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Post by fu on Jun 19, 2015 12:53:05 GMT -5
Huerta is taking heat from congress on other corruption/inefficiency issues. This is good for us - they will be VERY careful how they handle things - but when the heat gets turned down, we are targets. Be ready. So far they are just testing the push back from user groups and how they could be used to lever more money from congress. Cool. So was the plan shelved or just put on hold?
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Post by TCU 2U2 on Jun 25, 2015 9:31:35 GMT -5
Yeah when is the next meeting? "The FAA intend to move forward with its plan to evaluate the transition of 57 CWOs to LAWRS; site specific SRM panels should begin taking place by mid-July 2015.
The FAA will include a post in the Federal Register."
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Post by consltg on Jun 25, 2015 10:48:42 GMT -5
We were informed by our contractor that it's almost a sure bet that these 57 closures will go into effect this fall (10/1/15). We all thought it would be later than that. Are any of you hearing the same thing?
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Post by hlsto2 on Jun 25, 2015 11:13:54 GMT -5
I thought the airport would be given one year from the announcement of any closures. I wonder if any of the contractors are taking the evidence given on here, that the tower cannot do the job, and going to the FAA with the evidence?
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Post by weatheri on Jun 25, 2015 11:34:45 GMT -5
I thought the airport would be given one year from the announcement of any closures. I wonder if any of the contractors are taking the evidence given on here, that the tower cannot do the job, and going to the FAA with the evidence? It is my understanding that they were provided a couple hundred pages of "quality" LAWRS observation indicating less than satisfactory encoding. I was also told that they questioned the entire process as well; mainly that nobody can give quality and informed input because nobody knows the formula used for the "new" standards. They also notified the CWO team at the FAA that the SRMP Panel did not follow its own guidelines. I have not seen the document but was informed of its existence. Four contractors stuck their neck out to challenge the FAA.
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Post by skobie on Jun 25, 2015 13:51:43 GMT -5
Here's the letter the 4 contractors that were at the May 14 meeting sent to the FAA in response to what happened/didn't happen at the meeting. I would recommend we all contact all of the 14 User Groups again and your Congresspeople and send this letter to them for reference (along with the continued info on this website). I plan to this weekend:
skobie
SRM Panel Participants Richard Carlson, Pacific Weather, Inc. Stephen Derrickson, IBEX Weather Robert Riekkola, RNR Technologies, Inc. James Rockhill, The Rockhill Group, Inc.
June 5, 2015
Mr. Ken Cunningham – Change Proponent Contract Operations Group (AJT-21) Contract Weather Team Lead Federal Aviation Administration 600 Independence Ave. SW Washington, DC 20591
Reference: ASOS/CWO/HWO SRM Panel (SRMP) May 14, 2015 and July 8-9, 2014
Dear Mr. Cunningham,
We continue to review the Safety Management System Manual V4.0 (SMSM) and the material presented at the SRMPs listed above. We have a variety of questions and concerns regarding both meetings, which we would like to discuss and document. Some of the issues raised here reiterate comments submitted to your office September 5, 2014, after the first SRMP. We are uncertain if those comments were added to the initial SRMD or taken into consideration.
SRMP Procedures
The May 14, 2015, SRMP did not follow guidelines and procedures established in the SMSM. In particular the panel members were not permitted to discuss the effects of the proposed NAS change, which clearly jeopardizes the safety assessment process and results. SMSM Section 4.3.6 states:
4.3.6 SRM Panel Meetings Following the identification and invitation of SMEs and stakeholders, the SRM panel is convened. During the panel, the facilitator will lead participants in objectively examining, identifying, and mitigating potential safety hazards and effects associated with the proposed NAS change. Throughout the meeting multiple panel participants identified safety hazards and effects associated with the proposed change, specifically the transition of up to 57 CWOs to LAWRS. The facilitators explained the panel could not discuss the effects of the NAS change and this tenet was repeated over and over by the facilitators, yet their assertions directly contradict the SMSM. Without examining the effects of the NAS change the SRMP did not properly assess the safety aspects of the proposed change, consequently an in-depth safety analysis did not occur. Since multiple SME’s attempted to discuss the effects of the NAS change in vain, we wish to ensure the opinions of the dissenters were documented per SMSM 4.3.6.4:
4.3.6.4 SRM Panel Deliberations SRM panels should strive to reach consensus, but there may be instances in which not all SRM panel members agree on the results of the safety analysis. In those cases, document the results of the analysis, record the opinions of the dissenters, and deliver the results to the decision-maker. AJI encourages dissenting SRM panel members to provide their own rationale and data for why their severity and/or likelihood determination differs from that of the other SRM panel participants.
The SRM panel facilitator must mediate and assist SRM panel members in working through differences of opinion. The facilitator should be able to recognize, acknowledge, and use differences of opinion to help the SRM panel consider different points of view.
In addition, SMSM Section 4.3.1 states:
4.3.1 SRM Panel Facilitator All SRM panels are led by a facilitator, a trained expert on the SRM process. A person working in such a capacity must be trained and designated as an SRM panel facilitator. The role of the facilitator is to work with the change proponent to help scope the safety analysis and moderate the deliberations of the SRM panel. The SRM panel facilitator should become well-versed in the subject matter, requesting briefings and collecting all available and relevant safety information, as necessary, before the SRM panel convenes. The facilitator will provide all relevant information about the NAS change to the SRM panel members before the panel meeting. An effective SRM panel facilitator guides the panel to ensure compliance with the SRM process, limiting his or her influence on the safety analysis. He or she must remain neutral to the outcome. We requested and received a draft briefing package prior to the May 14, 2015, SRMP. Unfortunately, it did not contain all relevant information about the NAS change as directed by SMSM 4.3.1. The projected outcome of the change, which describes the proposed transition of up to 57 CWOs to LAWRS, was delivered during the meeting. This relevant and important information should have been provided to the panel before the meeting to allow for a thorough review and analysis. Furthermore, the methods the FAA used to identify the 57 airports proposed for transition were not disclosed, which is a significant omission of relevant information. It should also be noted that we did not receive a briefing package prior to the July 8-9, 2014, SRMP. In both instances the lack of information beforehand did not allow adequate preparation for the SRMP and inhibited meaningful deliberations and discussions among the participants. Inclusion of Original National Aviation Associations/Industry Groups The SMSM consistently emphasizes the importance of stakeholder involvement when making changes to the NAS. For example SMSM 3.6.1.2 states, in part: 3.6.1.2 Risk Avoidance
Risk must be avoided from the perspective of all affected stakeholders. Thus, an avoidance strategy is one that involves all of the stakeholders associated with the proposed NAS change.
In November 1994, senior management officials from the FAA and the NWS met with fourteen national aviation associations/industry groups and agreed on the ASOS Service Standards. These standards define the level of augmentation and back up required by the observers at ASOS sites. Subsequently, a government/industry team met to assess the needs for surface observations at the Nation’s airports. Their work resulted in agreement on a proposed four-level service standard and a determination of the FAA and NWS ASOS sites to which the standards apply. In February 1996, the Service Standards policy was implemented and applied to all FAA and NWS ASOS sites. With such significant changes to the Service Standards being proposed has the FAA actively sought input from the fourteen industry groups that helped create the original Service Standards? The original Service Standards information and policy was published in the Federal Register. The FAA is now recommending the transition of up to 57 CWOs to LAWRS, meaning numerous ASOS observations will no longer be augmented or backed-up to the level specified in the Federal Register. This portends a definite degradation of services. Have the proposed changes to current Service Standards policy been published in the Federal Register so industry groups and stakeholders can learn about the key changes and provide comments and feedback? Although included in the SRMP agenda and called for in the SMSM, complete Panel Member and Observer Introductions did not occur. Title, years of experience, specialty, SMS training, and identification as a panel member or observer were not disclosed to the panel. Without the requisite introductions it is not apparent if industry groups and other major stakeholders attended the SRMPs or are involved with the SMS process. Major changes to the Service Standards without involvement from the fourteen original industry groups is not sensible and increases risk to the Service Standards review process. In accordance with SMSM Appendix C, Section 3, please provide a detailed list of the stakeholders, including the name and title of each individual, that were invited to each SRMP but did not participate: Appendix C, Section 3—Safety Risk Management Panel 1. List the SRM panel members, including their title, specialty, and years of experience, and indicate whether they attended/participated in the SRM panel. (It is not necessary to indicate attendance for each meeting; document if a stakeholder was invited but did not participate.) 2. Describe the panel meeting schedule, responsibilities, and milestones achieved. Explain how the SRM panel worked through the SRM process. 3. If there is an existing process that was successfully used to develop and implement earlier systems, procedures, or NAS changes, then provide insight into how this process relates to the SRM and, if applicable, how this process was modified to meet all SRM requirements.
SRMP I and II - Inconsistencies
At this juncture it appears the recent SRMP was intended to dovetail with the one conducted July 8-9, 2014, but contradictions exist between the first and second SRMP. According to the SRMD Version 1.0, dated July 18, 2014, the panel recommended termination of HWO service at 15 non-standard airports in Alaska. Surprisingly, and without explanation, the FAA now indicates the previous SRM Panel concluded:
May 14, 2015, HWO SRM Handout Alaska facilities were not considered for further changes under revised July 2014 ASOS Service Standards Policy.
Why didn’t the FAA adopt the recommendation of the first SRMP to terminate the services at the 15 non-standard airports in Alaska? How did this important change effect the ASOS Service Standards agenda?
In addition, a list of Severe Winter Weather Parameters was introduced at the first meeting which was intended to add operationally-relevant parameters to the Service Standards algorithm. Ice pellets was an obvious omission from the list, which we have already expressed and wish to reaffirm. When proposed this change was described as an extra safety measure meant to ensure CWOs continue operating at airports that regularly experience severe winter weather and where air traffic controllers cannot leave the tower to augment or backup the ASOS. Inherent shortcomings of the ASOS present weather sensors were described as the reason for the algorithm addition. Oddly, the proposed outcome of the recent SRMP transitions up to 57 CWOs to LAWRS at many locations across the northern tier of the United States that frequently experience severe winter weather. Similar to the 15 non-standard airports in Alaska, this result is in stark contrast to the recommendations of the first SRMP.
What methods did the FAA use to identify the 57 airports slated for LAWRS? Exactly how the airports were chosen is unclear and unexplained. To conduct a proper safety analysis the FAA should disclose or share this information. Regrettably, the lack of transparency means SRM panel participants, stakeholders, and industry groups cannot/did not objectively assess the safety of the proposed changes to the Service Standards or the NAS.
As SRMP participants we do not understand how, when, or why critical changes were made to the recommendations of the first SRMP. Moreover, it appears many of the questionable changes to the Service Standards algorithm divulged in the first meeting have been adopted without any real discussion or input from stakeholders or industry groups. Notification to the public has also been nonexistent. This is troubling since the FAA has not revealed what specific changes have been made to the original algorithm, so it is impossible to examine the scope of the changes and their impact on safety. Above all, the profound and wide-ranging effects of the changes to the Service Standards and the associated algorithm (e.g., transitioning CWOs to LAWRS) were not discussed at both SRMPs, and they have not been conveyed to the stakeholders or industry groups, which is a breach of SMS policy.
Unspecified Algorithm
Although the Service Standards were agreed to by the FAA, NWS, and fourteen national aviation associations/industry groups, the FAA is proposing to unilaterally change the Service Standards. This will be accomplished by removing purported obsolete and unneeded parameters from the algorithm used to determine the Service Standard Levels. For example thunderstorms, visibility less than ½ mile, and visibility less than 3 miles is being removed from the bad weather score of the algorithm. The FAA added another modification to the algorithm at the recent SRMP, which is the removal of the nearest suitable alternate airport from the algorithm equation.
To this point it has been impossible to perform a meaningful safety analysis of the proposed algorithm changes. SME’s and stakeholders have never had access to the revised algorithm, its equation or how it is calculated, the arithmetic scoring utilized, what years of air traffic operations are part of the equation, and if the long-standing two-year sustainment rule was followed. We must underscore the effects of the wholesale changes being made to the Service Standards algorithm were not discussed at either SRMP, which defies the guidelines of the SMSM and renders the meetings ineffective.
Flawed Assertions
The FAA provides three reasons for overhauling the Service Standards and transitioning up to 57 CWOs to LAWRS. All three reasons are ambiguous and misleading.
1. For over twenty years LAWRS controllers have been providing human augmentation without degradation of service.
This assertion is false.
Certainly, no one could suppose there is “no degradation of service” when changing from a full-time professional weather observer whose entire job/career is dedicated to surface weather observation/reporting to a professional air traffic controller whose entire job/career is dedicated to controlling air traffic. Moreover, air traffic controllers will attempt to accomplish surface weather observations from the top of a very tall ATC tower (never being allowed to go outside) only “to the extent possible” IAW FAA JO 7110.65 Air Traffic Control, Paragraph 2-1-2 Duty Priority. Without question LAWRS is a constrained and subordinate function and a clear degradation of services.
For the last several years we have monitored and recorded LAWRS observations. The METARs/SPECIs disseminated from these sites repeatedly violate policies, procedures, and rules established in FAA JO 7900.5. Errors and omissions of critical weather data are common and widespread. Required information such as wind data, visibility, present weather, sky condition, and temperature and dew point is often missing and not backed-up or provided by LAWRS personnel. A small sampling of this data resulted in 200+ pages of degraded weather observations issued by LAWRS controllers, which we’ve attached/included with this letter. We continue to observe and capture a lot of substandard METARs and SPECIs issued by LAWRS personnel, and will provide this supplementary data to your office in the future.
2. Many advancements in sensors, algorithms, and equipment have occurred since ASOS inception.
• The capabilities and limitations of the ASOS have not changed appreciably since its inception.
• An advancement to the dew point sensor primarily helped reduce routine maintenance visits by technicians.
• The AWPAG replaced tipping-bucket technology in favor of a weighing precipitation gauge, but the FAA is not involved with capturing climatological data and/or precipitation amounts so this update primarily benefitted the NWS.
• The ice free wind sensor was introduced to the ASOS network during the summer of 2005 and started experiencing problems shortly afterward. In January 2008, the ASOS Ice Free Wind Problem Resolution Project Plan was launched, which established a road map for finding a resolution to the “bird alighting” dilemma along with resolving other problems with the sensor. Ice free wind sensor outages and issues continue today.
• The legacy Cloud Height Indicator sensor initially deployed with ASOS was the Vaisala CT12K ceilometer. In 1998, Vaisala discontinued production of the CT12K with an agreement to provide logistical support for the sensor through 2005. The NWS repair depot located in Kansas City, MO had an adequate inventory of logistical parts to support maintenance of the CT12K for at least two additional years (i.e., 2007). Therefore, a new ceilometer needed to be developed, tested, and deployed for the ASOS network. Beginning in 2008 the Vaisala CL31 ceilometer was phased-in to the ASOS network, but the current software doesn’t support its ability to report clouds to 25,000 feet. • ASOS ALDARS information remains inaccurate, unreliable, and does not replace the information currently provided by CWOs. In addition, the network only captures cloud-to-ground lightning strikes meaning only one of four types of lightning are detected by ASOS ALDARS. This leaves aviators at risk with no detection of IC (In Cloud), CC (Cloud to Cloud), or CA (Cloud to Air) lightning – a major weakness.
• Equipment outages continue to occur at a rate higher than advertised by the FAA, as demonstrated by performing monitoring statistic recorded by CWOs on a monthly basis. In fact, data captured and reported by AJT-21 does not match performance claims made in ASOS maintenance reports, compounding the statistical inconsistencies.
In essence, the advancements to the ASOS sensors, algorithms, and equipment aren’t noteworthy in the operational environment and have had minimal impact to the inherent limitations of the ASOS.
3. More weather information available to tower controllers, pilots/dispatchers, and airlines. This justification has no bearing on the requirement for accurate, complete, and timely surface weather observations at each airport. It is unclear exactly what weather information is being considered or referenced with this claim. The principle method to ascertain current weather conditions at every airport is the official surface weather observation, and this data cannot be replaced or substituted by weather information attained by external means.
Conclusion
As SRMP participants we believe the SMS process has been flawed due to the reasons stated herein. The approval actions listed in SMSM 5.6 have not been accomplished or realized. 5.6 SRMD and SRMDM Approval SRMD approval requires and represents that: • The SRMD was developed properly, • Hazards were systematically identified, • Risk was appropriately assessed, • Valid safety requirements were proposed for unacceptable risk, • Safety performance targets or other methods to verify predicted residual risk were approved by the responsible Service Unit, and • An implementation and monitoring plan was prepared.
We understand the fundamental mission of the ATO is to ensure the safe provision of air traffic services in the NAS, therefore we will continue to review the SMSM and the changes proposed by the SRMPs and forward any additional questions or comments as soon as possible.
Sincerely,
Richard Carlson
Stephen Derrickson
Robert Riekkola
James Rockhill
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Post by consltg on Jun 25, 2015 13:54:14 GMT -5
Hoping someone out there can verify if it's the intention of the FAA to close the 57 sites on 10/1 of this year. Our contractor has been great at keeping us informed on all the goings on between us and the FAA, (plus they've been very active in helping save our jobs),but we just find it a bit unfathomable and wreckless that they would do this so quickly. Just seeing if anyone else has heard of the same timeline. I thought their were more meetings on this also. Thanks.
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Post by fu on Jun 25, 2015 14:30:03 GMT -5
That is a nice letter skobie!
Consltg no official dates have been given yet, assume they want to do it as quick as possible though. Dates and responses to the issues raised in the letter skobie posted should be in the final report that the FAA sends out for the May panel.
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Post by alstein on Jun 25, 2015 14:59:02 GMT -5
Local Senator is saying as far as they can tell there are no plans to shut down sites.
I don't think they'll be able to do it within three months without massive pushback from across the board- including ATCs.
10/1/16 is possible, but given that's just one year from EOC- they may just ride out the contract and think it's easier to just not give new ones and shut it down then.
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Post by fu on Jun 25, 2015 15:19:23 GMT -5
That's an interesting theory alstein. I hope you're right.
What kind of pushback are you expecting from ATC?
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Post by TCU 2U2 on Jun 25, 2015 15:23:58 GMT -5
Local Senator is saying as far as they can tell there are no plans to shut down sites. I don't think they'll be able to do it within three months without massive pushback from across the board- including ATCs. 10/1/16 is possible, but given that's just one year from EOC- they may just ride out the contract and think it's easier to just not give new ones and shut it down then. Current contract ends on September 30, 2018 ... assuming all options are exercised. The contracts were added an additional option year shortly after the awards, which started December 1, 2013. This added option year was to make up for the long delay in awards to several of the groups due to protests running their course.
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