7993 

E PLURIBUS UNUM

NATIONAL TRA SPORTATIO

N

B OARD

SAFE T Y

N National Transportation Safety Board 

Washington, D.C. 20594 

Safety Recommendation 

Date: March 31, 2008

In reply refer to: A-08-10 through -13 

The Honorable Robert A. Sturgell 

Acting Administrator 

Federal Aviation Administration 

Washington, D.C. 20591 

On August 28, 2006, about 1506 Pacific daylight time,1 a Raytheon Aircraft Company 

Hawker 800XP airplane, N879QS, and a Schleicher ASW27-18 glider, N7729, collided in flight 

about 42 nautical miles (nm) south-southeast of the Reno/Tahoe International Airport (RNO), 

Reno, Nevada, at an altitude of about 16,000 feet above mean sea level (msl). The airline 

transport-certificated captain and first officer in the Hawker received minor injuries, and the 

three passengers were not injured. The private pilot in the glider received minor injuries, and 

both aircraft sustained substantial damage. Visual meteorological conditions (VMC) prevailed at 

the time of the collision. The Hawker, which was fractionally owned by multiple corporations 

and managed by NetJets Aviation, Inc., was operating under the provisions of 14 Code of 

Federal Regulations (CFR) Part 91, Subpart K, as an executive/corporate flight. It departed from 

Carlsbad, California, about 1400 and was en route to RNO with an instrument flight rules (IFR) 

flight plan filed. The glider was registered to a private owner and was operated by the pilot under 

the provisions of 14 CFR Part 91 as a personal flight. It departed from Minden, Nevada, about 

1300 for a local flight with no flight plan filed.2

Background 

The collision occurred in an area that is frequently traversed by air carrier and other 

turbojet airplanes inbound to RNO and that is also popular for glider operations because of the 

thermal and mountain wave gliding opportunities there.3

 The glider pilot, who intended a 5-hour 

flight in the local area to familiarize himself with the glider, was not communicating with air 

 

1

 All times are in Pacific daylight time unless otherwise noted. 

2

 The factual report for this accident, LAX06FA277A/B, can be found on the National Transportation Safety 

Board’s Web site at <http://ntsb.gov/ntsb/brief2.asp?ev_id=20060906X01297&ntsbno=LAX06FA277A&akey=1>. 

3

 The area surrounding RNO is known for its world-class gliding and hosts a number of gliderports and glider 

clubs. Three airports surrounding RNO service glider operations: Minden-Tahoe Airport (35 nm south of RNO), 

Reno/Stead Airport (14 nm north-northwest of RNO), and Truckee-Tahoe Airport (23 nm southwest of RNO). 
2 

traffic control (ATC) and was not required to do so.4 The Hawker flight was in radar and radio 

contact with an ATC facility. Before the collision, the Hawker had been descending toward RNO 

on a stable northwest heading for several miles, and the glider was in a 30o, left-banked, spiraling 

climb. According to statements from the Hawker’s captain and the glider pilot, they each saw the 

other aircraft only about 1 second or less before the collision and were unable to maneuver to 

avoid the collision in time. Damage sustained by the Hawker disabled one engine and other 

systems; however, the flight crew landed the airplane. The damaged glider was uncontrollable, 

and the glider pilot bailed out and parachuted to the ground. 

Because of the lack of radar data for the glider’s flight, it was not possible to determine at 

which points in each flight each aircraft may have been in the other’s available field of view. 

Although Federal Aviation Regulations (FARs) require all pilots to maintain vigilance to see and 

avoid other aircraft (this includes pilots of flights operated under IFR, when visibility permits), a 

number of factors that can diminish the effectiveness of the see-and-avoid principle were evident 

in this accident. For example, the high-speed closure rate of the Hawker as it approached the 

glider would have given the glider pilot only limited time to see and avoid the jet. Likewise, the 

closure rate would have limited the time that the Hawker crew had to detect the glider, and the 

slim design of the glider would have made it difficult for the Hawker crew to see it. Although the 

demands of cockpit tasks, such as preparing for an approach, have been shown to adversely 

affect scan vigilance, both the Hawker captain, who was the flying pilot, and the first officer 

reported that they were looking out the window before the collision. However, the captain saw 

the glider only a moment before it filled the windshield, and the first officer never saw it at all. 

The Hawker was equipped with a traffic alert and collision avoidance system (TCAS)-II 

capable of generating vertical resolution (collision avoidance) advisories (RA). However, the 

glider’s Mode C transponder was turned off and, therefore, was not detectable by the Hawker’s 

equipment.5

 Although transponder installation is not required on gliders, FARs require that any 

person operating a transponder-equipped aircraft must use the transponder.6

 Had the glider pilot 

turned on his transponder, the Hawker’s TCAS-II likely would have depicted the glider on the 

flight crew’s monitor and, at a minimum, would have generated an RA to alert the crewmembers 

and prompt them to deviate their course in time to prevent the accident. In addition, had the 

glider’s transponder been turned on, it would have provided position and altitude information to 

ATC personnel who could have used that information to provide separation services and traffic 

advisories to the Hawker crew. 

According to Reno Terminal Radar Approach Control (TRACON) personnel, it is not 

uncommon for arriving and departing air traffic to receive TCAS RAs because of transponderequipped gliders operating in the area. For example, in a 30-day interval before the accident, the 

 

4

 The collision occurred in Class E airspace that has no requirements for two-way radio communication. 

5

 The glider pilot turned off the transponder because he wanted to reserve battery power for radio use. 

6

 According to 14 CFR 91.215(c), “each person operating an aircraft equipped with an operable ATC 

transponder . . . shall operate the transponder, including Mode C equipment, if installed.” 
3 

facility recorded four such TCAS RA events reported by pilots.7 Each event involved a conflict 

between a transport-category airplane operated under 14 CFR Part 121 and a glider. 

The National Transportation Safety Board determined that the probable cause of this 

accident was the failure of the glider pilot to utilize his transponder and the high closure rate of 

the two aircraft, which limited each pilot’s opportunity to see and avoid the other aircraft. 

The investigative findings from this accident revealed safety issues related to limitations 

of the see-and-avoid concept in preventing midair collisions, especially when one or more highspeed aircraft are involved, and the regulatory exemption that allows gliders to operate without 

transponders. The Safety Board also noted that glider design and electrical power limitations 

present unique challenges for the installation and operation of transponders. Following this 

accident, members of the local glider groups and the Reno TRACON facility met and formed 

working groups to establish interim policies and procedures, improve communications between 

glider pilots and ATC, and educate glider pilots on the midair collision potential and what they 

can do to mitigate the risk.8

Benefits of Transponders in Collision Avoidance 

The limitations of the see-and-avoid concept for collision avoidance have long been 

recognized and acknowledged by the Safety Board and other aviation safety advocates. 

Following four midair collisions in 1986 and 1987, all of which occurred in daylight VMC, the 

Board issued a July 27, 1987, safety recommendation letter to the Federal Aviation 

Administration (FAA). This letter emphasized the Board’s longstanding belief that midair 

collision avoidance is significantly improved when pilots are alerted to the presence and location 

of potentially conflicting traffic by ATC personnel or a TCAS.9 

In the letter, the Safety Board expressed specific concerns about airspace in the vicinity 

of airports that is used not only by arriving and departing air carrier traffic but also by transiting 

aircraft operating under visual flight rules (VFR). The Safety Board concluded that, because both 

airborne TCAS and controller-initiated conflict alerts rely upon operating transponders, such 

transponders should be required for all aircraft that share airspace with TCAS-equipped air 

 

7

 The facility retains TCAS RA reports for only 30-day intervals. Safety Board investigators reviewed reports 

for the most recent available 30-day interval before the accident. 

8

 Also, as a result of this accident, the Safety Board issued Safety Recommendations A-08-14 and -15 to the 

Soaring Society of America, Inc., regarding expanding similar safety efforts in other areas and informing the glider 

community about this accident and the importance of transponders. 

9

 The letter also reiterated two safety recommendations to the FAA that were originally issued in 1985. Safety 

Recommendation A-85-64 asked that the FAA “expedite the development, operational evaluation, and final 

certification of . . . [TCAS] for installation and use in certificated air carrier aircraft,” and Safety 

Recommendation A-85-65 asked that the FAA “amend 14 CFR Parts 121 and 135 to require the installation and use 

of . . . [TCAS] equipment in certificated air carrier aircraft when it becomes available for operational use.” Both of 

these recommendations were classified “Closed—Acceptable Action” on May 23, 1989, because the FAA 

implemented the TCAS requirements and issued guidance materials for TCAS airworthiness and operational 

approval. 
4 

carriers. The Board issued a safety recommendation to the FAA on this issue.10 Although the 

FAA responded and issued a final rule on June 17, 1988, requiring transponders for aircraft 

operating near primary airports and in airspace at or above 10,000 feet msl, gliders and other 

aircraft without an engine-driven electrical system remain exempt from many requirements.11 

As evidenced by this accident, aircraft that are not using or not equipped with 

transponders and are operating in areas transited by air carrier traffic represent a collision hazard. 

This hazard has persisted more than 20 years since the Safety Board initially expressed concern. 

According to glider operators in the RNO area, the area of the collision is very popular with 

gliders for the thermal lift provided by the Pine Nut Ridge, and gliders can reach altitudes up to 

18,000 feet msl or higher.12 

Review of the Aviation Safety Reporting System (ASRS) database revealed that, from 

1988 to August 2007, 60 near midair collisions (NMACs) involving air carrier/corporate jet 

traffic and gliders were reported.13 Of these events, nine occurred in the vicinity of RNO, which 

represents more reports than any other airport area during that timeframe.14 Although the most 

recent reported RNO-area NMAC event, which occurred in August 2007, involved a glider that 

 

10 Safety Recommendation A-87-97 asked that the FAA “require transponder equipment with Mode C altitudereporting for operations around all Terminal Control Areas and within Airport Radar Service Areas after a specified 

date compatible with implementation of . . . [TCAS] requirements for air carrier aircraft.” This recommendation was 

classified “Closed—Acceptable Action” on May 3, 1989, because the FAA implemented transponder requirements 

for aircraft operating near certain primary airports and in other airspace at and above 10,000 feet msl. 

11 According to 14 CFR 91.215(b), all aircraft, unless otherwise authorized or directed by ATC, must be 

equipped with an operable transponder and altitude-reporting equipment for operations in Class A, Class B, and 

Class C airspace and within 30 nm of listed Class B airports, from the surface upward to 10,000 feet msl. However, 

14 CFR 91.215(b)(3) states that, “any aircraft which was not originally certificated with an engine-driven electrical 

system or which has not subsequently been certified with such a system installed, balloon or glider may conduct 

operations in the airspace within [30 nm of listed Class B airports, provided such operations are conducted] . . . (i) 

Outside any Class A, Class B, or Class C airspace area; and (ii) Below the altitude of the ceiling of a Class B or 

Class C airspace area designated for an airport or 10,000 feet msl, whichever is lower.” In addition, 

14 CFR 91.215(b)(5) states that “all aircraft except any aircraft which was not originally certificated with an enginedriven electrical system or which has not subsequently been certified with such a system installed, balloon or glider” 

are required, unless otherwise authorized or directed by ATC, to be equipped with an operable transponder and 

altitude-reporting equipment for operations in the following airspace: “(i) In all airspace of the 48 contiguous states 

and the District of Columbia at and above 10,000 feet msl, excluding the airspace at and below 2,500 feet above the 

surface; and (ii) In the airspace from the surface to 10,000 feet msl within a . . . [10-nm radius of a Class B airport] 

excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designed 

for that airport.” 

12 The floor of Class A airspace begins at 18,000 feet msl, and 14 CFR 91.135 requires that all aircraft operating 

in Class A airspace must do so under IFR and must operate an appropriate transponder with altitude-reporting 

capabilities, in accordance with 14 CFR 91.215. Therefore, glider pilots who wish to fly at 18,000 feet msl or higher 

must operate a transponder and activate the local glider operations box, which provides clearance from arriving 

traffic. According to the local glider pilots, the box is usually activated during mountain wave flying conditions. 

During thermal flying conditions, the gliders usually remain below 18,000 feet msl. 

13 Because ASRS reports are voluntary, it is possible that other NMAC events occurred but were unreported. 

14 Some of the reports did not specify where the event occurred, and those reports were excluded from 

determining area totals. After the RNO area, the next airport with the most NMAC reports was the Chicago Midway 

International Airport area in Chicago, Illinois, with four reports; followed by the City of Colorado Springs 

Municipal Airport area in Colorado Springs, Colorado, with three reports. The Washington, D.C., area (which 

includes more than one airport and the surrounding areas) had four NMAC reports filed.
5 

was equipped with a transponder that both ATC and the other aircraft’s TCAS detected,15 most of 

the ASRS reports involved gliders that were neither detected by the jet flight crews’ TCAS 

equipment nor visible on the ATC facilities’ radar screens, indicating that the gliders were not 

equipped with, or not using, a transponder. Some of the reports indicated that, after the flight 

crews reported to ATC that they saw the glider, the controllers noticed primary radar returns in 

the vicinity of the jet traffic. In some instances, the controllers had notified the jet crews of the 

primary radar returns but informed the pilots that they did not know what the traffic was or at 

which altitude it was flying. During postaccident interviews, Reno TRACON personnel reported 

that, although they can sometimes see primary radar returns for what they suspect are 

nontransponder-equipped gliders, they did not see any primary returns from the accident glider 

before this collision. Further, even when ATC personnel detect primary returns, they cannot 

ascertain the type or altitude of the aircraft. 

More than 10 years before this accident, Reno Flight Standards District Office (FSDO) 

personnel concluded that, on the basis of many NMAC reports, inspectors’ observations of traffic 

conflicts, and other information, the increasing glider operations in the departure and arrival 

areas around RNO represented a collision hazard. On April 11, 1997, the Reno FSDO manager 

submitted a memorandum to the FAA’s Office of Accident Investigation, Recommendation and 

Analysis Division (AAI-200)16 detailing these concerns. The memo indicated that: 

Gliders are invisible to radar because they do not have a transponder, and they 

will not show up as a primary target on radar due to their design. Air carrier pilots 

are very busy with the approach or departure procedure and tend to rely on their 

TCAS for identifying traffic. Gliders do not show up on TCAS unless they use an 

appropriate transponder. In addition, due to the design of the gliders, they are very 

difficult to see unless the air carrier is very close to them, which may be too late 

to avoid the glider. 

The memo detailed some of the FSDO’s efforts to correct the problem, stating that it 

developed an ongoing program to try to educate the glider community and air carriers. The 

memo stated that: 

However, the gliders continue to operate in the arrival and departure areas around 

RNO. This office has suggested that gliders carry transponders and/or 

communicate with the RNO tower. The glider community does not want to adopt 

the FAA’s suggestion. The glider community wants ATC to reroute the air carriers 

around their area of operation. RNO is located in a valley and if ATC were to try 

and reroute the air carriers then they would not be able to make a safe descent for 

landing. 

The memo suggested a number of solutions, including a proposal to require gliders to 

carry transponders with appropriate modes for ATC and TCAS. In response to the FSDO’s 

 

15 The reported circumstances of this event are discussed in more detail later in this letter. 

16 The original memo was addressed to the “Office of Accident Investigation, Recommendation and Quality 

Assurance Division, AAI-200,” which slightly misidentified the division’s title. However, the memo reached its 

intended recipient, and the manager of AAI-200 responded to it. 
6 

concerns, the FAA published a notice to airmen (NOTAM) cautioning pilots about glider soaring 

operations 30 to 50 miles south of RNO and ensured that the San Francisco Sectional 

Aeronautical Chart and five of the RNO-published instrument procedures were updated with 

caution boxes to warn pilots of extensive glider activity.17 However, the FAA elected not to 

implement the transponder recommendation. 

The Safety Board acknowledges that the FAA’s actions to publish the NOTAM and the 

chart updates are steps in the right direction. However, because the collision threats observed by 

Reno FSDO personnel 10 years ago persist today, the Safety Board concludes that the safety 

measures implemented by the FAA to notify air carriers and other RNO-area traffic of glider 

activity are insufficient to prevent collisions. The Board notes that, because of the limitations of 

the see-and-avoid concept, transponder-initiated collision alerts (either from ATC or TCAS) 

provide both VFR and IFR aircraft with a higher degree of safety in an environment where highspeed closure rates are possible. Therefore, the Safety Board further concludes that transponders 

are critical to alerting pilots and controllers to the presence of nearby traffic, so that collisions 

can be avoided, and that gliders should not be exempt from the transponder requirements. This is 

especially important at higher altitudes, where flight crews may rely more on their TCAS, 

expecting that other aircraft, including light aircraft, are in contact with ATC and/or are 

transponder-equipped. Therefore, the Safety Board believes that the FAA should remove the 

glider exemptions from the FARs that pertain to transponder requirements and use. 

Considerations for Transponder Installation Retrofits in Gliders 

Since 1998, the Soaring Society of America, Inc. (SSA) has encouraged glider operators 

to voluntarily install and use transponders because of their safety benefits. However, as 

mentioned previously, the Reno FSDO’s suggestion of voluntary transponder installation and use 

was met with resistance from members of the local glider community. When transponders were 

mandated in general aviation aircraft, gliders were excluded from the requirement because they 

lack an engine-driven electrical system to power the equipment. 

Although some newer transponders require less battery power than older models or 

models originally designed for powered aircraft, power limitations remain a concern for glider 

operators. According to a transponder article available from the SSA’s Soaring Safety Foundation 

(SSF), in order to power a transponder, a glider owner would likely need to install an additional 

battery, which would allow anywhere from 5 to 12 hours of transponder operation, depending on 

the type of transponder, the temperature conditions during the flight, and the age of the battery.18

 

17 Before this accident, the government’s National Oceanic Service (NOS) standard instrument departure (SID) 

and standard terminal arrival route (STAR) charts for RNO contained a relatively large box cautioning pilots of 

“intensive glider activity.” The instrument approach procedures for RNO published by Jeppesen Sanderson, which 

were used by the Hawker flight crew, contained a glider caution in the approach briefing section, but the SIDs and 

STARs did not have a glider caution. Following the accident, the Hawker’s operator contacted Jeppesen and 

requested that a similar caution advisory, as found on the NOS SIDs and STARs, be placed on the Jeppesen charts. 

Jeppesen has since added the caution advisory to its RNO SIDs and STARs. 

18 The article, “Choosing, Installing, and Using a Transponder,” was originally published in two issues of 

Soaring magazine in February and March 2002 and was updated December 2004 and made available on the SSF 

Web site at <http://www.soaringsafety.org/prevention/transponders.pdf>. 
7 

However, gliders typically have limited space to accommodate transponder equipment and the 

additional batteries needed to power it. 

The Safety Board recognizes that glider design issues present unique challenges for 

transponder retrofit installations and that some glider operators have voiced concerns about a 

lack of transponder installation guidance. The SSF article noted that some gliders do not have 

room to carry additional batteries and that glider fuselage designs and trailering, rigging, towing, 

and landing considerations have limited the locations where owners can feasibly mount 

transponder antennas. The Board notes that, in the past, the FAA has published guidance to help 

aircraft owners understand their options for approved installations of retrofit equipment to ensure 

that such retrofits meet airworthiness regulations. The Safety Board concludes that a policy 

statement for transponder installation in gliders would help facilitate timely and effective 

transponder retrofits. Therefore, the Safety Board believes that the FAA should develop guidance 

material for glider owners/operators that describes feasible installation options to aid in the 

prompt installation and approval of transponders in gliders. 

National Transponder Code to Identify Gliders and Minimize Battery Draw 

As mentioned previously, glider transponders require battery power. Many glider 

operators have reported having sufficient battery power to operate their transponders and other 

instruments/avionics19 during a 5- to 6-hour flight. However, during cross-country flights, which 

can last twice that time, transponders and other equipment can drain the installed batteries before 

the end of the flight. In fact, the glider pilot involved in the collision had turned off his 

transponder because he wanted to conserve battery power for radio use. 

Battery power issues are of such concern for gliders that, on November 5, 2003, the SSA 

submitted a petition20 to the FAA requesting that pilots of transponder-equipped gliders be 

allowed to turn the transponders off when flying more than 40 nm from the primary airport in 

Class B airspace and more than 20 nm from the primary airport in Class C airspace.21 On 

January 22, 2008, the FAA responded and denied the SSA’s request but stated that an ongoing 

rulemaking project proposes revisions to 14 CFR 91.215(c) that will cover the relief that the 

SSA’s petition sought. Although the Safety Board recognizes that gliders have electrical power 

limitations, the Board is opposed to any rulemaking action that would enable such exemptions 

because aircraft would remain at risk for a midair collision. The Board notes that this midair 

collision took place more than 40 nm from RNO, a Class C airport, and rulemaking exemptions 

could allow the circumstances of this accident to be repeated. 

Currently, all transponder-equipped aircraft, including gliders, operating under VFR use 

the transponder code 1200 unless otherwise instructed by ATC. According to transponder 

manufacturers, the battery draw from a transponder varies, depending on the number of 

 

19 Many gliders are equipped with a radio, variometer, and global positioning system, which all require battery 

power. 

20 The letter was open for public comments in FAA docket No. FAA-2003-16475. 

21 Class B and Class C airspace consists of specified airspace containing at least one primary airport around 

which the airspace is designated. All aircraft operations within Class B and C airspace are subject to certain 

operating rules and equipment requirements, including ATC transponder equipment requirements. 
8 

interrogations it receives (either from a ground-based unit or from a TCAS) and on the code 

tuned on the unit. The lower the transponder code, the lower the battery draw per interrogation. 

Some glider communities, including those in the vicinity of RNO, have worked to secure a letter 

of authorization with their local ATC facilities that establishes a local glider transponder code to 

notify controllers of glider activity in their area. For example, glider operations in the vicinity of 

RNO can use the transponder code 0440. 

In 2001, the SSA requested that the FAA provide a single, national transponder code for 

gliders so that ATC personnel could readily differentiate gliders from other aircraft appearing on 

their displays. This would enable ATC personnel to consider the limited flight options of these 

nonpowered aircraft when providing separation and advisory information to other pilots. For 

example, in an August 2007 ASRS report, a captain of a Boeing 737-300 reported that, while the 

captain’s flight was at 14,000 feet msl 25 nm southwest of RNO, a controller advised that traffic 

with a transponder was showing at or near the flight’s altitude.22 The captain did not see the 

traffic but noted that the TCAS unit provided an RA to descend, and the captain did so; however, 

the TCAS then “quickly commanded [‘climb, climb now’],” and the captain initiated a 

maximum-power climb with a course deviation to the west. The captain reported then seeing a 

glider pass off the right side of the airplane, about 200 feet away and coming head-on. The 

captain reported that, because the glider was climbing and descending, the TCAS reversed its 

initial RA and that the captain had to respond with “aggressive” maneuvers. 

Although this ASRS report did not provide any information about whether the controller 

knew or advised that the traffic was a glider or provided any advisories on its altitude or 

flightpath variations, the report further illustrates that both flight crews and ATC personnel could 

benefit from the ability to readily identify glider transponder returns and understand the 

limitations and variable flightpaths that may be associated with them. Therefore, the Safety 

Board supports the SSA’s request for the establishment of a unique national transponder code for 

gliders. Further, because of the battery power limitations of gliders, the Safety Board concludes 

that a glider-specific transponder code that is low in the transponder code range could reduce 

battery draw, which would increase the feasibility of using transponders in gliders. Therefore, the 

Safety Board believes that the FAA should establish a national transponder code for glider 

operations, as low in the transponder code range as feasible, that would notify air traffic 

controllers of glider operation/position. Also, to ensure the maximum possible safety benefit of 

this unique code, the Safety Board concludes that ATC personnel must be adequately informed of 

the code, what it represents, and under what limitations the users are typically operating. 

Therefore, the Safety Board believes that, upon establishment of a national transponder code for 

glider operations, the FAA should ensure that ATC personnel are informed of the code, what it 

represents, and under what limitations the users are typically operating. 

 

22 The report did not provide any information as to whether the traffic was using a unique transponder code, was 

in radio communication with ATC, or was known to ATC personnel to be a glider. 
9 

Therefore, the National Transportation Safety Board recommends that the Federal 

Aviation Administration: 

Remove the glider exemptions from the Federal Aviation Regulations that pertain 

to transponder requirements and use. (A-08-10) 

Develop guidance material for glider owners/operators that describes feasible 

installation options to aid in the prompt installation and approval of transponders 

in gliders. (A-08-11) 

Establish a national transponder code for glider operations, as low in the 

transponder code range as feasible, that would notify air traffic controllers of 

glider operation/position. (A-08-12) 

Upon establishment of a national transponder code for glider operations, as per 

Safety Recommendation A-08-12, ensure that air traffic control personnel are 

informed of the code, what it represents, and under what limitations the users are 

typically operating. (A-08-13) 

The Safety Board also issued safety recommendations to the SSA. In your response to 

this letter, please refer to Safety Recommendations A-08-10 through -13. If you need additional 

information, you may call (202) 314-6177. 

Chairman ROSENKER, Vice Chairman SUMWALT, and Members HERSMAN, 

HIGGINS, and CHEALANDER concurred with these recommendations. 

 

By: Mark Rosenker 

 Chairman

[Original Signed]