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Statement of Jack Johnson
President
Professional Airways Systems Specialists
before the
National Civil Aviation Review Commission
May 28, 1997 

Good Morning. My name is Jack Johnson, and I am President of the Professional Airways Systems Specialists (PASS) - District No. 6 - PASS/NMEBA (AFL-CIO). Thank you for allowing us to testify today on the issues surrounding future financing and budgeting of Federal Aviation Administration (FAA) activities.

As the exclusive representative for over 10,000 Systems Specialists, Flight Inspection Pilots, and Aviation Safety Inspectors working for the FAA, PASS has a significant interest in FAA funding. The services that our members perform range from systems maintenance, installation, and certification, to aviation and flight inspection. These dedicated men and women have a direct impact on the commercial and general aviation industries and on the safety, the efficiency, and the reliability of the air traffic control system.

In today’s testimony, I will explain how PASS believes the FAA’s choices to cut staffing and training, to contract out, and to attempt modernization without appropriate planning are misguided, waste money, and jeopardize the future safety and reliability of the National Airspace System (NAS). PASS also believes that a "spend less, get more" approach is possible if common sense fiscal responsibility is applied to FAA funding.

 Airway Facilities Systems Specialists

Airway Facilities (AF) Systems Specialists, or Technicians, form the backbone of the FAA’s air traffic control system. Their primary duties are to maintain, repair, and operate this system. Yet, because their positions are not highly visible, Technicians are often overlooked. But by no means are they any less important. In fact, FAA Technicians are the only people authorized to certify the operation and safety of facilities and to return systems to service.

Staffing

In 1981, 11,600 Technicians were responsible for maintaining 19,000 FAA facilities and equipment. According to the Administrator’s Fact Book, the entire field maintenance work force (including supervisors, managers, Technicians, and support personnel) totaled 8,209 for FY 1996. Yet, there are now over 37,000 FAA facilities and equipment.

Recently, at the request of the White House Aviation Safety and Security Commission, PASS calculated the number of FAA employees directly engaged in systems maintenance, as opposed to those who support systems maintenance. As of December 5, 1996, only 5,888 Airway Facilities employees provided hands-on maintenance of the entire National Airspace System. (See Appendix A for a more in-depth staffing analysis.)

As you can see, a different picture appears when "systems maintenance" staffing is distributed by operational structure. The number of systems maintenance employees assigned to hands-on maintenance jobs is approximately 63 percent of the total systems maintenance work force. While there is a need for managerial and supervisory direction in AF, as well as planning, engineering, and administration, 37 percent of the work force is excessive. It is no wonder that AF overtime usage in FY 1996 increased by 15 percent for the systems maintenance work force.

Within a 1995 cost-benefit analysis for the NAS Infrastructure Management System (NIMS), the FAA acknowledged that "service and system management efficiencies will not make up for the shortfall in available AF personnel during the period 1997 through 2001. (Note: The shortfall in service and system management effectiveness will result in a reduction of overall AF facility and service operational availability.)" Given the known impact of this staffing shortfall, why does the agency plan to hire only 25 additional Technicians in FY 1998?

The FAA shows that it has cut total systems maintenance staffing by over 7 percent since 1993. The problem is that Airway Facilities staffing in Headquarters has increased by over 50 percent in that same time. If these gains are removed from the picture, field staffing (including regional offices) has decreased by 13 percent. This shift in emphasis from the field to Headquarters is inconsistent with the needs of our archaic air traffic control system and our ability to field new systems and technology.

FAA management’s poor planning and decision making have led to today’s staffing problems. First, the agency calculated the field staffing reductions that it believed the now defunct Advanced Automation System (AAS) would achieve. Then, it cut the field maintenance staff by not hiring Technicians to fill the pipeline. But the system never materialized. Had the agency fulfilled the AAS promise, we may now have the correct number of employees. However, the agency terminated the AAS project, leaving us with the right work force for the wrong air traffic control system.

Throughout the tumultuous changes of the last few years – from budget cuts to FAA reform – the dedicated men and women who maintain the air traffic control system and the controllers who operate it have remained the constant. This system continues to be the safest in the world because of the PASS members who serve the flying public as Systems Specialists. The most productive step the FAA could possibly take would be to allow more of them to do their jobs.

Contracting Out

Unfortunately, staffing decreases have forced the agency to adopt a costly and dangerous alternative to in-house maintenance – contracting out. The FAA is allowing maintenance on the NAS – which is an inherently governmental function – to be performed by private contractors. PASS believes the agency’s decision to contract out the installation, repair, maintenance, and certification of FAA systems and equipment vital to the safe operation of air traffic is both bad government and bad business.

Studies have shown that contracting out costs taxpayers many times more than what it costs the government to have federal employees provide the same services. The contracting out of Airway Facilities services has proven to be excessively costly and inefficient.

For example, in FY 1996, the existing 29 maintenance contracts cost Airway Facilities $47,700,000. The generated workload for contract maintenance for FY 1996 was 503.8 employee years (or "the number of people that would be required if FAA employees were to perform this workload in-house.") This equates to $94,680 per employee year.

Now, if this maintenance was actually done in-house using the FAA’s labor rate for Technicians, $68,000 per employee year or 701.5 employee years of work could be realized. This equates to a net increase of 198 Technicians to be used in areas of staffing shortfalls.

Typically, the FAA will contract out the first few years of maintenance of a new system simply because it cannot train our Technicians fast enough to support these new systems. Despite the fact that Congress legislated personnel and acquisition reform to give the FAA greater flexibility, the agency has failed to reform training. Why?

There are three major reasons:

 

 Recently, the FAA contracted with Raytheon for the installation and maintenance of the Standard Terminal Automation Replacement System, or STARS, as it is commonly known. This system will replace aging radar display systems, controller workstations, and related equipment at about 170 FAA terminal ATC facilities by February 2005.

Assuming that Raytheon will perform most site preparation and installation work, the STARS contract is estimated to be worth $2.2 billion ¾ $940 million for facility and engineering and $1.3 billion to operate and maintain the system. According to the General Accounting Office (GAO), STARS costs could increase by as much as $500 million.

Technicians and Controllers should have been given hands-on involvement in this project from the onset; instead our roles have been limited. As such, PASS expects that the STARS project – like most FAA modernization efforts – will either run over budget and take longer for deployment, or the agency will raid resources from other programs to cover the shortfalls.

The FAA is also missing the opportunity to save money by giving on-site training on STARS to AF Technicians. When appropriate, on-site training can save time and money because the cost of sending an instructor to one site, or a group of sites, is much less than sending 15 or 20 Technicians to the Oklahoma City Academy.

STARS will be deployed with the current automation system, which would make on-site training of AF Technicians for a project of this magnitude not just appropriate, but extremely cost effective. However, the FAA has said it’s contracting out the first year of maintenance for STARS because it can’t train enough people in time to assume the maintenance.

How long will this excuse be acceptable? Why would the agency spend millions of dollars on the STARS contract when the agency’s AF Technicians can bring systems online faster and cheaper? The Display Complex Channel Rehost (DCCR) program, for example, was completed on time and $3 million under budget. The Voice Switching Control System (VSCS) was also commissioned on time and on budget. Technicians were responsible for both projects.

Meanwhile, Technicians at the Boise NAVCOM were so frustrated by poor contractor work that they submitted to management a creative business plan that would allow them to bid on contractor installation, training, and maintenance projects. Management awarded the employees the work; it was completed on time and under budget.

The FAA initially decided to contract out the maintenance of the DCCR and the VSCS systems. However, the agency altered its decision early on and chose to maintain the systems in house, despite intense lobbying and pressure from the contractors involved. Why is it more cost effective for FAA technicians to maintain the VSCS and the DCCR and not other systems?

AF Technicians have a proven track record, while private contractors often have failed to measure up to this high standard. An example of the satisfaction that FAA Technicians provide is evidenced in a letter to the FAA dated April 30, 1997. Mr. George Larson, Airport Director of the Jackson Hole, Wyoming Airport Board, writes:

 Since AWOS is not the most reliable weather system available, it is extremely important to our Airport, commercial air carriers serving this airport, and all general aviation pilots that we can promptly and expertly repair our AWOS when necessary. Your Technicians always provide us with that assurance, unlike the previous outside contract effort."

 Contractors are Unreliable

 The sentiments in the above letter convey how contractors lack the "pride of ownership" that our FAA Technicians provide the FAA. For example, just last week there was a major outage at the Cleveland Air Route Traffic Control Center (ARTCC) caused by a complete failure of a contractor’s (MCI) equipment. A large part of the ARTCC’s communications and radar systems were shut down after the power went out and the backup system failed. The more than 180 aircraft in the skies over Indiana, Michigan, Pennsylvania, New York, Ohio, and West Virginia had little contact with the controllers at the ARTCC.

 Because MCI has a two-hour call back procedure built into its contract with the FAA, there was no contractor at the ARTCC to respond to the outage. Facility services were in fact returned by an AF Technician who switched from the failed system to commercial power. However, since he had not been trained on MCI’s system, this Technician had to receive instructions from an MCI monitoring facility via telephone. It then took MCI 22 hours to replace the failed system and to return to normal operations.

 Other examples of contractor unreliability and inefficiency include:

 As you can see, the FAA has given contractors virtually free reign to install equipment and to perform maintenance on its systems without even considering the consequences. Our Technicians work with the NAS equipment everyday and are the only ones who can certify the systems. They understand the need to exhibit caution and to communicate with others before performing any maintenance on a system. Until contractors can guarantee immediate restoration and quality service – which PASS maintains will never happen – the FAA must return all maintenance to its own personnel.

The idea of having anyone outside of Airway Facilities employees conducting installation and operation of systems impacting live air traffic is unacceptable. The maintenance and operation of NAS systems that are used to separate traffic or to maintain safety are inherent governmental functions, whether the FAA owns the systems or not.

Modernization Efforts

For FY 1998, the facilities and equipment (F&E) budget request is a three percent decrease from the FY 1997 enacted level. F&E employees are directly involved in systems engineering and design. They are critical to the agency and will play a key role in modernization. PASS steadfastly believes that cutting the F&E budget is neither safe nor responsible. Without F&E support, FAA modernization efforts will fail.

There are now 2,869 new FAA systems and equipment (designated by the agency as units) in FAA storage/warehouses. In several instances, cuts in F&E funding are cited as the reason why delivery has been delayed to the field. For example, there are currently 439 Communications Facilities Enhancement radios (UHF and VHF transmitters/receivers) in storage. The project cost is $3,736,000. The reason for delay is cited by the FAA as "F&E funding shortfalls caused by cutbacks in funding for establishment or relocation of communications facilities."

Similarly, because of "partial F&E funding provided in FY 1996," 64 Doppler VHF Omnidirections Range (DVOR) systems are in storage. These systems cost $108,000 each for a project cost of $6,912,000. Unless F&E is funded at higher levels, more and more new systems will sit in boxes awaiting delivery to the field. Meanwhile, the current systems will age, and modernization goals will fail.

Chapter two of the final report of the White House Commission on Aviation Safety and Security addresses "Making Air Traffic Control Safer and More Efficient." According to the report, the "FAA should develop a revised NAS modernization plan within six months that will set a goal of being fully operational nationwide by the year 2005." The FAA has reached a stage where incremental improvement is not sufficient. Yet, given the agency’s track record and the current climate at the FAA, PASS believes the agency will not be able to meet the Commission’s recommendation.

The White House Commission found that the FAA’s "proposed schedule for modernization is too slow to meet projected demands, and funding issues are not adequately addressed." This has been the case for years. Since the early 1980s, the FAA’s modernization program has experienced substantial delays and cost overruns.

PASS believes the FAA can succeed in modernizing the air traffic control system by building on its proven strength – its employees. The same ingenuity and perseverance that now enable the men and women of PASS to keep the NAS running is what is needed to bring the FAA into the 21st century. Instead of telling these employees – who are stakeholders in the system – how they must change to be part of the future, the FAA should be asking its employees to show the agency the future.

According to the GAO, "in organizations with more constructive cultures, employees are more likely to involve others in decisions affecting them, openly share information, and resolve differences collaboratively." In the FAA, however, "ineffective coordination has caused the agency to acquire systems that cost more than anticipated and took longer to implement."

PASS employees are a vital part of developing the future NAS and are the FAA’s best insurance that this new system will work as advertised. But FAA management excludes its Technicians and Controllers – who are the subject matter experts in the field and the end users of the product – from devising and developing ATC modernization solutions and plans. Instead, they are merely asked to help implement management’s plan.

PASS urges the FAA to involve employees from the lowest operating levels in the highest levels of the acquisition process. The agency would thereby hear the concerns and needs of the employees and would have the experts available to help resolve identified problems. Problems in the design, operation, or maintenance of new systems would be corrected before they are fielded, when changes are still the responsibility of the contractor.

Although the GAO recommended that the "Secretary of Transportation direct the FAA Administrator to develop a comprehensive strategy for cultural change … [to] include specific responsibilities and performance measures for all stakeholders throughout FAA," the agency is not complying. Again, a perfect example is STARS.

Flight Standards Aviation Safety Inspectors

PASS proudly represents approximately 2,500 Aviation Safety Inspectors and clerical employees of the Flight Standards service. According to the FAA, "Inspectors have an enormous scope of responsibility that includes the oversight of: 7,300 scheduled commercial aircraft; 11,100 charter aircraft; over 184,000 active general aviation aircraft; 4,900 repair stations; over 600 schools for training pilots; 200 maintenance schools; and over 665,000 active pilots." The FAA also reports that Inspectors perform more than 400,000 safety inspections annually.

It is unfortunate that it took last year’s tragic crash of ValuJet Flight 592 to enlighten the public and the press to the clear and present dangers in the FAA’s aviation safety inspection program. Since the accident, the agency has reevaluated its program. And, at the request of former Administrator David Hinson, the FAA worked with PASS to conduct an internal safety audit, examining safety inspection concerns. The end result – a lengthy FAA 90 Day Safety Review report – contains six principal recommendations and over 30 supporting recommendations.

 Staffing

Issue six of the FAA 90 Day Safety Review addresses Inspector Resources and recommends that the FAA ensure "Flight Standards resources and training are adequate to meet safety requirements." The report finds that "Flight Standards staffing levels do not meet current requirements because: 1) Flight Standards funding has not kept up with rising personnel costs; 2) staffing standards are incomplete; and 3) the shortfall in support staff requires Inspectors to undertake non-technical tasks, which, in turn, prevents them from spending full time doing safety-related work."

PASS is pleased that the agency recognized that more Inspectors are needed to meet the growing aviation demands, requesting an additional 273 new Flight Standards Inspectors and certification personnel for FY 1998. We ask you to support this staffing increase and to recommend to Congress the appropriate funds to hire enough Inspectors to meet current needs. In addition, PASS asks you to recommend appropriate funds to hire more clerical personnel in Flight Standards. According to the FAA’s own staffing standards, Flight Standards was short nearly 200 clerical employees in FY 1996.

Training

Inspector training is as important as Inspector staffing. For FY 1998, PASS understands that the FAA has requested $30 million in its operations budget for additional technical training/flight proficiency training. The agency has also requested $13.2 million to meet the initiatives of Challenge 2000. While we are pleased that the agency is asking for more money for training, we are concerned that the funds are not specifically targeted for Inspectors.

Never before has the need for Inspector training been so essential. The FAA has established high standards that potential Inspectors must meet in order to qualify for employment with the Agency. FAA Orders stipulate that once Inspectors are hired and attend initial training according to their specialties, they must be kept current and exposed to the latest industry aircraft, systems, and technologies in order to stay current. For Operations Inspectors, this means recurrent flight training and regular flight proficiency. For Airworthiness Inspectors, this translates to training on specific aircraft and new technologies used in aviation maintenance.

In recent years, the FAA has failed to meet its own training requirements due to its lack of funds specifically targeted for Inspector currency and training. Substantial numbers of Inspectors are neither current nor proficient. For instance, as Flight Standards prepares to comply with its most recent internal directives regarding currency, bargaining unit employees report that approximately 30 percent of the operations work force will not be current and qualified as required to administer flight checks this fiscal year.

The lack of training funds has been a perpetual handicap to the Inspector work force. Flight Standards training dollars have been slashed below the absolute minimum in each of the last four years. The effect has reduced the number of field Inspectors receiving flight training even though they are still needed to perform vital certification functions. Only this year have the training dollars increased, but even these funds are far below Flight Standards true training requirements.

In a very shocking development, PASS was recently notified by the agency that it is proposing to change its FAA Aircraft Management Program to reduce flight hours for pilot currency (which would impact Operations Inspectors) from "24 to 12 in a 6 month period." On May 12, 1997, at Washington National Airport the consequences of FAA training shortfalls nearly became a reality. A lear jet owned and piloted by the FAA made a wrong turn and entered into an active runway as a USAir Express aircraft was taking off. The two aircraft narrowly missed colliding. How can the FAA even consider changing its currency requirements?

Last year the GAO testified that the "FAA needs to more effectively target [its] inspection resources." Moreover, the GAO stated that if the FAA’s request for additional Inspectors is approved, "it will continue to be important that FAA targets its hiring to areas of greatest need and provides both its current staff and any new hires with the technical training necessary to be fully effective." PASS agrees with the GAO that "the FAA has not provided the technical training that both the certification and inspection staffs need to be fully effective. To fully utilize staff increases, FAA will have to overcome these problems."

The progress that the agency has made this year in correcting its aviation safety inspection problems will be negated unless Inspector staffing and training needs are met. With input and support from PASS, the FAA produced meaningful and significant recommendations within the 90 Day Safety Review. The agency – with oversight from Congress – must now follow through to ensure that these recommendations are implemented. Otherwise, we will be back to square one.

Conclusion

The point that I have tried to make today is that the status quo is no longer feasible. The FAA simply cannot maintain the world’s safest airspace with shrinking budgets and reduced staffing levels. Nor can it turn over its maintenance responsibilities to contractors, masking the decision as cosmetic cost savings. The bottom line is that contracting out costs taxpayers many times more than what it costs the government to have federal employees provide the same services. In addition, contracting out puts lives in danger, as last year’s ValuJet crash – which has tentatively been attributed to oxygen generators which were loaded in the plane’s cargo hold by a contractor – tragically demonstrates.

PASS urges the Commission to recommend to Congress that the FAA immediately increase Technician and Inspector staffing levels, revamp training programs, and eliminate the costly practice of contracting out. These changes will lead to increased productivity and will ensure the safety and efficiency of the National Airspace System.

APPENDIX A

Recently, at the request of Vice President Gore’s Aviation Safety and Security Commission, PASS calculated the number of FAA employees directly engaged in systems maintenance, as opposed to those who support systems maintenance. While we attempted to get in-depth data from the FAA, we were informed that the AF organization does not track the information as requested. In fact, Airway Facilities management was only able to provide us with a very limited breakdown of staffing numbers:

Field Maintenance FY 1996

Employees in the Systems Management Offices (SMOs), and Atlantic City and Oklahoma City Centers. They provide maintenance and certification of facilities, engineering, program and administrative support, management and supervision: 8,209

Planning and Technical Support

Employees located in Regional Offices, Centers, and FAA Headquarters. These employees manage national programs by providing engineering and program analysis, resource management, and administrative support: 1,090

Total Operations (Systems Maintenance) Staffing: 9,299

While it is unfortunate that the agency could not provide additional data, PASS was able to assemble true staffing numbers by contacting field and regional offices directly. We intend to share this information with the FAA in hopes of avoiding future disagreements over the interpretation of staffing levels. According to our research, the actual distribution of systems maintenance staffing is as follows:

FAA Headquarters FY 1996

Including Atlantic City and Oklahoma City Centers: 885

Regional Offices

This includes regional offices only, without Headquarters elements: 841

SMO Offices

Includes the technical, program, and administrative support for the System Support Centers (SSCs), as well as the first line supervisors of the field maintenance employees: 1,685

AF Employees Providing Hands-On Maintenance of the NAS: 5,888

Total Operations (Systems Maintenance) Staffing: 9,299

ENDNOTES