Office of Inspector General
Audit Report
CONTRACT TOWERS CONTINUE TO
PROVIDE COST-EFFECTIVE AND
SAFE AIR TRAFFIC SERVICES, BUT
IMPROVED OVERSIGHT OF THE
PROGRAM IS NEEDED
Federal Aviation Administration
Report Number: AV-2013-009
Date Issued: November 5, 2012
Memorandum
U.S. Department of
Transportation
Office of the Secretary
of Transportation
Office of Inspector General
Subject:
ACTION: Final Report: Contract Towers
Continue To Provide Cost-Effective and Safe Air
Traffic Services, but Improved Oversight of the
Program Is Needed
Report No. AV-2013-009
Date:
November 5, 2012
From:
Jeffrey B. Guzzetti
Assistant Inspector General for
Aviation and Special Program Audits
Reply to
Attn. of:
JA-10
To:
Acting Federal Aviation Administrator
FAA’s Federal Contract Tower (FCT) Program (the Program) comprises
250 contract towers in 46 States and 4 U.S. Territories and provides services to a
wide range of users, including general aviation, commercial, cargo, and military
operators. Since its inception 30 years ago, the Program has been successful in
providing low-cost air traffic control services at airports that otherwise would not
have received these services, increasing the level of safety at these airports for
pilots and the surrounding local communities.
Between 1998 and 2003, we conducted four reviews evaluating various aspects of
the FCT Program.
1
1
OIG Report Number AV-1998-147, “Federal Contract Tower Program,” May 18, 1998; OIG Report Number AV-
2000-079, “Contract Towers: Observations on FAA's Study of Expanding the Program,” April 12, 2000; OIG Report
Number AV-2002-068, “Audit Report on Subcontracting Issues of the Contract Tower Program,”
December 14, 2001; OIG Report Number AV-2003-057, “Safety, Cost, and Operational Metrics of the Federal
Aviation Administration's Visual Flight Rules Towers,” September 4, 2003. OIG reports are available on our Web
site at http://
Overall, we found that the Program successfully provided air
traffic services to low-activity airports at lower costs than the Agency could
otherwise provide. We also found little difference in safety or the quality of
services provided at low activity towers whether they were operated by FAA or by
contractors. Finally, we found that users were supportive of the Program and
believed the services they received at contract towers were comparable to FAA
towers.
www.oig.dot.gov.
2
The House Committee on Appropriations, in its report accompanying the Fiscal
Year (FY) 2011 Transportation, Housing and Urban Development, and Related
Agencies bill, requested that we provide an update to our previous reviews.
Accordingly, our audit objectives were to evaluate the FCT Program’s (1) cost-
effectiveness and (2) safety benefits and overall user satisfaction. This audit was
conducted in accordance with generally accepted Government auditing standards.
Exhibit A details our scope and methodology. Exhibit B lists the organizations we
visited or contacted.
RESULTS IN BRIEF
Contract towers continue to provide air traffic control services at a lower cost than
similar FAA towers. Based on our review of 30 randomly selected contract and
30 FAA towers with a comparable level of operations, a contract tower cost, on
average, about $1.5 million less to operate than a similar FAA tower.
2
Also, contract towers had a significantly lower number and rate of safety
incidents
This
difference was mainly due to lower staffing and salary levels at contract towers
versus similar FAA towers. However, there are areas where FAA can strengthen
financial controls to better oversee the Program. In particular, the program office
does not review annual labor hours worked by the contractors to ensure that
staffing provisions in the contract are followed. This lack of oversight could lead
to non-compliance with contract requirements and possible overpayments to
contractors.
3
compared to similar FAA towers. For example, the 240 contract towers
in our review had 197 safety incidents in FY 2010, compared to 362 at 92 similar
FAA towers. FAA safety evaluations also found fewer operational deficiencies
with contract towers in areas such as improper radio communications by
controllers. In addition, users remain strongly supportive of the Program, citing
satisfaction with the quality and safety of its services. However, there are
opportunities for FAA to improve safety oversight of contract towers. For
example, contract towers are not included in voluntary reporting systems for safety
incidents, such as the Air Traffic Safety Action Program (ATSAP) that is currently
in place at all FAA facilities.
4
2
Using FY 2010 data, we compared personnel compensation and benefits, travel and transportation, supplies,
materials, and insurance costs for a sample of 30 contract and 30 FAA towers with similar air traffic density.
Finally, FAA has recently implemented a new risk-
based facility oversight system that relies heavily on reported safety data to
determine when towers are reviewed. However, this may cause some contract
3
These safety incidents include operational errors, operational deviations, and runway incursions. An operational error
occurs when an air traffic controller does not maintain minimum separation between two aircraft or between an
aircraft and terrain or obstacles. An operational deviation occurs when a controller allows an aircraft to enter
airspace managed by another controller without prior coordination and approval. A runway incursion is any incident
involving an unauthorized aircraft, vehicle, or person on a runway.
4
ATSAP is a voluntary, non-punitive safety reporting program established by the FAA to encourage air traffic facility
employees to voluntarily report safety and operational concerns.
3
towers to be evaluated less frequently in the future, which would be counter to
recent legislation that requires regular safety assessments of contract towers.
We are making recommendations to improve FAA’s internal controls and
oversight of contractual and safety aspects of the FCT Program.
BACKGROUND
In 1982, FAA began the FCT Program as a pilot program to contract air traffic
services for five low-activity “level 1” control towers that were closed as a result
of the Professional Air Traffic Controllers Organization strike. By 1993, the
Program had grown to 27 towers, and in 1994 Congress provided funding for a
multi-year program to convert additional FAA low-activity towers to contract
operations. The Program was further expanded in 1998 when Congress provided
funding for a cost-sharing program, which allows airports that would not normally
qualify for the FCT Program access by permitting its sponsors to pay for a portion
of the costs to operate the tower, with FAA providing at least 80 percent of the
cost.
Today, there are 250 towers in the FCT Program; 228 towers are fully funded by
FAA, 16 are part of the cost-share program, and 6 towers are used by the Air
National Guard.
5
Three contractors operate the towers in seven geographic areas.
The current contracts, which run from February 1, 2010, to September 30, 2014,
are worth nearly $600 million. The administrative functions of the Program are
overseen by FAA’s Contract Tower and Weather Group (CTWG),
6
CONTRACT TOWERS CONTINUE TO PROVIDE COST-
EFFECTIVE SERVICES, THOUGH FAA CAN IMPROVE ITS
OVERSIGHT OF THE PROGRAM
with safety
oversight provided by the Agency’s Aviation Safety Organization. FAA is
requesting $138 million in FY 2013 to operate the FCT Program, $8 million of
which is for the cost-share program.
Contract towers continue to provide cost-effective air traffic services, with the
average contract tower costing about $1.5 million less to operate than a
comparable FAA tower. This cost difference is primarily due to fewer staff at
contract towers who receive lower salaries compared to similar FAA-operated
towers. However, FAA can improve oversight of the FCT Program by ensuring
annual labor hours worked by the contractors meet contract requirements.
5
The six Air National Guard Towers are included in the FCT Program under a special agreement with the Department
of Defense.
6
CTWG serves as the technical and programmatic focal point for the Contract Weather Observation (CWO) and FAA
Contract Tower (FCT) programs. CTWG establishes standard operating procedures (SOPs) and processes for the
CWO and FCT programs to ensure FAA standards, orders, and procedures are achieved in a quality and timely
manner.
4
Operating Costs at Contract Towers Are Significantly Less Than
Comparable FAA Towers
Contract towers continue to operate at a lower cost than comparable FAA towers.
We selected a statistical sample of 30 contract towers, which we matched with
30 FAA towers with similar air traffic densities.
7
Based on our sample, the average cost to operate a contract tower in FY 2010 was
about $537,000, compared to $2.025 million to operate an FAA tower, a
difference of $1.488 million.
We evaluated the FY 2010
operating costs for each of the contract and FAA towers in our sample to
determine the annual cost difference. These costs included air traffic personnel
compensation and benefits, travel and transportation, supplies, materials, and
insurance. Infrastructure, maintenance, and equipment costs for FAA and contract
towers were not included in our analysis because, under terms of the contract, FCT
contractors are not responsible for these costs.
8
• Contract towers are staffed at lower levels than comparable FAA towers.
The contract towers in our audit sample had an average of 6 air traffic
personnel while the FAA towers had an average of 16 air traffic personnel (see
table 1). In FY 2010, staffing levels at the 240 contract towers ranged from 4
to 9 air traffic personnel, while staffing ranges at the 92 FAA towers ranged
from 7 to 27 personnel.
The difference in cost is primarily attributable to
two factors:
9
• Contract tower controllers are paid less than FAA controllers. Contract
tower controllers’ salaries are based on Department of Labor (DOL) wage
rates, which are lower than the salaries paid to FAA controllers. For example,
based on current DOL rates, an air traffic controller at a contract tower near
Tampa, FL, would receive base pay of about $56,000 per year, whereas an
FAA-employed air traffic controller in Sarasota, FL, an area with similar costs
of living, would receive base pay ranging from about $63,000 to $85,000 per
year, depending on the controller’s experience.
7
Density is defined as the average number of operations at a tower per hour the facility is open.
8
FAA’s FY 2010 estimated cost to administer the FCT Program ($2.23 million or about $9,000 per FCT) was not
included in our cost calculation. See Exhibit E for a summary of our cost difference estimate.
9
Air traffic personnel are defined as air traffic controllers, supervisors, and management.
5
Table 1. Cost and Staffing Differences Between 30 Contract Towers
and 30 Comparable FAA Towers
Average Air Traffic
Density
Average FY 2010 Cost
Average Number of
Air Traffic Personnel
FAA Tower
15.55
$2,025,104
16.23
Contract Tower
15.34
$536,911
6.03
Average Difference
0.21
$1,488,193
10.20
Source: OIG analysis based on FAA data
FAA Can Improve Its Oversight of the Contractual and Operational
Aspects of the Program
While contract towers continue to operate at a lower cost than comparable FAA
towers, FAA has opportunities to improve its oversight of the contractual and
operational aspects of the FCT Program. Our 1998 review of the FCT Program
found that contract towers were not staffed in accordance with contractor staffing
plans, raising concerns that the Government was being billed for services that
were not actually provided. In response to our report, FAA included a provision in
subsequent contracts to enhance oversight of contractor performance. This
provision requires contractors to submit a staffing plan that includes the number of
controllers that will work at the tower and the total annual number of hours those
controllers will work, exclusive of vacation, holiday, and sick leave. Once FAA
approves the staffing plan, the contractors must comply with the staffing levels
and hours of service called for in the plan, and actual hours worked must be within
plus or minus 3 percent of the approved plan. If the contractor works less than
97 percent of the hours specified in the contract, the amount paid to the contractor
could be reduced for each hour not worked.
However, our current audit found that the effectiveness of this control is limited
because FAA does not review the actual annual hours worked by contractors or
verify that the hours billed by contractors are accurate. According to a CTWG
official, no one in the Agency’s contracting office had reviewed the actual annual
hours worked by the three contractors to ensure they met contractual requirements.
Instead, the program office only reviewed monthly reports provided by the three
contractors and accepted those reports. As a result, FAA may be paying for
services that have not been provided and missing opportunities to recoup funds
due to the lack of a validation process.
In addition, officials from the CTWG office were not aware of staffing practices at
some contract towers. According to a CTWG official, none of the contractors had
submitted staffing plans for contract towers that included part-time staffing.
However, we found two towers during our site visits that used an alternative work
schedule allowing two employees or more to voluntarily share the responsibilities
6
of one full-time position, and receive salary and benefits on a pro-rata basis. The
contract does not prohibit part-time employees at contract towers but CTWG
officials were unaware of the job-sharing at these two towers until we brought it to
their attention.
WHILE CONTRACT TOWERS CONTINUE TO PROVIDE SAFE
SERVICES AND ARE SUPPORTED BY USERS, ADDITIONAL
OVERSIGHT IS NEEDED
Overall, contract towers had a lower number and rate of safety incidents. FAA
facility evaluations also found fewer safety/operational-related issues with contract
towers than with comparable FAA towers. In addition, users continue to support
the Program and are satisfied with the safety and quality of the services provided
by contract towers. However, there are opportunities for FAA to improve safety
oversight of contract towers. For example, contract towers do not have voluntary
reporting systems for safety incidents that are similar to FAA towers. In addition,
FAA’s new risk-based oversight system may cause some low-risk towers, such as
contract towers, to be evaluated less frequently in the future.
Contract Towers Have a Lower Number of Reported Safety Incidents
and Deficiencies Than Comparable FAA Towers
We compared the 240 contract towers and 92 comparable FAA towers
10
Table 2. Number and Rate of FY 2010 Safety Incidents at Comparable
Contract and FAA Air Traffic Control Towers
and found
that in FY 2010 contract towers reported both a lower number and rate of safety
incidents than comparable FAA towers (see table 2).
Total Number of Safety Incidents
Incident Rate Per One-Million Operations
Towers
Operational
Errors
Operational
Deviations
Runway
Incursions
Operational
Errors
Operational
Deviations
Runway
Incursions
240 Contract
18
12
167
1.24
0.83
11.55
92 FAA
52
35
275
4.54
3.06
24.01
Source: OIG analysis of FAA data
Contract towers also had a significantly lower number of deficiencies identified by
FAA during facility evaluations. FAA conducts these periodic evaluations to
determine if air traffic facilities, including contract towers, are in compliance with
FAA directives and to identify possible safety, procedural, training, and/or
administrative deficiencies. Using the same audit sample that we used for our cost
comparison, we reviewed facility evaluations for 30 contract towers conducted
10
See Exhibit A for an explanation of how our universe of contract towers and comparable FAA towers were selected.
7
between May 2006 and September 2010 and 30 comparable FAA towers
conducted between January 2007 and September 2010. These evaluations
identified a total of 156 deficiencies at the 30 contract towers and 338 deficiencies
at the 30 FAA towers. Some of the identified deficiencies at both contract and
FAA towers included outdated or incomplete training records, managers
inadequately conducting facility quality assurance reviews, controller
supplemental training not being completed, and improper position relief briefings
and radio communications by controllers.
Users Are Satisfied With the Level and Quality of Service Provided by
Contract Towers
As we have reported previously, pilots, flight instructors, airport officials, fixed-
based operators, as well as representatives from airport and general aviation
organizations, support the FCT Program. Specifically, users at 12 randomly
selected contract towers and 7 randomly selected FAA towers were satisfied with
the services provided by contract towers and the 3 contractors and believed the
services they receive were comparable to similar FAA towers. In several
instances, pilots were surprised to learn that towers they frequently interacted with
were actually contract towers, and described the services provided by similar FAA
and contract towers as “seamless.”
National and facility officials from the National Air Traffic Controllers
Association (NATCA), who represent controllers at 63 contract towers, similarly
support the cost-share portion of the Program. However, they had concerns
regarding controller staffing and training at contract towers that they believe could
compromise safety. They noted that contract towers have much lower staffing
levels than comparable FAA towers, are often single-staffed for portions of the
day, and that controller certification training at contract towers can take as little as
30 days, while at an FAA facility it can take from 1 to 5 years.
Despite NATCA’s concerns, FAA safety officials, local airport officials, pilots,
and other contract tower users generally stated that contract towers operate safely
and did not have concerns about staffing practices, including periods of single
staffing. In one case, a representative from a general aviation organization stated
that she received excellent services from a contract tower in West Virginia, even
during a time of day when it was staffed with only one controller. Airport and
general aviation representatives also stated that without the FCT Program many
small airports would not have the financial resources needed to operate these
towers and believed that towers with periods of single-staffing would be safer than
having no tower at all.
With regard to concerns over training time, FAA’s CTWG approves staffing levels
for contract towers and requires contract tower controllers to meet the same
8
certification requirements as FAA controllers and to be certified by FAA. In
addition, most contract tower controllers are former FAA or military controllers
who must have a Control Tower Operator license and between 6 months and
2 years experience in order to be hired. Conversely, FAA generally hires
controllers for its air traffic facilities with little or no air traffic experience who
require more training in order to certify at its facilities.
Accurate Incident Reporting at Contract Towers Is Critical to
Maintaining Safety
While contract towers continue to operate in a safe and efficient manner, there are
improvements that FAA can make to ensure the Program’s continued safety,
particularly in safety incident reporting. Contract towers must follow the same
process for reporting and documenting safety incidents as FAA facilities.
However, according to two FAA studies conducted between 2009 and 2010,
contract towers had a lower number of reported runway incursions than
comparable FAA towers between FY 2001 and FY 2008, and in FY 2009 contract
towers had a lower runway incursion reporting rate than FAA towers.
11
In light of these findings, managers from FAA’s Runway Safety Program Office
met with contractors and emphasized the importance of runway incursion
prevention and reporting. Subsequently, a 2010 FAA study found that more recent
data showed runway incursions reporting at contract towers had increased sharply.
However, contract towers still must rely on controllers to self-report safety
incidents, and unlike FAA air traffic control facilities, contract towers are not
included in voluntary reporting systems such as ATSAP, which allows controllers
to report safety violations without fear of reprisal through legal or disciplinary
actions. FAA is taking steps to include contract towers into a voluntary reporting
system, but has yet to require contractors to implement a similar system.
During
subsequent FAA facility evaluations of 17 contract towers, the Agency determined
that about 30 percent of the contract tower controllers interviewed did not know
the current definition of a runway incursion and 40 percent did not know the
criteria for classifying a runway incursion. FAA also found that two-thirds of
facilities reviewed had not submitted runway safety action plans for the previous
2 years.
Contract Towers May Not Receive the Same Level of Safety Oversight
in the Future
FAA will have to determine if its new facility oversight system will sufficiently
monitor contract towers. Prior to October 2010, facility safety evaluations, FAA’s
key mechanism to oversee contract towers, were conducted every 3 years for all
FAA and contract towers. In January 2012, FAA transitioned to a risk-based
11
“Study of Runway Incursion Reporting at Federal Contract Towers,” ATO’s Office of Safety, December 2010.
9
oversight system as its primary method to oversee air traffic facilities. Under the
new system, safety incident data entered by air traffic personnel is analyzed to
determine if specific safety problems or trends exist at air traffic facilities. Based
on this analysis, FAA will then focus its oversight to respond to those trends.
However, if data are unavailable due to a lower rate of occurrence, are unreliable,
or there are no trends to analyze, some low risk towers, including contract towers,
could go years without being evaluated. Should there be lengthy periods between
reviews of contract towers under this risk-based system, the system may not meet
the intent of new legislation
12
CONCLUSION
that requires the Secretary to “establish uniform
standards and requirements for regular safety assessments” of contract towers.
The FCT Program has successfully contributed to FAA’s goal of ensuring the
safety and cost-effectiveness of the air traffic control system. However, the
continued success of the Program will depend on effective follow through by FAA
to enhance how it collects and uses safety data on contract towers so that they
receive the appropriate level of oversight and to improve controls over the
Program’s contractual aspects to protect against any potential misuse of funds.
RECOMMENDATIONS
We recommend that FAA:
1. Develop a process to validate invoices and timecards submitted by FCT
contractors annually to (a) ensure that hours billed were actually worked and
met contract requirements, and (b) recover any overpayments made to the
contractors.
2. Modify FCT contracts to incorporate a voluntary reporting system, such as
ATSAP, at contract towers to ensure more comprehensive reporting of safety
incidents.
3. Implement a policy that will ensure its risk-based facility oversight system
allows for regular assessments of contract towers, as prescribed by Congress.
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL
RESPONSE
We provided FAA with our draft report on September 5, 2012, and received its
formal response on October 10, 2012. FAA’s response is included in its entirety as
an appendix to this report. FAA concurred with all three of our recommendations
12
FAA Modernization and Reform Act of 2012, Sec. 147, Public Law 112-95, February 14, 2012.
10
and proposed appropriate action plans. Based on FAA’s response, we believe the
Agency met the intent of all three recommendations and we consider them
resolved pending completion of the planned actions.
Since we issued our draft report, FAA has taken steps to improve its oversight of
the Program, which is cited in the Agency’s response. These steps include
developing new procedures to ensure contractual staffing requirements are met—
such as revising the audit process to validate contract tower controller timecards—
and conducting quarterly reviews of vendor’s monthly staffing reports for actual
hours worked compared with the base-lined contract. FAA has also modified the
vendors’ contracts to require a voluntary reporting system at contract towers, and
is finalizing its new risk-based oversight system that will provide safety oversight
of all air traffic facilities, including contract towers. However, FAA’s response
indicates that the Agency will not implement these changes until the end of this
year or the beginning of next year. We believe that implementing these changes is
critical to ensure the safety and financial success of the Program. Accordingly, we
request that FAA provide us with documentation once the new procedures have
been implemented.
ACTIONS REQUIRED
FAA’s planned actions for all three recommendations are responsive, and its target
action dates for the recommendations are appropriate. However, in accordance
with DOT Order 8001.C, we request that FAA provide our office with
documentation showing that it has implemented the new oversight procedures by
the target action dates indicated in its response.
We appreciate the courtesies and cooperation of FAA representatives during this
audit. If you have any questions regarding this report, please contact me at (202)
366-0500, or Robert Romich, Program Director, at (202) 366-6478.
#
cc: DOT Audit Liaison, M-1
FAA Audit Liaison, AAE-100
11
Exhibit A. Scope and Methodology
EXHIBIT A. SCOPE AND METHODOLOGY
We conducted our work from June 2011 through September 2012 in accordance
with generally accepted Government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
To determine the cost effectiveness of the FCT Program, we utilized a universe of
240 contract towers that as of February 2011 were under contract with FAA, and
excluded 6 towers in the Program that were operated on behalf of the Air National
Guard. We also utilized a universe of 92 FAA towers that the CTWG provided us
in February 2011 that it considered comparable to contract towers based on ATC
Levels and FY 2010 total number of operations. The OIG statistician, using
FY 2009 and FY 2010 numbers of operations and hours of service, calculated the
average density for each of the towers in the universe. The statistician then
selected a probability proportional to size (where size was density) sample of
30 contract towers, which we used to select 30 similar FAA towers by matching
the average density of each contract tower to a FAA tower. Then, we reviewed the
FCT contract and determined FAA costs compared to contractor costs. We
analyzed cost figures obtained from FAA's Office of Budget for each of the
30 contract towers and 30 similar FAA towers. These costs included personnel
compensation and benefits, travel and transportation, supplies, materials, and
insurance. Infrastructure, maintenance, and tower equipment costs were not
included in our analysis. Based on the sample of 30 FAA and 30 contract towers,
we calculated the FY 2010 average cost to operate an FAA tower and a contract
tower and the difference in FY 2010 average cost between the two groups.
To determine air traffic staffing levels at FAA and contract towers, we analyzed
staffing data obtained from FAA’s Office of Financial Services and FAA’s
Contract Tower and Weather Group for 92 FAA towers and 240 contract towers.
We included air traffic controllers, supervisors, and air traffic management in our
calculation of staffing levels.
To evaluate management controls established by FAA to administer the FCT
Program, we reviewed contractual agreements between FAA and FCT contractors
and FAA Orders on policies and procedures for administering the Program. We
held interviews and obtained information from FAA officials in the Air Traffic
Organization (ATO), Office of Financial Services, and the Office of Aviation
Policy and Plans. We also interviewed officials from the three FCT contractors.
To evaluate the safety of operations between FAA and contract towers, we
reviewed incident data for each of the 240 contract towers and 92 FAA towers for
12
Exhibit A. Scope and Methodology
FY 2010 provided by ATO’s Office of Safety (ATO-S). We then calculated the
rate of operational errors/deviations and runway incursions per million operations
for 240 contract towers and 92 FAA towers. In addition, we reviewed facility
safety evaluations conducted by FAA between May 12, 2006 and September 29,
2010 for 30 contract towers and between January 24, 2007 and September 29,
2010 for 30 FAA towers from FAA’s Facility Safety Assessment System (FSAS).
We identified deficiencies and determined whether our sample of 30 FAA and
30 contract towers were in compliance with FAA directives and procedures. We
also interviewed officials from FAA’s ATO, FCT contractors, and personnel from
7 FAA and 12 contract towers. We reviewed FAA’s 2010 Study of Runway
Incursion Reporting at Federal Contract Towers and analyzed FAA Orders
concerning Quality Assurance and Quality Control. Lastly, we reviewed
Congressional language contained in FAA’s Modernization and Reform Act of
2012.
To determine the quality of service provided by contract towers and user
satisfaction, we visited 7 FAA towers and 12 contract towers which were selected
using a stratified probability proportional to size with replacement sample design.
At these facilities we met with Air Traffic Managers, union officials, pilots, fixed
base operators, airport directors. We also met with representatives from airport
and general aviation organizations and NATCA.
13
Exhibit B. Organizations Visited or Contacted
EXHIBIT B. ORGANIZATIONS VISITED OR CONTACTED
FAA Headquarters, Washington, DC
Air Traffic Organization
• Contract Tower and Weather Group (CTWG)
• Mission Support
• Strategic Planning and Performance Group
• Office of Safety
Office of Financial Services
• ATO Finance
• Office of Budget
• Office of Acquisition and Business
Policy, International Affairs and Environment
• Office of Aviation Policy and Plans
FAA Field Locations
• Office of Safety, Quality Assurance Group and Quality Control Group, Fort
Worth, Texas
FAA Air Traffic Control Towers
• Addison Tower, Addison, Texas
• Fort Lauderdale Executive Tower, Fort Lauderdale, Florida
• Hillsboro Tower, Hillsboro, Oregon
• Meacham Tower, Fort Worth, Texas
• Palomar Tower, Carlsbad, California
• Santa Monica Tower, Santa Monica, California
• Vero Beach Tower, Vero Beach, Florida
14
Exhibit B. Organizations Visited or Contacted
Federal Contract Towers
• Albert Whitted Tower, St. Petersburg, Florida
• Danbury Tower, Danbury, Connecticut
• Gainesville Tower, Gainesville, Florida
• Georgetown Tower, Georgetown, Texas
• Goodyear Tower, Phoenix, Arizona
• Jefferson Tower, Jefferson City, Missouri
• Joplin Tower, Webb City, Missouri
• Oxford Tower, Oxford, Connecticut
• Ryan Field Tower, Tucson, Arizona
• Salem-McNary Field Tower, Salem, Oregon
• Southwest Oregon Regional North Bend Tower, North Bend, Oregon
• Sugar Land Tower, Sugar Land, Texas
FCT Program Contractors
• Midwest Air Traffic Control Service, Inc.
• Robinson Aviation (RVA), Inc.
• Serco, Inc.
Industry Groups
• National Air Traffic Controllers Association (NATCA)
• Aircraft Owners and Pilots Association (AOPA)
• American Association of Airport Executives (AAAE)
•
National Business Aviation Association (NBAA)
15
Exhibit C. List of Contract Towers (as of May 2012)
EXHIBIT C. LIST OF CONTRACT TOWERS (AS OF MAY 2012)
State Airport Name
Tower
ID
State Airport Name
Tower
ID
AK Bethel BET CT Tweed-New Haven HVN
AK Kenai ENA CT Waterbury OXC
AK
King Salmon
AKN
FL
Albert Whitted
SPG
AK
Kodiak
ADQ
FL
Boca Raton
BCT
AL Brookley BFM FL Cecil Field VQQ
AL Dothan DHN FL Charlotte County Airport PGD
AL
Tuscaloosa Municipal
TCL
FL
Flagler County Airport
XFL
AR
Fayetteville
FYV
FL
Gainesville
GNV
AR Northwest Arkansas Regional XNA FL Hollywood/North Perry HWO
AR Rogers Municipal-Carter Fld (CS) ROG FL Jacksonville/Craig CRG
AR
Springdale Municipal (CS)
ASG
FL
Key West
EYW
AR
Texarkana Muni/Webb Fld
TXK
FL
Kissimmee Municipal
ISM
AZ Chandler CHD FL Lakeland Municipal LAL
AZ Flagstaff Pulliam FLG FL Leesburg Regional LEE
AZ
Glendale
GEU
FL
Melbourne
MLB
AZ
Goodyear
GYR
FL
Naples
APF
AZ Laughlin International IFP FL New Smyrna Beach Municipal Arpt EVB
AZ Ryan Field RYN FL Ocala Airport OCF
AZ
Williams Gateway
IWA
FL
Opa Locka
OPF
CA
Castle
MER
FL
Ormond Beach Municipal
OMN
CA Chico Municipal CIC FL Page Field FMY
CA Fullerton FUL FL Panama City/Bay County ECP
CA
Hawthorne
HHR
FL
Pompano Beach
PMP
CA
Mather
MHR
FL
St Augustine
SGJ
CA Modesto MOD FL Stuart/Whitham SUA
CA Oxnard OXR FL Titusville/Cocoa TIX
CA
Palmdale
PMD
GA
Anthens Municipal
AHN
CA
Ramona
RNM
GA
Fulton County
FTY
CA Redding RDD GA Gwinnett County LZU
CA Riverside RAL GA Macon MCN
CA
Sacramento Executive
SAC
GA
Mc Collum
RYY
CA
Salinas Municipal
SNS
GA
SW Georgia/Albany-Dougherty
ABY
CA San Carlos SQL GU Agana, Guam GUM
CA San Diego Brown Field SDM HI Kalaeloa (John Rogers Field) (ANG) JRF
CA
San Luis Obispo
SBP
HI
Keahole-Kona
KOA
CA
Santa Maria
SMX
HI
Lihue
LIH
CA Victorville VCV HI Molokai MKK
CA Whiteman WHP IA Dubuque DBQ
CA
William J. Fox/Lancaster
WJF
ID
Friedman Memorial/Hailey
SUN
CO
Eagle County
EGE
ID
Idaho Falls
IDA
CO Front Range FTG ID Lewiston-Nez Perce County LWS
CO Grand Junction GJT ID Pocatello Municipal PIH
CT
Bridgeport
BDR
IL
Bloomington/Normal
BMI
CT
Danbury Municipal
DXR
IL
Decatur
DEC
CT Groton- New London GON IL So. Illinois/Carbondale MDH
CT Hartford-Brainard HFD IL St. Louis Regional ALN
16
Exhibit C. List of Contract Towers (as of May 2012)
State Airport Name
Tower
ID
State Airport Name
Tower
ID
IL
Waukegan Regional
UGN
MS
Hawkins Field
HKS
IL
Williamson County (CS)
MWA
MS
Meridian/Key Field (ANG)
MEI
IN Monroe County/ Bloomington (CS) BMG MS Olive Branch OLV
IN Columbus Municipal BAK MS Stennis HSA
IN
Gary Regional
GYY
MS
Tupelo Regional
TUP
IN
Muncie/Delaware County (CS)
MIE
MT
Gallatin Field/Bozeman
BZN
KS Forbes Field FOE MT Kalispell/Glacier Park GPI
KS Garden City Regional Airport (CS) GCK MT Missoula MSO
KS
Hutchinson Municipal
HUT
NC
Concord
JQF
KS
Johnson County Executive
OJC
NC
Hickory
HKY
KS Manhattan Regional MHK NC Kinston ISO
KS New Century IXD NC New Bern EWN
KS
Philip Billard Municipal
TOP
NC
Smith Reynolds (Winston Salem)
INT
KS
Salina Municipal
SLN
ND
Minot
MOT
KY Barkley Regional PAH NE Central Nebraska/Grd Island (CS) GRI
KY Owensboro/Daviess County OWB NH Boire Field/Nashua ASH
LA
Acadiana Regional
ARA
NH
Lebanon Municipal
LEB
LA
Alexandria International (ANG)
AEX
NJ
Trenton
TTN
LA Chennault CWF NM Double Eagle II AEG
LA Houma Terreborne HUM NM Farmington Municipal FMN
LA
Shreveport-DT
DTN
NM
Lea County/Hobbs (CS)
HOB
MA
Barnes Municipal
BAF
NM
Santa Fe County Municipal
SAF
MA Beverly BVY NV Henderson HND
MA Hyannis HYA NY Francis F. Gabreski FOK
MA
Lawrence
LWM
NY
Niagara Falls
IAG
MA
Martha's Vineyard
MVY
NY
Rome-Griffiss
RME
MA New Bedford EWB NY Stewart SWF
MA Norwood OWD NY Tompkins County ITH
MA
Worcester
ORH
OH
Burke Lakefront
BKL
MD
Easton
ESN
OH
Cincinnati Muni/Lunken
LUK
MD Frederick FDK OH Columbus Airport (Bolton Field) TZR
MD Martin State MTN OH Cuyahoga County CGF
MD
Salisbury-Wicomico County
SBY
OH
Ohio State University
OSU
MD
Washington Co. Reg'l/ Hagerstown
HGR
OK
Ardmore Municipal (CS)
ADM
MI Battle Creek BTL OK Enid Woodring Muni WDG
MI Detroit City DET OK Lawton Municipal LAW
MI
Jackson (CS)
JXN
OK
Stillwater
SWO
MI
Sawyer Gwinn
SAW
OK
Univ of Oklahoma/Westheimer
OUN
MN Anoka ANE OK Wiley Post PWA
MN St. Cloud Regional STC OR Klamath Falls (ANG) LMT
MO
Branson Airport
BBG
OR
McNary Field
SLE
MO
Columbia
COU
OR
Medford
MFR
MO Jefferson City Memorial (CS) JEF OR Pendleton Municipal PDT
MO Joplin Regional (CS) JLN OR Redmond RDM
MO
Rosecrans Mem'l/St. Joseph (ANG)
STJ
OR
Southwest Oregon Regional
OTH
MP
Saipan International
GSN
OR
Troutdale
TTD
MS Golden Triangle Regional Airport GTR PA Arnold Palmer Regional LBE
MS Greenville Municipal GLH PA Capital City CXY
17
Exhibit C. List of Contract Towers (as of May 2012)
State Airport Name
Tower
ID
State Airport Name
Tower
ID
PA
Lancaster
LNS
TX
Sugarland
SGR
PA
University Park
UNV
TX
Tyler
TYR
PA Williamsport/Lycoming Co. (CS) IPT TX Victoria VCT
PR Isla Grande SIG TX Waco CNW
PR
Rafael Hernandez (Aquadilla)
BQN
UT
Ogden-Hinckley Municipal
OGD
SC
Donaldson Center
GYH
UT
Provo Municipal
PVU
SC Grand Strand/Myrtle Beach CRE VA Charlottesville-Albemarle CHO
SC Greenville Downtown GMU VA Lynchburg LYH
SC
Hilton Head Airport
HXD
VI
Henry E. Rohlsen Airport
STX
SD
Rapid City Regional
RAP
WA
Bellingham Intl
BLI
TN McKeller-Sipes MKL WA Felts Field SFF
TN Millington NQA WA Olympia OLM
TN
Smyrna
MQY
WA
Renton
RNT
TX
Arlington Municipal
GKY
WA
Tacoma Narrows
TIW
TX Brownsville Intl BRO WA Walla Walla Regional (CS) ALW
TX Denton Municipal DTO
WA Yakima YKM
TX
Easterwood
CLL
WI
Appleton
ATW
TX
Fort Worth-Spinks (CS)
FWS
WI
Central Wisconsin
CWA
TX Georgetown GTU WI Chippewa Valley (Eau Claire) EAU
TX Grand Prairie (CS) GPM WI Kenosha Muni ENW
TX
Laredo Int'l
LRD
WI
La Crosse
LSE
TX
Lonestar Executive Airport
CXO
WI
Rock County
JVL
TX McAllen MFE WI Timmerman MWC
TX McKinney Municipal TKI WI Waukesha County UES
TX
New Braunfels Municipal
BAZ
WI
Wittman Regional
OSH
TX
Redbird
RBD
WV
Greenbrier Valley
LWB
TX Rio Grand Valley (Harlingen) HRL WV Morgantown MGW
TX San Angelo/Mathis Field SJT WV Parkersburg/Wood County PKB
TX
San Marcos
HYI
WV
Wheeling Ohio County
HLG
TX
(Galveston) Scholes Int'l
GLS
WY
Cheyenne (ANG)
CYS
TX Stinson Municipal SSF WY Jackson Hole JAC
ANG: Air National Guard Tower; CS: Cost-Share Tower
Source: FAA
18
Exhibit D. List of 92 Comparable FAA Towers
EXHIBIT D. LIST OF 92 COMPARABLE FAA TOWERS
State Tower Name
Tower
ID
State Tower Name
Tower
ID
AK
Juneau Tower
JNU
IL
Aurora Tower
ARR
AK Merrill Tower MRI IL Chicago Executive Tower PWK
AZ
Falcon Tower
FFZ
IL
Downtown Tower
CPS
AZ
Grand Canyon Tower
GCN
IL
Dupage Tower
DPA
AZ Prescott Tower PRC IN Lafayette Tower LAF
AZ
Scottsdale Tower
SDL
KY
Bowman Tower
LOU
CA Brackett Tower POC LA Lakefront Tower NEW
CA
Burbank Tower
BUR
MA
Hanscom Tower
BED
CA
Camarillo Tower
CMA
MA
Nantucket Tower
ACK
CA Chino Tower CNO MD Andrews Tower ADW
CA
Concord Tower
CCR
MI
Ann Arbor Tower
ARB
CA El Monte Tower EMT MI Pontiac Tower PTK
CA
Gillespie Tower
SEE
MI
Traverse City Tower
TVC
CA Hayward Tower HWD MI Willow Run Tower YIP
CA
Livermore Tower
LVK
MN
Crystal Tower
MIC
CA
Monterey Tower
MRY
MN
Flying Cloud Tower
FCM
CA Montgomery Tower MYF MN St Paul Tower STP
CA
Napa Tower
APC
MO
Downtown Tower
MKC
CA
Ontario Tower
ONT
MO
Helena Tower
HLN
CA
Palm Springs Tower
PSP
MO
Spirit Tower
SUS
CA
Palo Alto Tower
PAO
ND
Grand Forks Tower
GFK
CA Palomar Tower CRQ NE Eppley Tower OMA
CA
Reid-Hillview Tower
RHV
NE
Lincoln Tower
LNK
CA
Sacramento Tower
SMF
NH
Manchester Tower
MHT
CA
San Diego Tower
SAN
NJ
Caldwell Tower
CDW
CA
San Jose Tower
SJC
NJ
Morristown Tower
MMU
CA Santa Monica Tower SMO NJ Teterboro Tower TEB
CA
Sonoma Tower
STS
NV
North Las Vegas Tower
VGT
CA Stockton Tower SCK NY Farmingdale Tower FRG
CA
Torrance Tower
TOA
NY
Islip Tower
ISP
CO
Broomfield Tower
BJC
NY
Poughkeepsie Tower
POU
CO Pueblo Tower PUB NY Westchester Tower HPN
CT
Bradley Tower
BDL
OR
Hillsboro Tower
HIO
DE
Wilmington Tower
ILG
PA
Allegheny Tower
AGC
FL
Fort Lauderdale Executive Tower
FXE
PA
Northeast Philadelphia Tower
PNE
FL
Orlando Executive Tower
ORL
PR
San Juan Tower
SJU
FL Pensacola Tower PNS TX Addison Tower ADS
FL
Sarasota Tower
SRQ
TX
Alliance Tower
AFW
FL
St Lucie Tower
FPR
TX
Beaumont Tower
BPT
FL
St Petersburg Tower
PIE
TX
Hooks Tower
DWH
FL
Tamiami Tower
TMB
TX
Meacham Tower
FTW
FL Vero Beach Tower VRB VA Manassas Tower HEF
GA
Columbus Tower
CSG
VA
Patrick Henry Tower
PHF
GA DeKalb - Peachtree Tower PDK VA Richmond Tower RIC
HI
Maui Tower
OGG
VI
St Thomas Tower
STT
ID
Twin Falls Tower
TWF
WA
Paine Tower
PAE
Source: This list was provided by FAA for comparison purposes only. Currently FAA has no plans to expand the Contract
Tower Program to additional FAA-operated towers.
19
Exhibit E. FY 2010 Cost Comparison for FAA and Contract Towers
EXHIBIT E. FY 2010 COST COMPARISON FOR FAA AND CONTRACT TOWERS
FAA Towers
Contract Towers
Tower ID Name State
Avg.
Density
FY 2010 Cost
Tower ID Name State
Avg.
Density
FY 2010 Cost
TMB
Tamiami Tower
FL
37.3
CHD
Chandler Tower
AZ
36.6
$770,060.00
PAO
Palo Alto Tower
CA
33.1
OMN
Ormond Beach Tower
FL
33.4
$526,587.00
BED
Hanscom Tower
MA
32.4
GYR
Goodyear Tower
AZ
32.2
$650,900.00
MMU
Morristown Tower
NJ
25.6
TIX
Space Coast Tower
FL
25.6
$603,320.00
SJU
San Juan Tower
PR
22.1
SDM
Brown Field Tower
CA
22.0
$540,668.00
GCN
Grand Canyon Tower
AZ
20.7
CRG
Craig Tower
FL
20.5
$639,004.00
ADS
Addison Tower
TX
20.2
GEU
Glendale Tower
AZ
20.5
$557,436.00
PHF Patrick Henry Tower VA 19.8 $2,622,386.80 HUM Houma Tower LA 19.8 $428,950.00
TEB Teterboro Tower NJ 17.5 $3,592,653.65 RNT Renton Tower WA 17.7 $497,428.00
SRQ
Sarasota Tower
FL
17.3
APF
Naples Tower
FL
17.5
$730,984.00
CCR
Concord Tower
CA
16.1
TKI
McKinney Tower
TX
16.4
$548,767.00
CDW
Caldwell Tower
NJ
16.0
RBD
Executive Tower
TX
16.2
$591,452.00
SUS
Spirit Tower
MO
15.4
FUL
Fullerton Tower
CA
15.0
$517,224.00
NEW
Lakefront Tower
LA
14.5
FTY
Fulton County Tower
GA
14.5
$654,568.00
PNE
NE Philadelphia Tower
PA
13.4
LEE
Leesburg Tower
FL
13.4
$433,445.00
ONT
Ontario Tower
CA
13.2
MER
Castle Tower
CA
13.3
$504,864.00
OMA
Eppley Tower
NE
12.9
HFD
Hartford Tower
CT
13.1
$641,336.00
MRY
Monterey Tower
CA
12.4
TTD
Troutdale Tower
OR
12.5
$489,708.00
ILG
Wilmington Tower
DE
12.3
EWB
New Bedford Tower
MA
12.2
$545,924.00
SCK
Stockton Tower
CA
11.6
GMU
Greenville Tower
SC
11.5
$510,062.00
DPA DuPage Tower IL 10.8 $2,003,308.79 HHR Hawthorne Tower CA 10.8 $514,884.00
LNK Lincoln Tower NE 9.7 $2,237,513.66 MVY Martha’s Vineyard Tower MA 9.8 $530,100.00
MKC
Downtown Tower
MO
9.6
SWF
Stewart Tower
NY
8.8
$665,812.00
AGC
Allegheny Tower
PA
8.7
ALN
Regional Tower
IL
8.7
$432,256.00
MHT
Manchester Tower
NH
8.5
DEC
Decatur Tower
IL
8.2
$463,828.00
CSG
Columbus Tower
GA
8.1
HRL
Harlingen Tower
TX
7.6
$546,735.00
YIP
Willow Run Tower
MI
8.0
FLG
Flagstaff Tower
AZ
7.4
$466,112.00
HLN
Helena Tower
MT
7.6
IFP
Laughlin Tower
AZ
5.9
$378,188.00
TWF
Twin Falls Tower
ID
6.5
TXK
Texarkana Tower
AR
5.1
$397,385.00
BPT
Beaumont Tower
TX
5.1
ADM
Ardmore Tower
OK
4.3
$329,346.00
Total FY 2010 Costs For 30 Selected FAA Towers
Total FY 2010 Costs For 30 Selected Contract Towers
$16,107,333.00
Average FY 2010 Cost Per Selected FAA Tower
Average FY 2010 Cost Per Selected Contract Tower
$536,911.00
Difference in FY 2010 Average Cost Per Tower = $1,488,193.07
Source: OIG based on FAA Data
20
Exhibit F. End of FY 2010 Staffing Levels for Select FAA and Contract Towers
EXHIBIT F. END OF FY 2010 STAFFING LEVELS FOR SELECT FAA AND CONTRACT TOWERS*
FAA Towers
Contract Towers
Tower ID Name State
Avg.
Density
Personnel
Tower ID Name State
Avg.
Density
Number of ATC
Personnel
TMB
Tamiami Tower
FL
37.3
CHD
Chandler Tower
AZ
36.6
8
PAO Palo Alto Tower CA 33.1 14 OMN Ormond Beach Tower FL 33.4 6
BED
Hanscom Tower
MA
32.4
GYR
Goodyear Tower
AZ
32.2
6
MMU
Morristown Tower
NJ
25.6
TIX
Space Coast Tower
FL
25.6
8
SJU
San Juan Tower
PR
22.1
SDM
Brown Field Tower
CA
22.0
5
GCN Grand Canyon Tower AZ 20.7 11 CRG Craig Tower FL 20.5 7
ADS Addison Tower TX 20.2 18 GEU Glendale Tower AZ 20.5 6
PHF Patrick Henry Tower VA 19.8 20 HUM Houma Tower LA 19.8 5
TEB
Teterboro Tower
NJ
17.5
RNT
Renton Tower
WA
17.7
4
SRQ
Sarasota Tower
FL
17.3
APF
Naples Tower
FL
17.5
8
CCR
Concord Tower
CA
16.1
TKI
McKinney Tower
TX
16.4
6
CDW
Caldwell Tower
NJ
16.0
RBD
Executive Tower
TX
16.2
8
SUS
Spirit of St. Louis Tower
MO
15.4
FUL
Fullerton Tower
CA
15.0
5
NEW
Lakefront Tower
LA
14.5
FTY
Fulton County Tower
GA
14.5
10
PNE
NE Philadelphia Tower
PA
13.4
LEE
Leesburg Tower
FL
13.4
6
ONT
Ontario Tower
CA
13.2
MER
Castle Tower
CA
13.3
5
OMA
Eppley Tower
NE
12.9
HFD
Hartford Tower
CT
13.1
7
MRY
Monterey Tower
CA
12.4
TTD
Troutdale Tower
OR
12.5
5
ILG Wilmington Tower DE 12.3 16 EWB New Bedford Tower MA 12.2 6
SCK Stockton Tower CA 11.6 12 GMU Greenville Tower SC 11.5 6
DPA DuPage Tower IL 10.8 17 HHR Hawthorne Tower CA 10.8 5
LNK
Lincoln Tower
NE
9.7
MVY
Martha’s Vineyard Tower
MA
9.8
6
MKC
Downtown Tower
MO
9.6
SWF
Stewart Tower
NY
8.8
9
AGC
Allegheny Tower
PA
8.7
ALN
Regional Tower
IL
8.7
5
MHT
Manchester Tower
NH
8.5
DEC
Decatur Tower
IL
8.2
5
CSG
Columbus Tower
GA
8.1
HRL
Harlingen Tower
TX
7.6
6
YIP
Willow Run Tower
MI
8.0
FLG
Flagstaff Tower
AZ
7.4
5
HLN
Helena Tower
MT
7.6
IFP
Laughlin Tower
AZ
5.9
3
TWF
Twin Falls Tower
ID
6.5
TXK
Texarkana Tower
AR
5.1
5
BPT
Beaumont Tower
TX
5.1
ADM
Ardmore Tower
OK
4.3
5
Average Number of ATC Personnel at
30 Selected FAA Towers
16.23
Average Number of ATC Personnel at
30 Selected Contract Towers
6.03
∗ ATC Personnel includes air traffic controllers, supervisors, and management.
Source: FAA
21
Exhibit G. Major Contributors to This Report
EXHIBIT G. MAJOR CONTRIBUTORS TO THIS REPORT
Name Title__________
Robert Romich Program Director
Frank Danielski Project Manager
Natasha Thomas Senior Analyst
My Phuong Le Analyst
Aaron Rodgers Analyst
Mi Hwa Button Analyst
Petra Swartzlander Statistician
Megha Joshipura Statistician
Audre Azuolas Writer/Editor
APPENDIX. AGENCY COMMENTS 22
Appendix. Agency Comments
Federal Aviation
Administration
Memorandum
Date: October 10, 2012
To: Jeffrey B. Guzzetti, Director, Assistant
Inspector
General for Aviation and Special
Program
Audits
From: H. Clayton Foushee, Director, Office of Audit and Evaluation, AAE-1
Subject: Contract Tower Program Audit
The Federal Aviation Administration (FAA) Contract Tower Program has provided safe, cost
effective air traffic control services at low activity airports for over 30 years. The program has
provided an increased level of safety at many airports that otherwise would not have received
these services. The Department of Transportation (DOT), Office of Inspector General (OIG) has
conducted several audits of various aspects of the program. Overall, they have found that
contract towers provide services and outcomes comparable to those provided at FAA-staffed
towers. This draft report continues to validate the previous OIG report findings of cost
effectiveness, safety, and overall user satisfaction with the Federal Contract Tower (FCT)
program. The FAA is pleased the Contract Tower Program is often referred to as one of the
most efficient government programs and a model for government and industry partnerships and
will continue to provide the programmatic oversight necessary to ensure the program’s safety
efficacy and cost effectiveness.
RECOMMENDATIONS AND RESPONSES
Recommendation 1: Develop a process to validate invoices and timecards submitted by FCT
contractors annually to (a) ensure that hours billed are actually worked and met contract
requirements, and (b) recover any overpayments made to the contractor.
FAA Response 1(a): Concur. The current contract language requires the vendor to include and
submit invoices that reflect the hours worked and paid. The contract allows for a lapse of no
more than 60 calendar days between serviced performed and the submission of an invoice.
The FCT Program Office utilizes a monthly tracking sheet, which consists of cost breakdown by
each control tower. Upon receipt of the invoices, the FCT Program Office validates the air
traffic controller costs and checks for discrepancies against the monthly tracking sheet. The FCT
Program Office then compares the actual hours worked with the hours that were approved on the
base-lined contract. The Contracting Officer (CO) will notify the vendor of any discrepancies,
and identify adjustments needed in a resubmitted invoice.
23
Appendix. Agency Comments
The FCT Program Office will improve upon this process by coordinating with the CO to ensure
that the vendors are in compliance with the contract requirements. Currently, the vendors submit
invoices and actual hours worked in separate reports. The CO will notify the vendors that they
must submit actual hours worked in conjunction with the invoices effective October 2012.
The FCT Program Office will further strengthen its internal controls by developing a timecard
audit process to validate the FCT controller’s timecards. The timecard audit process will entail
conducting annual on-site inspections. The vendor will be required to provide a selected number
of air traffic controllers’ timecards. The FCT Program Office will validate the timecards against
the actual hours billed on the vendors’ invoices. The CO will notify the vendor of any
discrepancies. The timecard audit process will be implemented by January 1, 2013.
FAA Response 1 (b): Concur. The contract currently has language for the FAA to recover
overpayments made to contractors. The CO will notify the vendor if the performance levels are
not within the performance range of 97 to 103 percent. If the performance level is below
97 percent, overpayment will be recovered.
The FCT Program Office will improve upon this process by conducting quarterly reviews of the
vendors’ monthly staffing reports for actual hours worked. The staffing reports are then
compared to the hours that were approved on the base-lined contract. The reports are used to
calculate the performance percentage. The quarterly review allows the FCT Program Office to
proactively detect and notify the vendor of low performance levels that could result in the
recovery of overpayment at the end of the year. The quarterly verification of hours will be
implemented by January 1, 2013.
Recommendation 2: Modify FCT contracts to incorporate a voluntary reporting system, such
as ATSAP, at contract towers to ensure more comprehensive reporting of safety incidents.
FAA Response: Concur. The FAA modified all seven FCT contracts in September of 2011.
This requires each vendor to implement a voluntary reporting program. The requirements
identified in the contract mod are currently being implemented by the vendors. The FCT
Program Office and vendors expect the contractual requirements to be fully implemented by
December 31, 2012.
Recommendation 3: Implement a policy that will ensure its risk-based facility oversight
system allows for regular assessments of contract towers, as prescribed by Congress.
FAA Response: Concur. On January 30, 2012, the Air Traffic Organization (ATO) issued
safety orders FAA JO 7210.632, Air Traffic Organization Occurrence Reporting, FAA JO
7210.633, Air Traffic Organization Quality Assurance Program, and FAA JO 7210.634, Air
Traffic Organization (ATO) Quality Control. These orders provide enhanced processes for
collecting safety-related data, analyzing/identifying suspected risk trends, and assessing the
effectiveness of risk mitigations. All FAA facilities and FCTs are required to adhere to all
requirements contained in these orders. In accordance with these orders and the requirement to
conduct safety assessments, ATO Safety and Technical Training (AJI) will establish and
implement an Audits and Assessments Program. The AJI Audits and Assessments Program will
24
Appendix. Agency Comments
consist of standardized processes and procedures that will be used to conduct ATO assessments.
These standards, procedures, and checklists are scheduled for completion by December 1, 2012.
AJI will determine when to conduct these audits or assessments based on data analyses of
Mandatory Occurrence Reports, Electronic Occurrence Reports, and Voluntary Safety Reports
that identify potential risk within specific Facility, District, Service Area, or National Airspace
System wide. The AJI Audits and Assessments Program may be conducted through various
methods that may include: a review of available data from the Comprehensive Electronic Data
Analysis and Reporting tool, quality control and quality assurance data, Risk Analysis Event
analyses, information from Air Traffic Safety Action Program, direct observations, interviews
with personnel, developing a custom checklist, and other means as appropriate.
Within FAA JO 7210.634, there is a requirement that Field Assessments, referred to as
Compliance Verifications (CV), be conducted. CVs are a means of assessing Air Traffic
Facilities performance and identifying areas for improvement. There are two types of CVs that
can be conducted, Internal Compliance Verification (ICV) and External Compliance Verification
(ECV). ICVs are planned assessments accomplished through the use of a formal checklist and
random sampling methods such as, but not limited to, direct operational observation, discussions
with Service Delivery Point personnel, review of voice or radar data, equipment parameters,
certification parameters, and examination of other documentation. ECVs are assessments of
facilities that are conducted on an as needed basis as determined by the service unit, director of
operations, and/or the Quality Control Group (with the concurrence of the director of
operations). Determinations to conduct ECVs will be based upon data analyses of Mandatory
Occurrence Reports, Electronic Occurrence Reports, and Voluntary Safety Reports which
identifies potential risk within a specific facility. ECVs may be conducted through various
methods that may include: a review of available data; direct observation; interviews with
personnel; developing a custom checklist; and other means, as appropriate. All FAA and FCTs
must conduct a regularly scheduled ICV each Fiscal Year and report their findings.
Additionally, to support oversight efforts, all radar, voice, and other supporting data used to
conduct these assessments must be retained for 12 months following the date of the review.
Information related to the CV process (checklists, reports, facility information, tracking
information, mitigation plans, etc.) are stored in the Compliance Verification Tool (CVT), a
national database developed by AJI. The data in the CVT database supports the analysis of
system trends, the identification of suspected risk trends, and the development of requirements
for safety assessments.
The Audits and Assessment Group will begin their assessments once the standards, procedures,
and checklists are finalized in December 2012. The group will conduct a planned number of
assessments each year that will be determined by data-driven needs and available resources.
They will use the established assessment process and requirements checklists (developed based
on suspected risk trends and other data stored in the CVT) to assess compliance, facility
performance, and the effectiveness of operations in accordance with the ATO safety orders.