FAA internal personnel. 

Table 2. Roles and Responsibilities in the Development and Oversight of 

Flight Procedures

FAA Office Responsibilities

Air Traffic Organization

RNAV/RNP Group • Implements and integrates RNAV and RNP routes and 

procedures into the NAS 

Aviation System 

Standards 

• Designs and develops public and special instrument flight 

procedures (IFP)

• Operates a fleet of flight inspection aircraft for airborne 

evaluation of IFPs and maintains public procedures 

Air Traffic 

Facilities

• Evaluate and use the procedures operationally

• Train controllers on new procedures 

Aviation Safety

Flight Standards 

Service 

• Develops and evaluates design criteria for IFPs

• Oversees flight inspection policy and all IFP development, both 

FAA and third-parties

• Approves special procedures

• Enforces non-compliance penalties for procedures developed by 

third parties 

Air Traffic Safety 

Oversight Service

(AOV)

• Independently oversees the Air Traffic Organization

• Audits Air Traffic facilities, including the Aviation System 

Standards (office that develops instrument flight procedures)

• Enforces non-compliance penalties for procedures developed 

internally 

Recognizing that this organizational framework may cause confusion or 

duplicative efforts, FAA entered into a memorandum of agreement between the 

Air Traffic Oversight Service and Flight Standards in 2008. The purpose of the 

agreement was to define oversight relationships and coordination, leverage the 

resources and expertise of both organizations, and enhance oversight with the 
14

ultimate goal of providing one standard of safety oversight for the National 

Airspace System. 

However, our work has shown that, despite the memorandum of agreement, 

unresolved issues still exist between Flight Standards and the Air Traffic Safety 

Oversight Division regarding oversight roles and responsibilities, and this will 

impact how RNP procedures are implemented. Although FAA’s Flight Standards 

office is responsible for overseeing how FAA and third parties develop 

procedures, it does not have the authority to enforce penalties for non-compliances 

that it finds with procedures developed by FAA employees. That authority lies 

within the Air Traffic Safety Oversight Division. However, for procedures 

produced by third parties, FAA’s Flight Standards personnel have the authority to 

issue penalties for any procedures that they find unsafe. As a result, FAA will 

face challenges in meeting its goal of one standard of safety oversight for 

internally versus externally developed procedures. 

For example, two internal audits performed in 2007 and 2008 by FAA’s Air 

Traffic Safety Oversight Office (AOV) and the Flight Standards Flight Procedures

Implementation and Oversight Branch (AFS-460) could not determine that FAA

had performed required biennial procedure maintenance reviews for 100 percent 

of the 1,242 procedures sampled in 2007 and the 211 sampled in 2008. These 

reviews are important because they assess maintenance of the procedures, such as 

checking for new ground obstacles or changes to navigational procedures. FAA 

also selected 10 of the 211 procedures sampled during the 2008 audit to check for 

safety-related issues. Seven of these 10 had safety-of-flight issues, such as 

improper terrain evaluations and destabilized descent, which could lead to 

controlled flight into terrain.16

When these safety violations were identified, representatives from AFS-460

notified the ATO’s Aviation System Standards Office regarding the seven 

procedures they found to be unsafe, which resulted in Notice to Airmen actions

and/or procedure amendments. However, AOV, rather than Flight Standards, had 

to issue a warning notice because Flight Standards had no enforcement authority

to ensure that FAA corrected the identified problems. Although AOV issued a 

warning notice in June 2008, FAA is still working to correct the problems with 

performing biennial procedure reviews, almost 3 years after the problem was first 

identified. 

 

In addition, Flight Standards Service approves special RNP procedures for use but

does not have to coordinate them at the national level with the FAA Headquarters 

 16 Controlled flight into terrain (CFIT) occurs when an aircraft that is mechanically functioning normally is 

inadvertently flown into the ground, water, or an obstacle with inadequate awareness on the part of the pilot of the 

impending disaster.
15

RNAV/RNP program office, which is responsible for integrating RNAV and RNP 

routes into the National Airspace System. This is because, in the past, special 

procedures were not deployed in complex airspace. Now, special procedures are 

envisioned for complex airspace surrounding high density airports, which may 

conflict with public procedures also being planned or operated and create 

integration problems for the ATO. For example, in 2008, Southwest Airlines 

initiated a unique project to implement new RNAV/RNP arrivals and departures 

between Dallas-Love Field and Houston-Hobby airports. This project involved 

using new design criteria for departures and testing the feasibility of integrating 

RNAV routes at higher altitudes with airport-specific RNP arrivals and departures

to link city pairs. Although this project required an extraordinary level of 

oversight and coordination between FAA and industry, RNAV/RNP program 

officials expressed concern that they were not involved in the initial coordination

process. 

According to a Southwest Airlines representative, the airline recently decided not 

to pursue the Dallas-Houston project due to FAA’s lack of support for special 

procedures. However, coordination at a national level will still be important for 

any similar projects in the future. Without a policy that requires coordination at a 

national level with the RNAV/RNP program officials in planning and deploying

complex special procedures, FAA cannot ensure that new procedures will be 

smoothly and safely integrated into the National Airspace System. 

CONCLUSION

FAA’s successful implementation of NextGen is vital to effectively and efficiently 

manage the anticipated demand for air travel and reduce gridlock across the 

Nation’s airspace and airports. RNAV and RNP are critical building blocks for

NextGen capabilities in the near and midterm. Yet, FAA has not fully laid the 

groundwork for successfully implementing RNP procedures that can provide 

measurable benefits in terms of capacity enhancements and delay reduction at 

airports. Until airline officials have confidence that FAA can produce efficient

RNAV and RNP procedures, they will be less likely to make the needed 

investments to equip their aircraft and train flight crews. FAA Headquarters 

leadership must clearly define and communicate FAA’s implementation strategy 

and the role of third parties. In addition, FAA must address critical coordination 

challenges with all stakeholders and refine its oversight program to ensure the safe 

and timely implementation of new flight procedures.
16

RECOMMENDATIONS 

We recommend that FAA: 

1. Assess its in-house skill mix to determine whether the Agency has the 

expertise needed to design and deliver more efficient, value-added RNP 

procedures in a timely manner. 

2. Clearly define the role of third parties in developing and implementing RNP 

procedures, determine where third parties could play a cost-beneficial role in 

advancing the implementation of new procedures, and issue a report with the

results of this evaluation. 

3. Design an oversight strategy for third parties once the Agency clarifies their 

role in RNP design and implementation.

4. Improve the effectiveness of its approach for implementing new flight

procedures by:

a. performing cost-benefit analyses in close coordination with stakeholders 

before and after implementing RNP procedures.

b. aligning Flight Plan goals with producing beneficial RNP procedures that 

have significant benefits rather than focusing on the number of procedures.

5. Improve the safety oversight and coordination process for implementing new 

flight procedures by:

a. resolving the Air Traffic Organization’s concerns with the draft guidance 

that authorizes third parties to develop instrument flight procedures. 

b. evaluating and clarifying the 2008 Memorandum of Agreement between 

the Flight Standards Service and the Air Traffic Safety Oversight Service 

regarding oversight roles and responsibilities between these FAA offices to 

ensure that oversight functions are properly coordinated for all instrument 

flight procedures and enforcement actions are handled consistently.

c. establishing a procedure for Flight Standards to coordinate with the 

RNAV/RNP program office on any request from industry to develop 

special RNP procedures that have national implications to ensure that these 

procedures do not conflict with procedures that already exist or are being 

created. 
17

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided FAA with our draft report on October 15, 2010, and received the 

Agency’s formal response on November 16, 2010. FAA concurred with 

recommendations 1, 2, 3, 4b, 5a, and 5b; partially concurred with recommendation 

4a; and did not concur with recommendation 5c. Overall, FAA’s response meets 

the intent of most of our recommendations, including actions proposed for 4a. 

However, we are requesting that FAA provide target dates for recommendations 3 

and 4b and reconsider its position for recommendation 5c. FAA’s response is 

included in its entirety as an appendix to this report.

For recommendation 3, FAA concurred but requested that we close it based on its 

current oversight system for third parties. However, FAA will not complete its 

evaluation and determination of third-party roles until February 1, 2011. 

Therefore, we cannot make a final decision on whether FAA has a properly 

designed oversight strategy until after the Agency makes its determination on the 

role of third parties as recommended in our report.

For recommendation 4a, FAA stated that it will perform cost-benefit analyses 

before and after implementing RNP procedures at specific project sites rather than 

on a procedure-by-procedure basis. We consider this action reasonable given 

FAA’s new Metroplex initiative, in which the Agency plans to measure the 

benefits achieved by enhanced flight procedures implemented at 21 busy 

metropolitan areas. 

For recommendation 4b, FAA stated that it was “considering a proposal” to 

eliminate numeric goals from its FY 2011 Flight Plan but did not provide a target 

date for completion. In addition to a target date, FAA needs to specify in its Flight 

Plan how it will measure and report on progress in establishing new routes. This 

clarification is important for airspace users given industry’s strong desire for more 

beneficial routes that can enhance capacity and reduce delays.

For recommendation 5c, FAA stated that it has existing guidance that provides 

adequate procedures for coordination with all concerned lines of business. We are 

aware of this guidance; however, not all of FAA’s lines of business agree that that 

the regional coordination process as outlined in the current guidance is adequate 

for complex projects, such as the initiative with Southwest Airlines to introduce 

new special procedures at select airports. While FAA RNAV/RNP program 

officials attended meetings, they expressed significant concern with the overall 

level of coordination and the degree of national involvement. Therefore, we 

request that FAA determine whether the RNAV/RNP officials’ concerns have 

been adequately resolved and evaluate whether the Agency needs to update 
18

existing guidance to require a higher level of coordination for any future special 

procedures that have significant national implications.

ACTIONS REQUIRED 

FAA’s planned actions and target dates for recommendations 1, 2, 4a, 5a, and 5b

are responsive, and we consider these recommendations addressed but open 

pending completion. We request that FAA provide, within 30 days of this report, 

a target date for recommendations 3 and 4b and clarifying information for 

recommendation 5c as discussed above. We appreciate the courtesies and 

cooperation of FAA representatives during this audit. If you have any questions 

concerning this report, please contact me at (202) 366-0500 or Robin Koch, 

Program Director, at (404) 562-3770.

#

cc: FAA Senior Vice President for Operations, ATO

FAA Associate Administrator for Aviation Safety 

Director of Flight Standards Service 

Anthony Williams, AAE-001

Martin Gertel, M-1 
19

Exhibit A. Objectives, Scope, and Methodology

EXHIBIT A. OBJECTIVES, SCOPE, AND METHODOLOGY

At the request of the Chairman of the House Committee on Transportation and 

Infrastructure, Subcommittee on Aviation, we performed an audit of FAA’s plans 

for qualifying and overseeing non-governmental third party instrument flight 

procedure developers. The objectives of this audit were to (1) assess the extent to 

which FAA is relying on third parties for the development of new Required 

Navigation Performance (RNP) procedures and (2) determine whether FAA has 

established sufficient mechanisms and has sufficient staffing to provide safety 

oversight. 

To determine the extent to which FAA is relying on third parties for the 

development of new RNP procedures, we interviewed managers at all levels of

FAA, officers of the National Air Traffic Controllers Association and Professional 

Airways System Specialist organization, the Air Transport Association, and the 

chair of the Performance-Based Operations Aviation Rulemaking Committee. We 

also met with representatives of the aviation industry who are involved in RNP 

design and implementation to ascertain their concerns regarding FAA’s design and 

implementation of RNP procedures and whether there is a market for third party 

developers. We obtained and reviewed documentation regarding the qualification 

of third party vendors to design and implement public RNP procedures as well as 

met with officials of the two vendors.

To determine whether FAA has sufficient mechanisms and sufficient staffing to 

provide safety oversight, we met with officials of the Flight Standards Service 

office tasked with overseeing instrument flight procedure developers and the Air 

Traffic Safety Oversight Office. We obtained and reviewed plans for overseeing 

third party vendors as well as for implementing the Safety Management System as 

a safety oversight mechanism. We also obtained and reviewed staffing 

information for the oversight office. We also obtained and reviewed audit reports 

from the Air Traffic Safety Oversight Division and the Flight Standards 

Implementation and Oversight Branch for procedures developed internally and 

externally. 

We conducted this audit from March 2009 through October 2010 in accordance

with generally accepted government auditing standards prescribed by the

Comptroller General of the United States. Those standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence that provides 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. 
20

Exhibit B. Facilities Visited or Contacted

EXHIBIT B. FACILITIES VISITED OR CONTACTED

FAA Headquarters, Washington DC

• Air Traffic Organization

o System Operations Services, RNAV/ RNP Program Office

o Safety Services, Office of Safety Risk Management

• Aviation Safety

o Flight Standards Service

o Office of Air Traffic Oversight

Mike Monroney Aeronautical Center, Oklahoma City, OK

• Technical Operations Services, Aviation System Standards

• Flight Standards Service, Flight Procedures Implementation/ Oversight 

Branch

FAA Field Facilities

• Western Region Flight Procedure Office, Renton, WA

• Western Service Center, Renton, WA

• Alaska Airlines Certificate Management Office, Seattle, WA

• Delta Airlines Certificate Management Office, College Park, GA

• Eastern Region Flight Procedure Office, College Park, GA

• Atlanta Terminal Radar Approach Control, Peachtree City, GA

• Dallas Terminal Radar Approach Control, Dallas, TX

Aviation Stakeholders

• Professional Aviation Safety Specialists, Washington, DC

• Air Transport Association, Washington, DC

• National Air Traffic Controllers Association, Washington, DC

• Mitre Corporation, McLean, VA

• Jeppesen Sanderson, Atlanta, GA

• American Airlines, Fort Worth, TX

• Delta Airlines, Atlanta, GA

• Southwest Airlines, Dallas, TX

• Naverus, Seattle, WA

• Alaska Airlines, Seattle, WA

• The Boeing Company, Everett, WA
21

Exhibit C. Major Contributors to This Report

EXHIBIT C. MAJOR CONTRIBUTORS TO THIS REPORT

Robin Koch Program Director

Name Title

Coletta Treakle Project Manager

Raymond Denmark Senior Analyst

Claudia Estrada Analyst

Andrew Olsen Analyst

Andrea Nossaman Writer-Editor
22

Appendix. Agency Comments

APPENDIX. AGENCY COMMENTS

Federal Aviation 

Administration 

Memorandum

Date: November 16, 2010

To: Jeffery B. Guzzetti, Assistant Inspector General for Aviation and Special Program 

Audits

From: Clay Foushee, Director, Audit and Evaluations, AAE-1

Subject: OIG Draft Report: FAA Needs to Implement More Efficient Performance- Based 

Navigation Procedures and Clarify the Role of Third Parties

The Next Generation Air Transportation System (NextGen) is the Federal Aviation 

Administration’s (FAA) plan to modernize the National Airspace System (NAS). Through 

NextGen. FAA is addressing the impact of air traffic growth by increasing NAS capacity and 

efficiency while simultaneously improving safety, reducing environmental impacts, and 

increasing user access to the NAS. To achieve its NextGen goals, FAA is implementing new 

Performance-Based Navigation routes and procedures that leverage emerging technologies and 

aircraft navigation capabilities.

Performance-Based Navigation (PBN) is comprised of Area Navigation (RNAV) and Required 

Navigation Performance (RNP) and describes the capability to navigate using performance 

standards. RNAV and RNP specifications facilitate more efficient design of airspace and 

procedures which collectively result in improved safety, access, capacity, predictability, 

operational efficiency, and environment. Specifically, improved access and flexibility help to 

enhance reliability and reduce delays by defining more precise terminal area procedures. RNAV 

procedures can provide benefit in all phases of flight, including departure, en route, arrival, 

approach, and transitioning airspace.

PBN is a cornerstone of FAA’s NextGen vision. As RNAV and RNP procedures are implemented 

in the NAS, they may provide additional end-to-end benefits by enabling an integrated procedure 

design concept at and between busy airports that will continue to enhance safety and capacity for 

industry and the flying public.
23

Appendix. Agency Comments

OIG Recommendation 1: Assess its in-house skill mix to determine whether the Agency has the 

expertise needed to design and deliver more efficient, value-added RNP procedures in a timely 

manner.

FAA Response: Concur. FAA will assess its capacity to meet the projected increase in demand 

for RNP procedures in support of NextGen, Metroplex and other airspace optimization initiatives. 

FAA will complete this assessment by February 1, 2011.

OIG Recommendation 2: Clearly define the role of third parties in developing and implementing 

RNP procedures, determine where third parties could play a cost-beneficial role in advancing the 

implementation of new procedures, and issue a report with the results of this evaluation.

FAA Response: Concur. The experience of FAA working with the two third-party instrument 

flight procedure developers under the Other Transaction Agreement has served as a platform to 

compare the relative advantages and disadvantages of third-party procedures development as a 

supplement to the FAA’s in-house capability. The FAA will use the results of these efforts to 

clearly define the future role to be served by third-party developers. The results of the evaluation 

and determination of future third-party roles will be completed by February 1, 2011.

OIG Recommendation 3: Design an oversight strategy for third parties once the Agency clarifies 

their role in RNP design and implementation.

FAA Response: Concur. As noted in the report, the Flight Standards Service (AFS) established

the Flight Implementation and Oversight Branch (AFS-460) to provide oversight of third-party

developers. Presently FAA provides comprehensive oversight for the two authorized third-party

vendors for their end to end procedure development activities. Existing staffing and resources are 

able to meet current demand. FAA provides oversight using traditional AFS surveillance and audit 

program techniques. To date, the demand for third-party public procedures has been limited. 

Should the demand for third parties IFP development increase in the future, FAA will adjust its 

oversight resources accordingly. FAA requests the OIG close this recommendation.

OIG Recommendation 4: Improve the effectiveness of its approach for implementing new flight 

procedures by:

a. Performing cost-benefit analyses in close coordination with stakeholders before and after

implementing RNP procedures.

FAA Response: Partially concur. The FAA already conducts site-specific analyses of potential

benefit mechanisms for each project site. Due to the time and level of effort required, only

selected projects are currently assessed post implementation. Under the Metroplex initiative. FAA 

will establish study teams to identify solutions that will address the unique challenges at 21

specific geographic areas. Study team recommendations will identify the benefits expected for

each Metroplex and establish a baseline for measuring post-implementation results. The first two 

Design and Implementation Teams for North Texas Metro and DC Metro will begin in mid to late 

February 2011 and will complete work in 2 1/2 to 3 years. As in all large airspace projects, 

benefits will likely not accrue until completion of the project. The FAA has committed to 

completing the optimization of airspace and procedures for each of the identified 21 Metroplex 

areas within 5-7 years.
24

Appendix. Agency Comments

b. Aligning Flight Plan goals with producing beneficial RNP procedures that have significant 

benefits rather than focusing on the number of procedures.

FAA Response: Concur. In alignment with RTCA Task Force 5 and OIG recommendations, FAA 

is considering a proposal to eliminate numeric PBN targets from its FY-2011 Flight Plan.

OIG Recommendation 5: Improve the safety oversight and coordination process for

implementing new flight procedures by:

a. Resolving the Air Traffic Organization’s concerns with the draft guidance that authorizes

third parties to develop instrument flight procedures.

FAA Response: Concur. AFS and ATO senior managers continue to be actively engaged in

discussions to remedy these concerns and have set a target date of March 31, 2011 for resolving

them.

b. Evaluating and clarifying the 2008 Memorandum of Agreement between the Flight 

Standards Service and the Air Traffic Safety Oversight Service regarding oversight roles and 

responsibilities between these FAA offices to ensure that oversight functions are properly 

coordinated for all instrument flight procedures and enforcement actions are handled 

consistently.

FAA Response: Concur. Air Traffic Safety Oversight Service (AOV) and AFS managers are

currently reviewing the Memorandum of Agreement (MOA). This MOA was developed in order

for AFS to assist AOV in audits, when requested. A thorough review of this MOA will be

completed by March 31, 2011.

c. Establishing a procedure for Flight Standards to coordinate with the RNAV/RNP program 

office on any request from industry to develop special RNP procedures that have national 

implications to ensure that these procedures do not conflict with procedures that already exist 

or are being created.

FAA Response: Nonconcur. Existing guidance outlined in FAA Order 8260.43A, Flight

Procedures Management Program, set forth adequate procedures for coordination with all

concerned lines of businesses on any request from industry to develop special RNP procedures.

This guidance has been in effect for seven years.

This FAA Order establishes the Regional Airspace Procedures Team (RAPT). The RAPT is the

FAA’s regional point of contact responsible for coordinating, prioritizing, and evaluating requests 

for establishment, amendment, and cancellation of flight procedures within the regional

boundaries.

It is intended that the RAPT provide a coordinated FAA response to customer requests and needs

related to flight procedures. As directed by the order, the RAPT is specifically responsible for

developing and maintaining a process for the receipt, review, control, and tracking of flight

procedure requests, suggestions, and initiatives from FAA and other sources so that procedures

are compatible with national and international concepts, plans, goals, priorities, and objectives.
25

Appendix. Agency Comments

The RAPT is also responsible for supporting national programs and industry activities in matters

associated with flight procedures. It also provides expertise to users and service providers

regarding implementation of satellite-based flight procedures in the National Airspace System and 

solicits suggestions and recommendations regarding RNAV and RNP implementation.

The Order also specifies that special procedure requests are considered and processed by the

RAPT in the same manner as standard procedures. Following recommendation by the RAPT and 

other required processing and development, special procedures are certified by the Flight

Technologies and Procedures Division, AFS-400, and forwarded to the appropriate AFS Division 

for issuance to general aviation operators via letter of authorization from the local Flight 

Standards District Office or to air carriers via operations specifications from its certificate holding 

office.

The specific example referred to on page 15 of the report concerning the Southwest Airlines RNP 

initiative at Dallas Love (DAL) and Houston Hobby (HOU) airports appears to have been a

miscommunication. A review of our records indicates the RNAV/RNP Program Office had a

representative at these initial coordination meetings. Additionally, the procedure developer,

Naverus, provided the FAA representative with access to the Naverus web portal for the

“DAL/HOU Early Adopter Program” where preliminary design graphics were posted. FAA

requests that the OIG close this recommendation.