Office of Inspector General

Audit Report

FAA OVERSIGHT IS KEY FOR CONTRACTOR-OWNED 

AIR TRAFFIC CONTROL SYSTEMS THAT ARE NOT

CERTIFIED 

Federal Aviation Administration

Report Number: AV-2011-149

Date Issued: August 4, 2011
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: INFORMATION: FAA Oversight Is Key for 

Contractor-Owned Air Traffic Control 

Systems That Are Not Certified

Federal Aviation Administration

Report Number AV-2011-149

Date: August 4, 2011

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’s (FAA) certification process is an integral 

quality control method to ensure that air traffic control systems, subsystems, and 

services directly affecting the flying public are safe and function as intended. 

FAA has historically owned and operated all key air traffic control (ATC) systems

in the National Airspace System (NAS) but has transitioned more of them to the 

private sector in recent years. In 2007, FAA revised its certification policy to 

require Agency certification for FAA-owned, but not contractor-owned, systems.

Given this policy shift, the former Chairmen of the House Committee on 

Transportation and Infrastructure and Subcommittee on Aviation requested that 

we assess the impact of the certification change on FAA’s overall responsibility 

for maintaining the safety and integrity of key NAS systems. Specifically, they 

cited concerns that this change could reduce FAA’s visibility into the quality and 

performance of these systems. For example, while FAA will use the Automatic 

Dependent Surveillance - Broadcast (ADS-B) system1

 1 ADS-B is a satellite-based surveillance technology that is designed to supplement radar, using aircraft avionics and 

ground-based systems to provide information on aircraft location to pilots and air traffic controllers. 

—which is expected to be a 

cornerstone of the Next Generation Air Transportation System (NextGen)—for 

moment-by-moment control of aircraft, FAA will not certify the system’s 

contractor-owned ground infrastructure. Accordingly, our objectives were to 

(1) assess the impact of FAA’s revised certification policy on the safety and 

integrity of air traffic control systems, such as ADS-B, and (2) identify 
2

vulnerabilities that FAA faces in relying on private sector ownership of key air 

traffic management systems.

We conducted this performance audit in accordance with generally accepted 

government auditing standards. Exhibit A details our scope and methodology, and 

exhibit B lists facilities visited or contacted.

RESULTS IN BRIEF

FAA is gaining insight from its experience using monitoring rather than 

certification to ensure the ADS-B ground infrastructure meets FAA’s standards. 

Therefore, FAA’s justification for this decision is not fully developed, and as such, 

we could not fully assess the outcomes of FAA not certifying contractor-owned 

systems. Regardless, the outcomes are of critical importance because FAA is 

solely responsible for maintaining the safety and integrity of the NAS. In the case 

of ADS-B, FAA has developed an active monitoring system called the 

Surveillance and Broadcast Service (SBS) monitor that is intended to help FAA 

ensure the ground equipment at each individual ADS-B site is working. There are 

risks with this oversight approach. In particular, FAA has not developed

automated means and procedures to analyze the large amount of performance data

that the SBS monitor generates or assigned sufficient staff to do the analyses. 

Also, FAA has not ensured the network design for the SBS monitor works as 

intended and is a reliable tool that can help FAA avoid and resolve outages. 

As FAA shifts from operating its own systems to overseeing contractor-owned and 

-managed systems, the Agency is vulnerable to losing long-term visibility into 

NAS system performance. While the SBS monitor may prove a viable alternative 

to certification for ADS-B, it is unique in the NAS. FAA does not formally 

require such a monitoring capability for all NAS systems regardless of ownership 

and instead makes this decision on a case-by-case basis for contractor-owned 

systems. These systems, however, will be a large part of the NAS and, as such,

FAA’s inconsistent application of its own quality standards, such as remote 

monitoring, poses a risk of inadequate performance. A second vulnerability facing 

FAA, as more contractor-owned systems are allowed into the NAS, is inadequate 

logistics support. Contractor oversight is resource intensive, and FAA will need 

assurance that contractor systems meet FAA reliability standards. However, FAA 

has serious shortfalls in logistics personnel—a critical concern since we found that 

FAA’s logistics staff provide significant technical expertise and oversight of the 

contractor-owned ADS-B equipment and networks. Securing this expertise is 

especially vital in cases where FAA must assume greater control, especially when 

the contractor has inadequate logistics and maintenance support, which has 

occurred in the past.
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We made six recommendations to FAA to address immediate risks with an 

independent monitoring capability and potential vulnerabilities as the Agency 

becomes more reliant on contractor-owned NAS systems. FAA concurred with all 

of our recommendations, but we have requested that the Agency clarify its 

response for two of them. 

BACKGROUND

FAA maintains a comprehensive certification process designed to ensure that all 

NAS systems, subsystems, and services work safely.

2

 According to FAA, 

certification is a quality control method used by the Air Traffic Organization’s 

Technical Operations staff to ensure NAS systems and services are performing as 

expected.3 FAA certification encompasses several “levels”4 and is accomplished 

by having a credentialed5 FAA technician check and test systems or pieces of 

equipment on a periodic basis to ensure that they can be safely operated or 

returned to service and will not negatively impact any aspect of the NAS. FAA 

has criteria for determining which NAS systems and services require certification.6

• Moment-by-moment positional information to pilots or Air Traffic personnel 

during aircraft operations or communications control during these operations

 

The criteria dictate that certification is required if a NAS system provides any of 

the following:

• Essential meteorological information for aircraft taking off and landing

• Decision support information that could directly affect aircraft heading, 

altitude, routing, control, or conflict awareness

In September 2007, FAA revised its certification procedures to clarify that only 

“FAA-owned or -maintained NAS systems” must be certified. Previously, FAA 

did not specify ownership or maintenance responsibility as a specific requirement 

for certification. According to FAA, the revision to its certification procedures 

was made due to the 2005 transfer of FAA’s flight services operations to 

Lockheed-Martin (except those provided by FAA-owned and maintained systems 

 2 FAA’s legal authority for certifying systems is Title 49, U.S.C. Sec. 44502, which states the FAA Administrator 

may (a) acquire, establish, improve, operate, and maintain air navigation facilities and (b) provide facilities and 

personnel to regulate and protect air traffic. FAA’s certification process is described in Order 6000.15E. 3 FAA Order 6000.30D, “National Airspace Maintenance Policy.” 4 Every higher level encompasses the levels below it. Equipment is the lowest, then Sub-System, System, and finally 

Service, which is the highest level of certification. 5 FAA issues certification credentials to individuals who have attained a professional level and are responsible for the 

operation and performance of air traffic control facilities. The credentials process is a confirmation that the 

individual possesses the knowledge and skills to assume responsibility for the operations of a service, system, or 

subsystem. 6 FAA Order 6000.15E, “General Maintenance Handbook for NAS Facilities.”
4

in Alaska) under the FS-21 contract.7

In applying the revised procedures to ADS-B, FAA will certify the ADS-B data 

provided by avionics on ADS-B-equipped aircraft and at the FAA facilities using 

or routing the ADS-B data

However, FAA did not formally implement 

the policy change until 2007, soon after the Agency awarded a service-based 

contract to ITT for ADS-B. Under the contract terms, the Agency will own 

ADS-B surveillance data transmitted, and the design and configuration of the 

system, but ITT will own the hardware and ground infrastructure used to transmit 

the signal to FAA’s air traffic control facilities. 

8

Figure 1. FAA Depiction of ADS-B Service Certification

(see figure 1 below). However, FAA will not certify 

the hardware components that make up ITT’s ground system. 

Source: OIG, based on a graphic by FAA

FAA states that it will certify ADS-B data similarly to how it certifies radar data. 

According to FAA, the ADS-B signal contains electronic metrics intended to 

assure accuracy and integrity through continuous automatic monitoring; therefore, 

FAA maintains it does not need to certify ITT’s ground infrastructure that 

transmits the data.

 7 Flight service stations provide aeronautical information, such as weather briefings, flight planning assistance, and 

aeronautical notices. In 2005, FAA awarded a contract to Lockheed Martin to provide flight services under the 

Flight Services-21 (FS-21) program. See OIG Report Number AV-2007-048, “Controls Over FAA’s Conversion of

Flight Service Stations to Contract Operations,” May 18, 2007. OIG reports are available on our Web site: 

http://www.oig.dot.gov/. 8 FAA’s certification process includes certification of avionics in accordance with Technical Standard Orders and 

Advisory Circulars and technician certification at the automation platform.

Note: ITT’s ground 

infrastructure is not certified.
5

MONITORING RATHER THAN CERTIFYING AIR TRAFFIC 

CONTROL SYSTEMS SUCH AS ADS-B PRESENTS RISKS

FAA’s decision to require certification only for FAA-owned, not contractorowned systems did not change the Agency’s responsibility for the safety and 

integrity of the NAS. However, it is too early to gauge the full impact of this 

decision because FAA is only in the early stages of its experience with systems, 

such as ADS-B, that are not certified under this new approach. FAA uses an 

automation tool, the SBS monitor, to alert FAA if ADS-B components are 

unreliable for managing air traffic due to outages or discrepancies. Tests of the 

monitor indicate it aids FAA’s oversight of ADS-B’s performance, but there are 

risks with this approach that FAA has not addressed and that will be especially 

important if it decides to use similar tools to oversee other contractor-owned 

systems. First, only a fraction of the 800 planned ADS-B ground sites are 

operational. Yet, the SBS monitor is already generating more performance data 

than the assigned FAA staff have time to analyze. Further, FAA is still developing 

automated means and procedures for such data analysis. Second, the ADS-B 

contractor is still implementing a remediation plan in response to an 11-hour 

ADS-B outage last summer that affected air traffic over the Gulf of Mexico and 

disabled the SBS monitor. This outage highlights FAA’s dependency on the 

monitor for visibility into the ADS-B network’s operational status. Consequently, 

the effectiveness of FAA’s contractor oversight using monitoring in lieu of 

certification will only be as reliable as the monitoring tools FAA develops and 

deploys.

FAA Has Limited Experience With the SBS Monitor and Lacks Means

To Analyze the Performance Data

Early tests of the SBS monitor indicate it will aid FAA’s oversight of ADS-B 

system performance. However, FAA has limited experience overall with the 

monitor. As of late April 2011, the monitor was covering 335 of the 

approximately 800 transceivers ITT intends to deploy nationwide. Moreover, the 

Agency has yet to develop a means to analyze the extensive volume of 

performance data the monitor generates or assign sufficient staff for that purpose.

Until FAA addresses these issues, it is not clear whether FAA’s monitoring plan 

will be sufficient to actively monitor all 800 ADS-B ground transceivers, once 

deployed, to ensure FAA’s requirements are being met. 

FAA has installed two SBS monitors at a cost of $10.4 million: one at the FAA 

Technical Center in Atlantic City, NJ, and one at the FAA Aeronautical Center in 

Oklahoma City, OK. Originally, FAA planned to deploy more than 20 monitors, 

but based on a cost-benefit analysis, FAA decided to deploy just the 2 systems. 

During actual testing, we observed that the SBS monitor: 1) displayed known outof-service transceiver sites in Alaska—depicting the “red alert” status for 
6

non-functioning equipment and providing green indications for functioning 

equipment—and 2) allowed continuous “24/7” automated coverage that is not 

possible through periodic site visits by a certified technician. 

While these tests showed that the SBS monitor is useful, it is important to note that 

the SBS monitors convey a large amount of information about the ADS-B system 

that requires FAA to commit both staff resources and develop procedures for 

analyzing this information. Specifically, each monitor displays graphics and text 

(see figure 2 below) showing the status of ITT’s ground transceivers. This 

information is intended to provide FAA personnel with enough detail to examine 

component performance within each of ITT’s transceiver stations and help assess 

whether the contractor is meeting contract specifications.

Figure 2. SBS Monitor Displaying ADS-B Transceiver Station Data

Source: OIG picture at Oklahoma City, OK

However, FAA has yet to develop automated analyses capabilities for the 

performance data or procedures for analyzing and using the performance data 

collected from each site to help verify the reliability of the ADS-B ground system 

components. After the first 83 ground stations were deployed, the monitoring 

system was already generating 1,100 pages of data per month on the reliability of 

individual system components. Moreover, according to FAA officials responsible 

for the design and deployment of the SBS monitor, four staff are required to 

analyze the data that the monitor delivers, but only two have been assigned despite 

requests to the program office for additional resources. In sum, the SBS tool will 

not be a fully effective monitor of the ADS-B system without procedures and 

capabilities in place to analyze the system’s data. This will be further exacerbated 
7

given the massive increase of data that will come with full deployment of 

800 ground stations.

The SBS Monitor Proved To Be Unreliable During an ADS-B Network 

Outage, Validating Risks

According to FAA, the data from the SBS monitor are essential to verify whether 

FAA can rely on the ADS-B ground system and identify trends in performance. 

However, relying on these data also presents risks, particularly in light of the 

monitoring system’s vulnerability to network failure. During an August 2010 

ADS-B network outage, the SBS monitor failed to work as intended and proved 

unreliable. The outage, which lasted more than 11 hours and affected traffic 

throughout the Gulf of Mexico, required controllers to manually separate ADS-Bequipped aircraft in non-radar airspace,

9 and revealed a weakness in the ADS-B 

network design. At the time of the outage, ITT was operating a single network 

hub (called a National Operations Center) without a back-up capability.10

A subsequent FAA independent test report in September 2010

 When 

the network outage occurred, surveillance data transmitted by ITT’s ground 

system through the hub stopped reaching FAA control centers. At the same time, 

the SBS monitors stopped receiving ground equipment status information because 

this information also flows through the hub and not directly from ITT’s ground 

system components. This outage demonstrated that unless FAA receives direct 

input from each of the 800 planned ITT transceivers, the Agency will not have 

independent assurance that the ground system is performing to FAA’s 

specifications. According to FAA, ITT is implementing an ADS-B Outage 

Remediation Plan, which includes providing back-up communication between ITT 

and FAA locations from a second network hub. The majority of the remediation 

work was completed during the second quarter of fiscal year 2011.

11

 9 Much of the air traffic in the Gulf of Mexico consists of low-flying helicopters servicing hundreds of off-shore oil 

platforms.

further 

underscored the need for an effective SBS monitor that alerts FAA to performance 

problems in the ITT ground system and highlighted the need to expedite this 

effort. The report stated that the ADS-B system remains vulnerable to an outage 

and noted significant gaps in reporting procedures and communication between 

facilities that manage air traffic, Agency operational control centers, and 

scheduled and unscheduled ADS-B maintenance activities. Additionally, the 

report stated that training for more than 100 FAA staff on diagnosing problems 

with ADS-B was either inadequate or not provided in a timely manner. FAA has 

begun addressing the report’s recommendations, which included that the ADS-B 

program office assess gaps in communication and procedures for ADS-B outages, 

10 The NOC is the hub into which all ADS-B surveillance data flows before being transmitted to controllers’ displays. 11 Office of Independent Safety Assessment, Automatic Dependent Surveillance-Broadcast (ADS-B) Critical Services 

Independent Operational Test and Evaluation (IOT&E) Report, September 10, 2010.
8

implement solutions to those gaps, improve notification procedures to ensure realtime reporting of service status to FAA facilities, and develop comprehensive 

training on ADS-B and the SBS monitor. 

Another event that demonstrated the need for an independent and reliable FAA 

monitoring capability occurred in November 2009, when the contractor-owned 

and operated FAA Telecommunications Infrastructure (FTI) experienced an 

outage that delayed more than 800 flights nationwide. As we reported in June 

2010,12

FAA FACES POTENTIAL LONG-TERM VULNERABILITIES IN 

EFFECTIVELY OVERSEEING CONTRACTOR-OWNED SYSTEMS

the FTI outage exposed key limitations on FAA’s and the prime 

contractor’s abilities to oversee FTI, as neither could readily identify the specific 

components that failed or their location in the NAS. During our review of the FTI 

outage, the Air Traffic Organization’s Chief Operating Officer told us that a 

“paradigm shift” in how FAA oversees contractor-owned systems is needed. This 

is particularly important given that FAA plans to rely on a contractor to develop 

and implement Data Communications—a NextGen transformational program that 

will require a multibillion-dollar investment. 

FAA’s shift from operating its own systems to overseeing contractor-owned and 

-managed systems exposes the Agency to several long-term vulnerabilities that 

may limit its visibility into NAS system performance. First, contactor-owned 

systems are expected to be fully integrated into the NAS, but it is not clear 

whether FAA is fully committed to applying FAA safety and quality control 

standards equally to all systems regardless of ownership. In addition, oversight of 

the early ADS-B deployment is resource-intensive and, in particular, requires 

logistics expertise to oversee the contractor’s infrastructure. However, FAA has a 

personnel shortfall for these essential services Agency-wide. Having the right 

logistics expertise takes on greater importance in cases where contractor logistics 

support plans for contractor-owned systems have proven inadequate and FAA has 

had to assume control of contractor logistics and maintenance, which the Agency 

did in 2010 for the Standard Terminal Automation Replacement System (STARS). 

FAA Standards, Such as Remote Monitoring, Are Not Consistently 

Applied to Contractor-Owned Systems

As the number of privately owned systems that are expected to be fully integrated 

into the NAS expands, FAA is at increased risk of inadequate contractor 

performance by not applying the same standards to contractor-owned systems that 

it requires for its own systems. This is particularly a risk given that FAA’s 

 12 OIG Correspondence CC-2010-012, “Letter to Chairmen Oberstar and Costello Regarding the 2009 FAA 

Telecommunications Infrastructure Outage,” June 17, 2010. 
9

commitment to equally applying these standards has not always been 

demonstrated. Most notably, the SBS monitor is unique to ADS-B and an 

alternative to certification; FAA has yet to require a similar type of monitoring 

capability for all NAS systems regardless of ownership. In the past, FAA required 

that new NAS systems had to be remotely monitored—a requirement that enables 

continuous independent oversight regardless of how far a remote system may be 

located from an observer who can determine whether that system is performing in 

accordance with FAA specifications. However, FAA recently approved a revised 

order on remote monitoring of NAS systems that allows the decision of whether 

remote monitoring will be required for contractor-owned systems to be made on a 

case-by-case basis. FAA’s dependency on the SBS monitor demonstrates the 

critical need for this type of capability to oversee the ADS-B ground 

infrastructure. Without a similar type of capability for other contractor-owned 

systems, FAA could jeopardize the Agency’s visibility into system performance, 

and of greater importance, the safety and reliability of the NAS.

Drawing distinctions between FAA-owned and contactor-owned systems in terms 

of requiring a monitoring capability sets a precedent that exposes FAA to potential 

vulnerability should FAA also decide to not hold contractors to other quality and 

performance standards. To provide assurance that contractor-owned systems will 

meet FAA’s needs before putting them into operation, FAA has a series of 

established operating orders. For example, all FAA-owned systems are required 

to pass the following:

• Factory, service, and site acceptance tests to ensure that systems meet FAA 

standards and that FAA has a presence throughout the development and 

implementation cycle.

• Functional and physical configuration audits to ensure that components are 

manufactured and installed to specifications and standards.

• Independent operational tests and evaluations to ensure that FAA 

independently verifies that systems meet Agency requirements after 

implementation.

ADS-B implementation in Florida demonstrated the importance of taking steps to 

ensure that contractor-owned systems meet the same standards as those for FAAowned systems. During a product configuration audit, which FAA requires for all 

newly deployed systems, regardless of ownership, FAA field personnel correctly 

identified that an ADS-B transceiver was installed with no back-up transmitter 

system, although the blueprints for the site called for a back-up. Had FAA’s 

requirements to conduct a configuration audit not been applicable to contractor-
10

owned systems, this critical issue may not have been identified until the 

transceiver failed and the absence of a back-up capability had been revealed.

FAA’s Logistics Support Needed for Effective Contractor Oversight Is 

Inadequate 

Contractor oversight is resource intensive and requires the right expertise in a 

number of essential areas, one of which is logistics support. However, FAA has 

serious shortages in the logistics personnel needed to oversee these essential 

services Agency-wide. We cautioned in an October 2007 hearing before the 

House Aviation Subcommittee that FAA’s approach for implementing ADS-B 

would require an extraordinary level of oversight.13 Currently, the ADS-B 

program office is using both contractor and in-house staff to oversee ITT’s ADS-B 

implementation. More specifically, as we observed with ADS-B, staff at FAA’s 

Logistics Center in Oklahoma City, OK, are heavily involved in providing 

technical expertise and oversight of the contractor-owned equipment and 

networks. However, once the ADS-B infrastructure is fully deployed, FAA will 

require a different skill mix; specifically, more internal expertise in contracting, 

logistics, and program management and less expertise in research and acquisition. 

FAA’s 2010 fiscal year budget submission indicated that it identified a “serious 

shortage of government personnel” to oversee logistics services Agency-wide. As 

an important step to address this shortage, FAA requested a funding increase from 

its 2009 budget and included increased numbers of logistics personnel as an item 

in its initial acquisition workforce plan. We have work underway to examine 

FAA’s progress in addressing these issues.14

Securing the necessary logistics expertise takes on greater urgency in cases where

FAA’s logistics support plans for contractor-owed systems may not be adequate.

FAA requires contractors to prepare a logistics support plan to ensure that they 

will provide satisfactory system support and maintenance throughout the life of 

the contract, but this method has proven limitations. For example, in 2010, FAA 

assumed control of the maintenance and logistics for STARS (Standard Terminal 

Automation System) after the Agency determined it was financially advantageous 

to perform these functions in-house. However, according to the FAA logistics 

center, the turnover was complicated because the contractor did not maintain 

adequate logistics information about the STARS system. While contractors are 

required to prepare logistics support plans for FAA approval, FAA can find itself 

vulnerable should these support plans not include sufficient documentation, such 

as parts numbers and supplier information. FAA’s experience with STARS 

demonstrated how this vulnerability can manifest itself.

 13 OIG Testimony Number CC-2007-100, “Challenges Facing the Implementation of FAA’s Automatic Dependent 

Surveillance - Broadcast Program,” October 17, 2007. 14 OIG Audit Announcement, “FAA’s Acquisition Workforce,” issued November 23, 2009.
11

CONCLUSION

FAA is embarking on an urgently needed transformation of the Nation’s air traffic 

system, and certification of NAS systems is important to ensure that new systems 

perform as intended and do not negatively impact safety. Regardless of ownership

and whether systems are certified, FAA cannot afford to lose visibility into system 

performance. While we focused on FAA’s efforts to monitor the performance of 

the uncertified ADS-B ground infrastructure in our audit, our results indicate that 

similar levels of contract oversight will be essential for all future NextGen-critical

technologies that are contractor-owned but not certified. Our work also highlights

a number of vulnerabilities that FAA faces and must mitigate in carrying out this 

oversight. Otherwise, the full impact of FAA’s transition of systems and services 

to the private sector and the revised certification procedures will remain uncertain 

as will the Agency’s ability to safely integrate contractor-owned systems into the 

NAS. 

RECOMMENDATIONS

We recently made a number of recommendations to FAA to reduce risk and 

enhance contract oversight of ADS-B, which FAA has concurred with and begun 

to address.

15

As a result of this audit and to further reduce risk with the SBS monitor, we 

recommend that the SBS program office:

In addition, FAA is responding to recommendations from an 

independent safety report that addressed improving training on ADS-B and the 

SBS monitor for technicians and supervisors, including how to diagnose system 

problems. 

1. Complete the development of automated capabilities and procedures for 

analyzing the contractor performance data being collected from the SBS 

monitoring system. 

2. Evaluate the number of FAA staff currently assigned to analyze the extensive 

volume of data the SBS monitoring system generates and require additional 

resources be allocated as appropriate. 

3. Document and apply the lessons learned from the August 6, 2010, ADS-B 

outage to improve the SBS monitor’s functionality and performance. 

Specifically, as part of the remediation plan, take steps to ensure real-time 

reporting of ITT transceiver service status directly to the SBS monitoring 

system from each ADS-B ground system transceiver site. 

 15 OIG Report Number AV-2011-002, “FAA Faces Significant Risks in Implementing the Automatic Dependent 

Surveillance–Broadcast Program and Realizing Benefits,” October 12, 2010.
12

To address potential vulnerabilities as FAA becomes more reliant on contractorowned systems in the NAS, we recommend that FAA:

4. Apply FAA standards and quality assurance practices to all NAS systems 

regardless of ownership. 

5. Assess the costs and benefits of requiring a monitoring capability, similar to 

the SBS monitor for ADS-B, in lieu of certification for all contractor-owned 

systems in the NAS and require that capability to be developed as appropriate.

6. Acquire the logistics expertise needed to oversee all contractor-owned systems 

in the NAS to include requiring that contractor logistics support plans contain 

sufficient documentation regarding system maintenance.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided FAA with our draft report on June 21, 2011, and received its 

response on July 20, 2011. FAA’s response is included in its entirety as an 

appendix to this report. FAA concurred with all of our recommendations, and the 

planned actions and milestones meet the intent for most of them. However, we are 

requesting that FAA clarify its actions regarding recommendations 5 and 6.

For recommendation 5, FAA identified several systems, in addition to ADS-B, for 

which the Agency relies on a monitoring capability. For future systems, FAA

states that each program will separately assess the costs and benefits of having a 

monitoring capability in accordance with the Agency’s Acquisition Management 

System policy. While we acknowledge the importance of adhering to existing 

policies in making these decisions, it is unclear from FAA’s response whether its 

decisions to require monitoring capabilities will be based on the cost and benefit 

analyses or the priority the Agency will give monitoring capabilities in light of 

other investment decisions. FAA’s dependency on the SBS monitor demonstrates 

the critical role of this type of capability in overseeing contractor-owned systems. 

FAA’s response does not specifically recognize the critical importance of 

contractor monitoring for future programs, which is the intent of our 

recommendation. Accordingly, we are requesting that FAA clarify its response. 

For recommendation 6, FAA states that it will provide training to certify 

25 contractor logistics specialists, which we agree is an important step forward. 

However, it is unclear how FAA has determined that 25 is the appropriate number 

of logistics specialists needed to oversee current and future contractor-owned 

systems, as well as review contractor logistics support plans for sufficiency and 

adequacy. Therefore, we are requesting that FAA provide additional details for 
13

determining how many logistics specialists will be needed to oversee these 

essential services Agency-wide, and describe its plan for achieving that goal.

ACTIONS REQUIRED

FAA’s planned actions and target dates for recommendations 1, 2, 3, and 4 are 

responsive, and we consider these recommendations resolved but open pending 

completion of planned actions. However, we request that FAA clarify, within 

30 days of this report, its responses to recommendations 5 and 6. Specifically, for 

recommendation 5, we request that FAA clarify whether the Agency will formally

require a monitoring capability for future contractor-owned systems based on cost 

and benefit analyses. For recommendation 6, we request additional details 

regarding its plan to acquire the logistics support specialists that are needed to 

oversee current and future services Agency-wide.

We appreciate the courtesies and cooperation of FAA and industry representatives 

during this audit. If you have any questions concerning this report, please contact 

me at (202) 366-0500 or Barry DeWeese, Program Director, at (415) 744-0420. 

#

cc: FAA Deputy Administrator 

Vice President for En Route and Oceanic, Air Traffic Organization

Vice President Terminal Services, Air Traffic Organization

Anthony Williams, AAE-001

Martin Gertel, M-1
14

Exhibit A. Scope and Methodology

EXHIBIT A. SCOPE AND METHODOLOGY

We conducted this performance audit 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 objective. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions. We 

conducted the audit between October 2009 and June 2011 and included such tests of 

procedures and records as we considered necessary, including those providing 

reasonable assurance of detecting abuse and illegal acts.

To conduct our work, we examined documentation provided by the program office 

related to the Air Traffic Certification Process and the ADS-B program. 

Specifically, we reviewed ADS-B implementation plans, test results, and contract 

documentation related to scope of work and technical performance requirements. 

We analyzed sections of FAA’s acquisition management system and orders related 

to certification, logistics, maintenance, and operations. We also interviewed FAA 

administration personnel, program office officials, industry, and union 

representatives to discuss the rationale for, and impact of, the 2007 change in 

certification requirements. Additionally, we reviewed FAA presentations for 

ADS-B made to stakeholders, Performance Control Board presentations; and other 

documentation that were provided by FAA to industry, government and Congress. 

During the audit, we contacted or visited FAA Headquarters, ADS-B Program 

Office, the FAA Technical Center and Logistics Center, Air Carriers, ITT offices, 

and various Key ADS-B field sites. At those locations, we discussed a range of 

topics to include role in the certification process for FAA-owned facilities and 

potential vulnerabilities of private sector ownership of NAS systems. 
 15

Exhibit B. Facilities Visited or Contacted 

EXHIBIT B. FACILITIES VISITED OR CONTACTED

Industry Contacts

• Boeing Traffic Management

• ITT Corporation

• Alaska Air Carriers Association

FAA Headquarters, Washington, DC

• Surveillance Broadcast System Program Office, Washington, D.C.

FAA Field Locations 

• FAA Logistics Center and Aviation System Services at Oklahoma City, OK

• FAA Technical Center, Atlantic City, NJ

• Alaska Regional Office, Air Route Traffic Control Center, and Aircraft 

Certification Office in Anchorage, AK (Juneau Key Site)

• Southwest Regional Office, Houston, TX (Gulf of Mexico Key Site)

• Southern Region, College Park, GA (Louisville, KY Key Site)
16

Exhibit C. Major Contributors to This Report

EXHIBIT C. MAJOR CONTRIBUTORS TO THIS REPORT

Name Title

Barry DeWeese Program Director 

Chuck Ward Project Manager

Gregg Bond Senior Analyst 

Henning Thiel Analyst

Andrea Nossaman Writer-Editor

Audre Azuolas Writer-Editor
17

Appendix. Agency Comments

APPENDIX. AGENCY COMMENTS

Federal Aviation

Administration

Memorandum

Date: 

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

Program Audits 

From: Clay Foushee, Director, Office of Audit and Evaluation, AAE-1 

Subject: OIG Draft Report: FAA Oversight Is Key for Contractor-Owned Air 

Traffic Control Systems That Are Not Certified 

The Federal Aviation Administration’s (FAA) NextGen implementation will be 

comprised of both FAA owned and operated systems as well as provisioned services 

provided by private corporations. Regardless of how a given capability is established 

within the National Airspace System (NAS), the FAA recognizes that through a 

combination of its Safety Management System policy, it's AMS policy and its life cycle 

maintenance policy that fielded systems/services must be certified in order to maintain 

the target level of safety for the respective NAS capability.

Achieving NextGen benefits requires that the agency integrate new technologies and 

evolve both its oversight and business process roles. In the latter, the coordination of the 

respective policies identified above and their implementation is expected to provide this 

oversight and ensure compliance of all systems/services proposed for NAS integration. 

There is some work still to be done in this regard and our responses below indicate both 

progress for the specific Surveillance Broadcast System (SBS) program as well as plans 

for policy and practice implementation for other similar proposed systems and services in 

the future. 

OIG Recommendation 1: Complete the development of automated capabilities and 

procedures for analyzing the contractor performance data being collected from the SBS 

monitoring system.

FAA Response: Concur. The SBS Program Office will complete the development of 

automated capabilities and procedures for analyzing the contractor performance data 
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Appendix. Agency Comments

being collected from the SBS monitoring system by June 2012 with an interim software 

build for the SBS monitor in December 2011.

OIG Recommendation 2: Evaluate the number of FAA staff currently assigned to 

analyze the extensive volume of data the SBS monitoring system generates and require 

additional resources be allocated as appropriate.

FAA Response: Concur. The SBS Program office recently approved, and is funding, an 

additional 6 FTEs for SBS Monitor data analysis. Additional resources from other FAA 

organizations will also be engaging in SBS Monitor data analysis, including Second 

Level Support, the Operational Support Facilities, and the Program Operations Field 

Managers. By December 2011, a draft In Service Management Plan will be developed 

which will contain details on how the FAA will manage and monitor the operations of the 

SBS service, including resource requirements.

OIG Recommendation 3: Document and apply the lessons learned from the August 6, 

2010, Automated Data Surveillance–Broadcast (ADS-B) outage to improve the SBS 

monitor's functionality and performance. Specifically, as part of the remediation plan, 

take steps to ensure real-time reporting of ITT transceiver service status directly to the 

SBS monitoring system from each ADS-B ground system transceiver site. 

FAA Response: Concur. The FAA has documented a step-by-step outage remediation 

plan which is being updated monthly and reported to the COO. To prevent further SBS 

Network Outages as well as address the General Accountability Office’s 

recommendations to account for human factors in NextGen implementation, SBS is 

executing a 4-pronged approach to strengthen the reliability and resilience of the ITT 

network: 1) ITT Human Process Intervention; 2) ITT Improvement in preventing 

outages; 3) ITT Improvement in restorative services: and 4) FAA- ITT joint 

preventative measures. The majority of planned steps have been completed. The details 

of this remediation plan are reported in Attachment 1.

The remaining two steps are: A) Investigate improvements and implement corrective 

actions in the communications between ITT and FAA Operational Control Centers and 

Service Delivery Points, planned completion is November 30, 2011; and B) Closely 

monitor service and radio reliability and take corrective actions as needed. On-going 

analyses have been established through the use of an FAA Monitor that provides detailed 

monthly reports. The planned completion date of the final step and the overall 

remediation plan is December 30, 2011.

OIG Recommendation 4: Apply FAA standards and quality assurance practices to all 

NAS systems regardless of ownership.

FAA Response: Concur. The Safety Division of the Air Traffic Organization will work 

with Technical Operations and the program offices to develop methods and standards 

specifically designed to provide quality assurance practices toward all NAS systems 

regardless of ownership. As an example, we are presently updating our NAS 
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Appendix. Agency Comments

Maintenance Policy to distinguish our provisioning services with systems such as ADSB. We will complete a draft strategy by 

October 31, 2011. 

OIG Recommendation 5: Assess the costs and benefits of requiring a monitoring 

capability, similar to the SBS monitor for ADS-B, in lieu of certification for all 

contractor-owned systems in the NAS and require that capability to be developed as 

appropriate. 

FAA Response: Concur. Currently, the agency accomplishes very similar monitoring, 

oversight & performance assurance for other FAA owned & leased systems utilizing 

Remote Maintenance Monitoring (RMM), Remote Maintenance Logging System 

(RMLS), National Airspace System Performance Analysis System (NASPAS), Operation 

Control Centers (OCC), and the National OCC (NOCC). The ADS-B monitoring will be 

accomplished in accordance with the “Technical Operations Services Maintenance 

Concept of Operations for 2014 and Beyond,” dated May 27, 2011. Additionally, the 

management of provisioned services is delineated in the draft “Order 6000.30E, National 

Airspace System Maintenance Policy”, which is currently under review.

For any future systems, as the monitoring for each service provision is unique to that 

acquisition, the Air Traffic Organization (ATO) standardizes the need for certification 

through the tech ops maintenance policy, but manages the specific response and its 

cost/benefit analyses through Acquisition Management System (AMS) policy. AMS 

policy applies to all acquisitions regardless of whether they are FAA owned systems or 

private service provisions. Recent changes to AMS policy require that the Vice President 

(VP) for Technical Operations be a signatory for the Implementation Strategy and 

Planning Document (ISPD), which identifies how a given system intends to implement a 

capability, integrates into the NAS and is supported for its life cycle. It is expected that 

this document, along with the functional requirements document, will form the basis for 

subsequent cost/benefit analyses and the acquisition baseline formulation for the 

program. These documents are all presented to the Joint Resources Council (JRC) as the 

basis for any final investment decision. This process ensures that new services have 

feasible and service certification provisions with costs fully understood as part of their 

proposed baseline.

The acquisition executive board (AEB) is currently reviewing this process to ensure that 

all proposed programs are following this process and that ATO Finance includes these 

requirements in their cost validation and cost/benefit analyses. Review and approval of 

practices to ensure this process is part of investment analysis process is part of an 

ongoing the Verification and Validation (V&V) subgroup activity of the AEB. The AEB 

is expected to receive recommended changes to current AMS practices from the V&V 

subgroup in the first quarter of fiscal 

year 2012.
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Appendix. Agency Comments

OIG Recommendation 6: Acquire the logistics expertise needed to oversee all 

contractor-owned systems in the NAS to include requiring that contractor logistics 

support plans contain sufficient documentation regarding system maintenance.

FAA Response: Concur. The FAA Acquisition Workforce Council (AWC) has 

identified integrated logistics support professionals as a critical need in its workforce 

plan. To date, the AWC has identified core competencies, training requirements, and the 

certification path for this profession. Additionally, the FAA has identified 25 Integrated 

Logistics Support specialists in its acquisition workforce. The latest version of this plan, 

to be published in September 2011, will identify certification targets for this population in 

FY 2012. To address the specific needs of contractor-owned systems, by November 30, 

2011 the FAA will conduct a review of its current contractor service provisions to 

establish sufficiency of its logistics support plans and documentation. The output of this 

review will be briefed to the Acquisition Workforce Council at its December 2011 

meeting and will identify skill needs/gaps for contractor service provisions, update 

certification targets for the integrated logistics support population as appropriate, and 

identify additional workforce strategies for meeting such targets.