ToddC. Emerson, #8175 

444 South River Road 

St. George, Utah, 84790 

Telephone: (435)634-3530 

Facsimile: (435)634-3505 

Email: temerson@skywesl.com 

- and -

Michael L. Dworkin #64047 

465 California Street, Suite 210 

San Francisco, California 94104 

Telephone: (415)421-02500 

Facsimile: (415)421-2560 

Email: law@avialex.com 

Attorneys for SkyWest Airlines, Inc. 

0£C22 20H 

.-O 

V 

en 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

SkyWest Airlines, Inc. 

FAA Cases No. 201INM060010 and 06001 

DMS Nos. FAA-2011-0485 and 0486 

SKYWEST AIRLINES, INC.'S 

SUPPLEMENTAL AND AMENDED 

RESPONSES TO COMPLAINANT'S 

INITIAL DISCOVERY REQUEST 

Judge: The Honorable Richard C. Goodwin 

SKYWEST AIRLINES, INC. (hereinafter refeiTcd to as "SKYWEST"), by and 

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

Discover)' Request and Production of Documents, previously filed and served on October 11, 
2011. 

INTRODUCTION AND GENERAL OBJECTIONS 

SKYWEST adopts and incorporates as if fully set forth herein, its objections and 

responses made in SKYWEST's Response to Complainant's Initial Discover}' Request 

referenced above. 

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

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

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

be considered tentative ai best. 

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

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

initial Discover}^ Response on October 11, 2011, has asserted numerous affirmative defenses and 

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

response or admission contained herein, SKYWEST reasserts each and every affirmative defense 

contained in its Answer, which SKYWEST incorporates herein by this reference as if fully set 

forth herein. 

INTERROGATORIES 

The objections set forth above are hereby incorporated herein in their entiret)'. 

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

the Interrogatories as follows: 

201INM0600I0 and 06001 l/DMS Nos. FAAO-2011-0485 and 0486 

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

Page 2 
Interrogatory No. I: Identify by name, address and telephone number all persons whom you 

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

Supplemental and Amended Response: 

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

served objections and responses: 

21. Andrew Avers, Aviation Safety Inspector, FAA SkyWest CMC; and 

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

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

SKYWEST's investigation and discover^' are ongoing and continuing, and SKYWEST 

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

Interrogatory No. 2: Identify by title, dale, author, present custodian, and content, all 

documents, including correspondence, obtained by you or in your 

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

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

matter. See Request for Production No. 1. 

Supplemental and Amended Response: 

In addition to those documents previously identified and/or provided in SKYWEST's 

previously filed and served objections and responses: 

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

to Andrew Ayers, FAA CMO; 

201INM0600I0 and 060011/DMS Nos. FAAO-2011-0485 and 0486 

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

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

to Andrew Ayers, FAA CMO; 

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

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

23. Delta Airlines Flight Operations Manual, 5.6.10-1 I, Flight Planning—Weight 

Data Record. 

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

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

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

impeachment. 

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

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

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

summary of each person's anticipated testimony. 

Supplemental and Amended Response: 

Response to Interrogatory No. 3 is amended as follows: 

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

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

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

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

2011NM060010 and 060011/DMS Nos. FAAO-201 1-0485 and 0486 

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

Page 4 
and to add: 

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

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

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

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

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

and the ostensible reasons therefor. 

SKYWEST further reserves the right to call as its witnesses any persons identified in 

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

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

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

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

Interrogatory No. 4: Identify by title, date, author, present custodian, and content, all 

documents which you anticipate offering into evidence at the hearing in 

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

Production No. 2. 

Supplemental and Amended Response: 

Response to Interrogator)' No. 4 is amended to add: 

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

Andrew Ayers, FAA CMO; 

2011NM060010 and 060011/DMS Nos. FAAO-2011-0485 and 0486 

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

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

Andrew Ayers, FAA CMO; 

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

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

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

Data Record. 

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

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

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

Complainant. 

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

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

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

for purposes of impeachment. 

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

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

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

Supplemental and Amended Response: 

Response to Interrogatory No. 7 is amended to add: 

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

201INM0600I0 and 060011/DMS Nos. FAAO-2011-0485 and 0486 

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

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

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

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

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

with Complainant's Human Factors Policy; and 

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

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

expenditure of resources. 

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

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

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

support of any affirmative defenses raised in any Answer to the 

Complaint, to include identity'ing the specific FAA policy you claim is 

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

Production No. 3. 

Supplemental and Amended Response: 

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

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

FAA AC 120-27E and FAA Orders 2150.3B and 9550.8A. 

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

2011NM060010 and 060011/DMS Nos. FAAO-2011-0485 and 0486 

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

Page 7 
right to amend and/or supplement these responses up through the date of hearing. 

REQUESTS FOR PRODUCTION 

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

Production of Documents, filed and served on October 11, 2011, SKYWEST is producing the 

following responsive documents: 

EXHIBIT DESCRIPTION 

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

Operations to Andrew Ayers, FAA CMO; 

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

Operations to Andrew Ayers, FAA CMO; 

I) Letter dated May 17.2011. from Andrew Ayers, CMO to Chris 

Brown; and 

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

2005. 

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

Planning"—Weight Data Record, said document is proprietar)' to Delta Airlines. SKYWEST wil 

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

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

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

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

201INM060010 and 060011/DMS Nos. FAAO-2011-0485 and 0486 

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

Page 8 
right to amend and/or supplement these responses up through the date of hearing. Finally, 

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

impeachment. 

Dated thi is l/0> ' day o f December, 2011. 

MICHAEI^iJ>^^ORJCIN 

Co-Counsel for SkyWest Airlines 

2011NM060010 and 060011/DMS Nos. FAA0-20n-0485 and 0486 

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

Page 9 
CERTIFICATE OF SERVICE 

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

correct copy of the foregoing SKYWEST'S SUPPLEMENTAL AND AMENDED 

RESPONSE TO COMPLAINANT'S INITIAL DISCOVERY REQUEST was served as 

follows: 

The Honorable Richard C. Goodwin 

Office of Hearings. M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room EI2-

320 

Washington. D.C. 20590 

{Federal Express) 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Ann: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building ~ Suite 2W1000 

{Federal Express} 

Jeffrey M. Harper 

Federal Aviation Administration 

Northwest Mountain Region, ANM-7 

1601 Lind AvenueS.W. 

Renton, Washington 98057 

FAX (425) 227-1007 

{Facsimile and Federal Express} 

OKSANA ZHAR2J4AVSKY 

2011NM0600IO and 060011/DMS Nos. FAAO-2011-0485 and 0486 

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

Page 10 
EXHIBIT 19 

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

Operations to Andrew Ayers, FAA CMO 
SkMks t 

March 2, 2011 

Andrew Ayers 

Aviation Safety Inspector - Air Carrier Operations 

Federal Aviation Administration 

SkyWest Certificate Management Office 

1020 North Flyer Way 

Salt t^tce aty, Ur 84116 

RE: Amendment to SkyWest Weight and Balance Program 

Dear Mr. Ayers: 

This letter is a request for consideration of the enclosed amendment to the SkyWest Airlines Approved 

Weight and Balance Program, Included is the original document with the indusion of an amendment 

containing Human Factors documentation and FAA Order 9550.8A, Human Factors Policy. The addition 

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

the Four Components of Safety Management Systems, 

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

consideration is necessary. SkyWest seeks to employ known Human Factors methods to accomplish tfie 

ulti(nate goal of operational safety. Thank you for your cortsideration. 

Sincerely, 

Chris Brown 

Director of Flight Operations 

cc: Chip Childs 

iCIen Brooks 

Edward Rubottom 

Cari Salamone 

444 South River Road 

St. George, UT84790 

435.6343000 

www.skywest com 
SMWest 

a m AIRLINES ® 

Weight and Balance Program 

Amendment Proposal 

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

Program. This request is desigT>ed to address ttie numerous cargo weight errors that have been 

identified in recent Lett«?rs of Investigation (LOI) from the SkyWest Certificate Management Office, 

Irrterrwl audits of the weigtrt and balance process reveal that while there is the possibility for a gross 

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

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

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

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

this request, SkyWest woukl like to plan proactrvely for small errors in cargo wveight by implementing a 

self imposed limitation on the capabilities of its aircraft. The purpose of this proposal is rwt to allow for 

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

is held paramount at all ti'mes. 

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

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

if the weight was physjcally on tK>ard the aircraft, even though in most cases the weight will not be 

physically present The aircraft operating envelope will be curtailed in such a way that for small 

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

Vbfithin the manufacturer's operating envelope. 

SkyWest has implemented several self imposed limitations in the past. This proposed [imitatk)n is 

similar in nature to these previously approved limitations: 

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

restriction within 4000* of the current aircraft altitude. By instructing flight crews to initiate a 

descent upon receipt of deararKC, SkyWest sacrifices additional fiiel savings in order to 

mirwmize missed crossing restrictions. 

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

CRJ-700/900. Restricting the maximum altitude of CRJ series aircraft provides additiorial stall 

protection at high altitudes. 

• Amending the n«ximum takeoff weight of the assigned Delta Airilne CR700 aircraft to 74,999. 

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

aircraft BOW. Specifically, adding: 

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

• CRJ-200 = 60lbs.or2 starwlard checked bags 

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

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

CRJ 2tK) Specifics 
The additional 60 lbs. will be artificially added into ttie BOW at the BOW center of gravity. By adding the 

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

event that the planr>ed weight is not physically present in the cargo fain, the only performance 

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

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

speed, shorter takeoff and landing distances, etc.) and will remain within all manufacturers limitations at 

all times. 

Because the additional we^ t was planned at the BOW center of gravity, the lack of physical presence 

will have no effect on aircraft CG or trim settings. 

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

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

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

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

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

lbs. in tt>e aft cargo bin. 

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

shift the index aft by 0.44. 

(Bin XArm - 366.42) x Weight 

= Index Shift 10000 

(687 - 520) X 60 

= 0.44 

23000 

Figure 1: CRJ20a Index SNft Calculations 

To compensate for this possible index shift, the aft operating envelope limit will t>e curtailed forward by 

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

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

envelope. 

EMB 120 Specifics 

The calculations for the EMB L20 are very similar to the CRJ 200 because the EMB has a single cargo 

compartment. The indusion of an additional 30 lbs. of cargo will cause the aircraft CG to shift the index 

aft by 0.63. To compensate for this possible shift, tfie aft operating envelope limit will t>e curtailed 

forward by an irtdex adjustrT>ent of 0.63. 
(Bin XArm - 366.42) x Weight 

= Index Shift 10000 

(578-366.42) X 30 

= 0.63 

10000 

Ftgure 2: EMB120 Index Shift C^cUation 

CRi 700 / 900 Specifics 

The CRJ 700 and CRJ 900 are dissimilar fi-om the CRJ 200 and EMB 120 because tf>e CRJ700 and CRJ900 

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

compartments, both the aft and forward limits will be curtailed by the nrrost adverse k>ading 

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

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

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

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

adjustment of 0.48 white the aft operating envek>pe limit will need to t>e shifted forward by and index 

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

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

forward by and index adjustment of 0.74. 

The formulas arxl loading configurations are given in the tables and figures below. 
(Bin XArm - 860) X Weight 

= Index Shift 

40000 

Rgure 3: OUTGO Index Shift Calculation 

CRJ 700 

FWD Cargo Bin (lbs.) 

0 

30 

60 

90 

FWD Index Shift 

0.00 

-0.16 

-0.32 

-0.48 

AJT Cargo Bin (lbs.) 

90 

60 

30 

0 

Aft Index Shift 

0.60 

0.40 

0.20 

0.00 

Total Index Shift 

0.60 

0.24 

-0.12 

-0.48 

Table 1: CRi 700 Index Shift Calculations 

(Bin XArm - 771) x Weight 

- Index Shift 

40000 

Figure 4: CRJ900 Index Shift Calculation 

CRJ 900 

FWD FWD Shift 

0 

0 

0 

0 

30 

30 

30 

60 

60 

90 

0.00 

0.00 

0.00 

0.00 

-0.25 

^.25 

^.25 

-0.50 

-0.50 

-0.75 

Center 

0 

30 

60 

90 

0 

30 

60 

0 

30 

0 

Center Shift 

0.00 

-0.14 

-0.27 

-0.41 

0.00 

U 1 4 

-0.27 

0.00 

-0.14 

0.00 

AFT 

90 

60 

30 

0 

60 

30 

0 

30 

0 

0 

Aft Shift 

0.74 

0.49 

0.25 

0.00 

0.49 

0.2S 

0.00 

0.25 

0.00 

0.00 

Total Shift 

0.74 

0.35 

fl.03 

-0.41 

0.24 

-0.14 

-0.52 

-0.25 

-0,64 

-0.75 

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

however, ensure ttiat operational safety is maintained in any small miscount S(tuatk>ns caused by the 

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

The SkyWest philosophy has been and remains Safety first, with tfiat in mind it is our hope for rapid 

consideration ar»d approval of this request 
Human Factors Apper>dix to Weight and Balance Proposal 

The above proposal invohfes a modification to the SkyWest Weight and Balance program and Is desee d 

to account for limitations on human performarKe. In order to fully understand the motivation and 

reasoning behind such a proposal, it is important to investigate the Human Factors prirKtples driving this 

request. 

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

interface can indude all "psyctiotogical, social, pftystcal, biok^ical and safety characteristics' (1) that 

may affect the manner in %vhtch a human interacts with a system. 

Human Factors is defined as "A multidisdplinary effort to generate and compile information about 

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

procedures, jobs, environments, training, staffing, and personnel management for safe, comfortable, 

and effective human performarKe". (2| 

This proposal investigates the susceptibility for error in the SkyWest Airiines weight and balarKe 

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

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

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

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

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

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

separate cargo twns, each requiring an individual inverrtory. The ramp worker is tasked with the 

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

type of task is referred as a "VigilaiKe" task, wfiereas the human operator is asked to maintain "cSose 

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

changing circumstances" (3). In this case, tt»e particular stimulation is tfie items loaded into the aircraft 

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

human vigilarKe performarKe. Environmental stressors affecting ramp vigitarKe performance irKlude: 

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

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

wil) likely perform at a higher level tftan the ramp agent working a cold, snowy, night in Chicago. In the 

airiine business, a difficult working erwironment is sometimes unavoidable, ar>d the system must be 

designed in a way tfiat will mitigate this risk and prevent error. 

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

strategy. Although current techrK»logy exists to aid in aircraft load manifest error prevention, it Is not 

feasible for implementation in tiie SkyWest system. SkyWest does not contiol the parent policies and 

procedures cor^tnictir^ tf»e framework of the cargo process. These policies and procedures are 

managed by SkyWest's major airiir»e partners (i.e. Delta Airiines, United Airiines) and the introduction of 

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

strategies. Any human interface eiKompasses a liability for error. As an example, "many headlinehitting disasters of the last 15 years have involved human error in the operation of complex 

technological systems. Hollnagel (SL for example, estimates that the icKklence of human error 

contributing to accidents has risen firom about 20% in the 1960*5 to about 80% in 1990* (4). As systems 

in general become more complex and become more mechankally reliable, the portion of risk 

attributable to human error also increases. *7hK position has led many researdiers to advocate the 

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

with tf*e understanding that human operators are rnherentiy fallible, but careful system design can often 

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

create an accident" (5|. SkyWest Airiines is limiting the capabilities of its aircraft in order to design a 

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

should one occur. 

The FAA has accepted and embraced the idea that Human Factors plays a key part in system design. 

FAA Order 9550.8A outlirws the responsibility of all FAA organizations to "Implenwnt error prevention 

and mitigation strategies to emphasize human error reduction" (2). The appendw to FAA Order 9550.8A 

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

[Examine] d^ign and contextual conditions (including supervisory and organizational 

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

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

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

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

SMS composed of (7): 

• Describing the system 

• Identifying the hazards 

• Assessing the risk 

• Analyzing the risk 

• Controlling the risk 

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

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

in place at other US. air carriers. Delta Airiines currently uses a 600 lb. tolerance to account for "last 

minute bag change flexibility' (6). In the DAL program, 'If the numtwr of additional bags k>aded after 

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

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

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

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

small miscount situattons caused b^ limitations on human performance. 
EXHIBIT 20 

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

Operations to Andrew Ayers, FAA CMO 
March 4, 2011 

Andrew Ayers 

Aviation Safety Inspector-Air Carrier Operations 

Federal Aviation Administration 

SkyWest Certificate Management Office 

1020 North Flyer Way 

Salt Lake City, UT 84116 

Re; 14CFR§121.693 

Dear Mr Ayers: 

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

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

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

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

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

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

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

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

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

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

to assure afaso/ute accuracy. 

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

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

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

§ 121.693 Load manifest: All certificate holders. 

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

time: 

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

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

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

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

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

weights: 
Andrew Ayers 

March 4, 2011 

Page 2 

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

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

takeoff time). 

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

compliance with applicable en route performance limitations. 

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

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

the destination airport. 

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

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

airports. 

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

limitations are not exceeded, 

(c) The total weight computed under approved procedures: 

The SkyWest Weight and Balance Manual contains approved procedures for computing 

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

calculated. 

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

center of gravity is within approved limits. 

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

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

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

certificate holder. 

No change 

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

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

information. 

Sincerely, 

Chris Brown 

Director 

Flight Operations 
EXHIBIT 21 

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

us Department 

crfTransDorTorion 

F«d«rai AviaHon 

AdfiWHVtrofton 

m 

Northwest Mountain Region 

Cokxado, Idaho. Montana, 

Oregon, Utah, Washington, 

Wyoming 

SkyWest Certificate Management Office 

1020 North Ryer Way 

Salt Lake City, Utah 8411&-2959 

801-257-6100, 800-332-2795 

Fax; 801-257-5138 

r^ay 17, 2011 Tracking Number: 2352 

Christopher C. Brown 

Director of Aircraft Operations 

SkyWest Airlines, Inc. 

444 South River Road 

St. George, Utah 84790-2086 

Dear Mr. Brown: 

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

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

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

reduce the documented issues with aircraft loading and documentation accuracy. 

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

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

identified the following issues: 

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

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

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

14 CFR § 121.693(a), even if the airplane were loaded conrectly, because of 

the built-in "error. Additionally, 14 CFR § 121.666 states, in part, that the 

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

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

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

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

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

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

designed to create a baseline standard and establish safe operating 

procedures in the event of sn^aW variances in weights. The concept of an 

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

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

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

performance by Ground Service Agents handling SkyWest flights. Absent 

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

errors previously identified by t^e SkyWest CMO. SkyWest's proposal, as rt 

stands, is rxjt a human factor mitigation strategy, but a human factor 

compensation strategy. 

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

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

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

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

CMO cannot approve SkyWest's proposed amendment at this time. 

Sincerely, 

--f^ Ar>drew J. Ayers 

Principal Operations Inspector 

cc: Klen P. Brooks, Vice President of Flight Operations 
EXHIBIT 22 

/^«'^.««F^c/^.,Po,iey,F^A Order 9550.8A, Revised August 10, 2005 
Human Factors PoUcy 

FAA Order 9550.8A 

[Rev: August 10,2005] 

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

and coordinating human factors considerations in Federal Aviation Administration (FAA) pTX>grams 

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

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

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

3. CANCELLATIONS. This order supercedes FAA Order 9550.8 dated October 27, 1993, 

which is canceled. 

4. EXPLANATION OF CHANGES. This order clarifies die meaning of human factore 

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

policy and responsibilities for incorporating human factors in agency functions. 

5. DEFINITIONS. 

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

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

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

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

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

identify the scope of human Actors considerations for study, analysis, and resolution. 

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

6. BACKGROUND. 

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

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

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

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

consistent, long-term support for hiunan factors research and development, analysis, and the 

application of human factors information. Subsequent to the Office of Technology Assessment 

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

FAA to augment its research effort in himian factors and ensure coordination with other agencies 

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

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

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

groups whose members include pilot and controller unions, airfirame and parts manufacturers, as 

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

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

safety and productivity goaJs, increased coordination, ftmding, and long-terra, high level 

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

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

in aviation certification, regulation, operations, and acquisitions. 

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

engineering include: 

1) Increased personnel efficiency, effectiveness, and productivity; 

2) Improved system performance and usability; 

3) Reduc<:d operations and maintenance costs; 

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

regulations, and business case and investment decisions; and 

5) Enhanced aviation safety. 

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

meets FAA long and short range needs covering both research and engineering applicatimis. The FAA 

Human Factore Policy Oixkr supporte regulation and operation of the National Airspace System by 

providing an agenda for the c(mduct and institutionalization of human fectors activities relative to 

achieving regulatfory goals and cAjectives, executing research and develt^Mnent programs, fecilitating 

Capital Investment Plan acquisitions, and responding to operariwial missitm performance requirements. 

8. OBJECTIVES. The human factors-oriented approach is to: 

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

updating of valid and tunely hunmn fectors information to support agency needs; 

b. Develop and institutionalize formal procedures that systematically incorporate 

human factors considerations into agency activities; and 

c. Establish and maintain organizational infrastructure that provides the necessary 

human factors expertise to agency programs and activities. 

9. HUMAN FACTORS COORDINATING COMMITTEE, This order prescribes the 

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

the generation, distribution and application of human factors information through a representative 

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

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

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

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

within FAA. 

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

planm'ng and execution of the functions of all FAA organizational elements and activities associated 

with National Airspace System acquisitions and operations. 

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

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

considerations shall be integrated at the earliest phases of FAA projects and incorporated within the 

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

Page 2 
achieved through a human-cenlcTcd emphasis in (^jerations, research, applications, and infi^stnicture 

support resulting in safe and effective human-system interfaces. Program managers shall employ 

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

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

operationally suitable within the intended environment. 

Human performance shall be integrated into procedure development, system performance 

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

architecture engineering, and other activities within the agency. 

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

and incorporated into activities and decisions related to mission analyses and mission need 

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

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

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

assessment plans and reviews. 

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

integrate human factors considerations appropriately and successfully, inter alia: 

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

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

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

• (Quantitative human performance measures and criteria 

• Human factors risks and means/methods to mitigate them 

" Life cycle costs and benefits including staffing and training 

• Analytical methods and technical tools to conduct human factors activities 

" Conventions, guidelines, and standards needed to apply human &ctors 

• Measures, databases, and related information on hunan-in-the-loop operational performance 

• Results from human-in-the-loop analyses, modeling, simulations, demonstrations, and 

• Less<ms learned about addressing human factors in FAA programs (e.g., in requirements, 

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

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

for research and engineering programs and applications. 

IL RESPONSIBILITIES. 

1 LI All FAA Organizations: 

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

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

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

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

a. Execution. Conduct activities to: 

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

Page 3 
certification, and regulatory activities in the promotion of civil aviafioOEnsure c^ierational human perftMroancc constraints and enhaiK^CTitfots arc routinely 

iiKorporatcd in mission analysis and capability/requirements (fetermination processes, life 

c^'cle cost and benefit analyses, risk assessments, system operaticMial performance 

^>ecifications, system baseline measurements, solicitation package preparaticm and source 

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

cffectivoiess and measures of perfomianoe), operational test and evaluation plans, program 

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

assessments. 

Acquire necessary human performance information by means of the research, 

engineering, and development processes. 

Assess the suf^xwlability and affondability of human resource requirements (e.g., staffing 

and training) to meet plans for (he future NAS architecture aixl systems. 

Implement error prevention and mitigation strategics to emphasize human error reduction. 

• Integrate human factors into feult tree analyses and other risk management techniques for 

c^)etarion and maintenance activities. 

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

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

authorities on issues related to accessibility and accommodaticffi for people with 

disabilities and special needs. 

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

pcrfomi. direct, or assist in: 

Serving as the organization's representative to the Human Factors Coordinating 

Committee 

Defining human fectors risks and mitigation plans during mission analysis, investment 

analysis, and requirements determination. 

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

trade studies, and prototypes. 

• Preparing and updating human factors portions of acquisition and engineering 

managenKnt plans, procurement packages, test and evaluation plans, performance 

measures and criteria, and data collection efforts. 

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

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

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

• Coordinating human ^tors engineering efforts and user working group activities. 

• Coordinating human factors in training development, integrated logistics support, safely, 

configuration management, and other system engineering fiinctions. 

c System Engineering. Establish mechanisms to incorporate human factors risk 

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

service area, and National Airspace System architecture level. 

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

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

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

implementation, and monitoring of safety management system risks include: 

• The scope of human fectors areas of interest 

• Tools and techiuques used, and their frequency of use 

• Data and databases used, and their quality and availability 

• Metrics and measures used, and how they arc scored 

• Standards and conventions used, and compliance with them 

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

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

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

e. Program Performance Measurement Establish mechanisms by which to continuously 

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

aiul learning and growth perspectives using program performance measures and tools such as the 

human factors balanced scorecard approach. 

C Processes and Procedures. Establish and apply: 

• Processes and procedures that systematically identify the human fectors expertise essential 

to applying human fectors to acquisition, operations, ceitificatiMi, and regulatory activities. 

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

human dimension. 

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

Managerial and executive level awareness training for human factors. 

• Program management team and engineering staff technical training for management of 

human factors in acquisition and (^rations. 

• Operational le\'el human Actors familiarization training. 

Academic-Industry-Government coordinatimi and technology transfer on the application of 

human factors. 

• Professional training and education for human factors coordinators and support employees 

on topics and issues related to the human factors discipline. 

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

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

implementation activities throu^iout the agency, 

• Availability of human factors quality control personnel for oversight, dircction, and support 

Adequate funding for human fectors technical suf^xxt. 

• Sufficierx:y of funding for human performance research, engineering, and data collection 

projects. 

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

scientific validity of approved research and studies. 

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

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

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

6w:tors "community of practice" across the agency, and providing human factors support to research 

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

other Organizational elements as appropriate. The Program Director for Human Factors serves as 

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

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

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

1. Principal advisor and focal point to die FAA Administrator. Air Traffic Organization Chief 

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

traffic management engineering. 

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

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

engineering applications. 

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

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

Executive as required. 

c. Provides human factors guidance, directioTL, sponsorship, and representation to internal and 

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

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

It. Manages FAA Human Factors Research. Engineering, and ftevelopmcnt Program. 

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

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

execution. 

f. Performs technical quality assurance for human factors research. 

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

certification, regulation, and standards). 

h. Serves as primary interface <m human factors for Research, Engineering, & Devclopnient air traffic 

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

Defense, National Aeronautical Space Administration, and Eurocontrol. 

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

Subcommittee on Human Factors. Also, provides human factors prograirmwdc suf^x)rt to Research 

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

Traffic Services. 

111. Conducts suptx>rt activities for the human factors ^'community of practice" across the agency. 

j . Chairs, directs, and orchestrates activities of the FAA Human Factors Coordinating Committee 

as sot forth under Appendix 3 (Human Factors Coordinating Committee) of this order. 

Page 6 
k. Coordinates for the ager»cy the communication, evaluation, advice, and support for the human 

factors community of fniactice on strategic planning, risk management, and organizational 

infrastructure requirements arxl capabilities for human factors activities and expertise. 

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

community of practice needs. 

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

agency programs for human factors products and services. 

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

analytical methods, ccxiventions and guidelines, technical tools, data arxl database availability, 

human performance criteria, life cycle costs, humai^in-the-loop analyses, and "lessons learned** for 

human factors research and engineering applications. 

0. For Air Traffic Organization, serves as clearinghouse, quality assuraxKC, and document control for 

human factors policy and starxlanJs. 

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

Organization Operations Planning (ATO-P) service area and other organizational elements as 

appropriate. 

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

incoiporation of himian factors considerations in NAS Enterprise Architecture developments 

and modifications and to enhance human-system integration in other system engineering 

endeavors. 

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

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

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

Operations Planning activities. 

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

required. 

1 U Checklist for Human Factors Research and Engineering. Appendix 2, Organizational 

Checklist for Human Factors Research, Applications, and Infrastructure Support, provides an 

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

Administrator 

Page 7 
APPENDIX I 

HUMAN FACTORS STUDY AREAS 

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

equipment performs better while enabhng the human to maintain awareness of the operational 

situation. 

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

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

3. CHI (Computer-Hoinaa interaction): Employing effective and consistent user dialogues, 

interfaces, and procedures across system fimctions. 

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

required user communications and teamwork. 

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

including new technologies and procedures, will be introduced. 

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

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

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

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

technical sophistication and clarify. 

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

system will N: subjected and understanding the associated effects on human-system 

performance. 

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

operati<maI and maintenance concepts. 

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

orgaiuzational influences) as causal factors contributing to human error, and consideration of 

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

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

effective and consistent labels, symbols, colors, terms, acronyms, abbreviations, formats, and 

data fields. 

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

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

usable, 

i 3. I/O Devices: Selecting input and output (I/O) methods and devices that allow operators or 

maintaincrs to perform tasks, especially critical tasks, quickly and accurately. 

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

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

users. 

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

performing intended functions while maintaining interoperability and consistency with other 

system elements or support systems. 

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

case of use. 

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

hazards. 

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

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

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

skills, abilities, tools, or characteristics. 

20. Staffing: Accommodating constraints and efficiencies for staffing levels and organizational 

structures. 

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

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

are easily learned and retained. 

22. Visual/Aoditorj' Al«rts: Designing visual and auditory alerts (including error messages) to 

invoke the necessary operator and maintainer response. 

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

measures. 

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

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

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

Page 9 
APPENDIX 2 

DEFINTIONS 

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

consitferations concurrent with other engineering disciphrjes during the analysis, design, development, 

testing, and fielding of a system, service, or facility in which human performance is essential in meeting 

safc^ and capability objectives. 

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

about human capabilities and limitations related to hardware, software, facilities, iwocedures, jobs, 

cwganizations, envirxmroents, training, staffing, errors, situational awareness, workload, personnel 

management, decision support tools, and oihcr perfonnance implications in which the human is a 

compOTient in meeting safety and capability objectives. 

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

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

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

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

Human-System integration. The concept and processes associated with optimizing total system 

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

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

in program defmition, analysis, design, development, testing, and implementation. 

OMB Exhibit 300 Requirements. The analyses, information, and documentation associated with 

OMB Circular 11, Part 7, Exhibit 300 requirements and all attachments necessary to initiate, 

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

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

facilities. 

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

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

Page 1 
APPENDIX 2 

ORGANIZATIONAL CHECKLIST FOR HUMAN FACTORS RESEARCH, 

APPLICATIONS, AND INFRASTRUCTURE SUPPORT 

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

For Research: Plan, review, aiKl prioritize human factors research which supports the organization's 

needs. 

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

basis? 

Arc you provided with an adequ^e strategy to conduct human factors efforts at the appropriate 

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

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

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

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

vs university to satisfy specific human factors requirements? 

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

research to organizaticmal flinctions? 

For Applications: Develop and institutionalize formal mechanisms that systematically incorporate 

human factors considerations into the c»^anization's activities. 

• Are human resource constraints and human-system performance considerations identified early in 

organization program activities? 

Are human resource impacts of the program identified? 

Do system operational perfonnance specifications (including system integration requirements) 

consider human factors? 

Is human performance for the program/project quantitatively measured? 

Is human performance and usability an explicit item in contract/vendor evaluation criteria and 

contract award? 

Have analyses been done and data been made available to address human periiwmance? 

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

strategy? 

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

in operational terms? 

Do life cycle costs reflect total hiunan resource commitments? 

Has the system been stressed to its performance limits (incliHlir^ human-in-the-lo(^ analysis)? 

Do program/project decisions use human performance data? 

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

For Infrastructure Support: Establish and maintain the infrastmcture that provides the organization 

with the necessary human factors expertise and capabilities. 

Arc human factors experts available arnl involved? 

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

Is there continuity of human factors effort? 

Are there adequate fiinds for required human factors tasks? 

Arc the appropriate human factors tools, techniques, and technical capabilities available? 

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

Page 2 
Do policies, processes, and procedures enhance the consideration of human performance? 

• Arc job aids and practitioner tools available to suppc»t and apply human factors considerations? 

For Program Reviews: 

Are sufficient human factors resources available to ensure the program's success? 

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

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

Is human factors integrated into system engineering activities? 

Are human factors issues regulariy raised and nssolved in pnjgram/projecf deliberations, 

functions, activities, arnl decisi<His? 

Are system requirements, specifications, and evaluations replete with operator and maintainer 

perfwmance parameters? 

Page 3 
APPENDIX 3 

HUMAN FACTORS COORDINATING COMMITTEE 

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

human factors endeavors constructively and enhance the use of human factors 

information. Composition and functions of the Human Factors Coordinating Committee 

arc as follows: 

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

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

required, 

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

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

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

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

ensurc the best interests of the govertuncnt. Under tlw provisions of Paragraph 11 

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

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

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

purpose of preparing minutes of the meetings. The Human Factors Coordinating 

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

factors responsibilities. Candidate organizations include: 

- Air Traffic Organization Service Areas 

- Associate Administrator for Aviation Safety 

- Associate Administrator for Airports 

- Associate Administrator for Commercial Space Transportation 

- Assistant Administrator for Information Services 

- Assistant Administrator for Region and Center Operations 

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

Technical Center 

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

Aerospace Medicine 

- Aeromedical Research Division, Civil Aeromcdical Institute, Office of 

Aerospace Medicine 

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

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

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

organizations. Specific fixnctions of the Hiunan Factors Coordinating Committee are to: 

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

coordination of research results; 

b. Foster the dissemination and exchange of human factors information 

amoug agency organizations; 

Page 4 
c. Facilitate the integration of human factors into procedure development, 

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

within the agency; 

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

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

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

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

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

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

out. 

5. Responsibilities. 

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

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

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

(3) Reviewing committee documentation prior to publication or 

distribution; and, 

(4) Ensuring appropriate representation, organization, documentation, 

and administration to su|^x)rt the committee. 

b. Committee Members. Committee members shall be responsible for 

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

coordinating human factois program activities within and across their organizations; 

(2) Supporting their respective human factors research and 

engineering programs within their organizations; 

(3) Monitoring their resf)ective human factors research requirements 

development processes within their organizations; 

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

committee on human factors matters within their organizations; 

(5) Attending committee meetings or designating an alternate if 

attendance is not possible; and 

Page 5 
(6) Participating in committee and other activities such as workshops, 

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

Page 6