9/11/18

 

8900.1 CHG 616

VOLUME 7  INVESTIGATION

CHAPTER 5  CONDUCT A COMPLAINT INVESTIGATION

Section 1  Background and Procedure

7-131    PROGRAM TRACKING AND REPORTING SUBSYSTEM (PTRS) ACTIVITY CODES.

A.    Resolved as a Complaint:

    Operations: 1737.

    Maintenance: 3740.

    Avionics: 5740.

    Cabin Safety: 8737.

B.    Other:

    Operations: 1771.

    Maintenance: 3766.

    Avionics: 5766.

    Cabin Safety: 8771.

7-132    OBJECTIVE. The objective of this task is to determine, through investigation, analysis, and assessment, the appropriate resolution of a received complaint. Successful completion of this task may result in several different outcomes based on the nature of the complaint and its resolution.

7-133    GENERAL.

A.    Authority. Part A of Subtitle VII of Title 49 of the United States Code (49 U.S.C.) authorizes the Administrator to prescribe rules, regulations, orders and minimum standards in the public interest. Title 49 U.S.C. §§ 40113, 44709, and 46101 authorize the Administrator to conduct investigations.

B.    Inspector Responsibilities. The inspector must determine whether to resolve the complaint quickly and reassuringly over the telephone or whether it requires further action.

1)    When a complaint is resolved quickly by explanation, the complaint is closed with a record in PTRS describing the occurrence.
2)    Sometimes there is a limited amount of evidence but not enough to support further action. In that case, the inspector may leave the complaint open until enough information is available to pursue an investigation, or the inspector may close the complaint with a record that insufficient evidence is available to pursue an investigation.
3)    In many cases, the complaint must be referred to another Federal Aviation Administration (FAA) office or the agency responsible for handling that type of complaint.
4)    An inspector must document any complaint, including action taken to address and/or close the complaint.
5)    In addition to obtaining a complete statement from the complainant, the inspector may need to conduct additional activity in order to adequately investigate, analyze, and assess the complaint.
Indicates new/changed information.

C.    Determination of FAA Responsibility. Areas of responsibility are determined by using the following criteria:

1)    The performance of FAA facilities or functions;
2)    The performance of non-FAA-owned and operated air traffic control (ATC) facilities or Navigational Aids (NAVAID);
3)    The airworthiness of FAA-certified aircraft;
4)    The competency of FAA-certified airmen, air agencies, commercial operators, or air carriers;
5)    The adequacy of the Code of Federal Regulations (CFR);
6)    The airport certification safety standards or operations involved;
7)    The airport security standards or operations involved (however, note that aviation security is now under the direction and control of the Transportation Safety Administration (TSA) and therefore Flight Standards Service personnel observing or being notified of a possible security incident should report the occurrence to the local TSA office);
8)    The airman medical qualifications involved; and/or
9)    Whether there was an apparent violation of Title 14 of the Code of Federal Regulations (14 CFR).

7-134    ACTIVE LISTENING. Effective or active listening is a skill that comes from practice and from a genuine desire to know what the other person means. An inspector may receive complaints from many sources, and the inspector’s response will vary, depending on the source and the nature of the complaint. Inspectors receive most complaints over the telephone, usually from a member of the public who may be irate, upset, and/or concerned. In addition, the person likely will not be familiar with the FAA organization or areas of responsibility, and thus may have contacted the office erroneously. The inspector must remember that, no matter how agitated the complainant may be, the matter must not be taken personally.

A.    Inspector’s Role in Active Listening. The inspector who initially receives a complaint, whether by telephone or by personal contact, represents the Agency in a “frontline position.” Whatever the circumstances of the contact or nature of the complaint, the inspector should assume an attitude of quiet, active listening and helpfulness. The inspector’s demeanor should be calm, restrained, and respectful. Table 14-2-1A, Tips for Active Listening (Volume 14, Chapter 2, Section 1), contains some listening tips that are good to remember when handling complainants by telephone or in person.

B.    Handling Referrals. If it seems immediately clear that the nature of the problem is not within the scope of the district office or even of the FAA, the inspector should allow the contact to finish talking, and then repeat the witness’ description of the event. This brief reiteration of the complaint sends a signal to the complainant that the complaint was heard, understood, and considered. Then the inspector may proceed to explain that the complaint should be referred to another office or agency.

C.    Followup. The inspector should follow up on any complaint by giving the complainant the name of the appropriate office and, if possible, the contact information for that office. In some instances, the inspector may wish to make the initial contact for the complainant. If the inspector is not certain whom the source should contact or whether the complaint should be handled in the district office, it is acceptable to acknowledge that fact. The inspector should obtain the complainant’s name and contact information, and the inspector should indicate that they will contact the complainant as soon as possible. Then the inspector should consult the unit supervisor, or, if necessary, the region, or conduct independent research before contacting the complainant with the appropriate information.

7-135    KINDS OF COMPLAINTS.

A.    Complaints Within the Field Office Area of Responsibility (AOR). Certain complaints can and should be investigated at the local field office level (e.g., Flight Standards District Office (FSDO), certificate management office (CMO), or International Field Office (IFO)). This would include complaints against certificated aircraft, airmen, repair stations, air agencies, and air operators within the geographic limits of the district office.

B.    Complaints About FAA Personnel. The inspector will forward all complaints that involve actions or behavior of FAA personnel, regardless of AOR, to their supervisor.

C.    Complaints Outside FAA Responsibility. FAA inspectors deal only with issues within the FAA’s statutory and regulatory authority. If an inspector receives a complaint that does not involve FAA responsibilities (see subparagraph 7-133C), that complaint must be referred to the appropriate agency (local, state, or Federal).

1)    Environmental Concerns. This involves complaints about noise or environmental problems, such as aircraft noise, pollution, or proximity of airport to persons. Other environmental concerns, such as agricultural chemicals sprayed by 14 CFR part 137 operators, may be the concern of other agencies such as the Environmental Protection Agency (EPA), when no aviation safety issues are involved. Safety complaints about part 137 operators fall under subparagraph A.
2)    FAA-Certificated Operators. The inspector will refer consumer complaints (e.g., lost luggage, late departures or arrivals) about FAA-certificated operators (such as commercial airlines) to the operator of the air carrier. If unsatisfied, the inspector can encourage the complainant to call the Aviation Consumer Protection Division of the U.S. Department of Transportation (DOT) at 202-366-2220. The website for this division is https://www.transportation.gov/airconsumer.
3)    Equipment Failure. This category of complaints involves flight procedures, faulty NAVAIDs, or air traffic procedures. This type of complaint generally comes from pilots rather than the general public, and the inspector should refer them to the local ATC facility that has jurisdiction over the procedure or NAVAID. The local ATC facility will be able to report the problem to the Air Traffic Organization (ATO) Technical Operations or other appropriate organization.
4)    Hazardous Airport Conditions. This type of complaint may come from the public or from pilots, and may involve the physical condition or layout of an airport or hazards posed by construction. Inspectors should refer these complaints to the airports division in the region.
5)    Security. Security complaints may encompass concerns ranging from those who believe security is inadequate to those who believe they have been treated unfairly by security screening personnel. Inspectors should refer these complaints to the appropriate agency, such as the TSA.
6)    Unmanned Aircraft Systems (UAS). Complaints may involve those who witness or have information about a safety-related information UAS occurrence. These types of complaints are processed per the guidance provided in this section. Also, see additional information specific to UAS surveillance in Volume 16, Chapter 5.
7)    Military Complaints. Complaints involving military airports or military personnel usually involve low flying, and often come from people who live close to military bases, Military Operations Areas (MOA), or restricted areas. See Volume 7, Chapter 1, Section 2.
8)    Alleged Criminal Activity. Complaints of this nature can also be very diverse. The inspector does not become involved unless aviation safety is also an issue. Refer these to the appropriate law enforcement agency, local or Federal.

7-136    COMPLAINTS.

A.    Complaint Submission. It is FAA policy to respond to all complaints that come to the attention of the Flight Standards Service, whether by mail, email, phone, or in person.

1)    Individuals who complain via telephone should be encouraged to submit their specific complaint(s) in writing.
2)    Individuals may be encouraged to contact the FAA Hotline. The complainant may be provided with the following information:
a)    Information received by the FAA Hotline includes issues involving aviation safety, violations of FAA regulations or policy, concerns involving FAA employees or facilities, maintenance issues, aircraft incidents, and/or aircraft accidents.
b)    The FAA Hotline may be contacted through the following methods:

    By telephone at 1-800-255-1111, 1-800-322-7873, or 1-866-835-5322;

    Online at https://hotline.faa.gov/; or

    By email through FAAHotline@faa.gov.

c)    The hours of operation for the FAA Hotline Program are 0800 to 1600 Eastern Time, Monday through Friday, except on Federal holidays. After 1600 Eastern Time, if a reporting individual believes their safety issue is time critical and should not wait until the next business day to be addressed, he or she may select an option that transfers the call to the Washington Operations Center (WOC), which will forward the call to the Air Safety Investigator. All other after-hour calls left on the FAA Hotline voicemail system will be retrieved the next business day.
d)    A reporting individual, who contacts the FAA Hotline, may request that their identity remain confidential.
e)    The hotline analyst inputs the information submitted by the reporting individual into the automated hotline tracking system, creates a hotline report, and provides an acknowledgement of receipt by phone or email back to the reporting individual.
f)    Additional information can be found in FAA Order 1070.1, FAA Hotline Program, and below in paragraph 7-137.

B.    Complaint Handling. Complaints and concerns will receive prompt handling, including a written FAA response.

1)    Flight Standards Service personnel should attempt to provide a final written response within 10 business-days from the time of receipt. When this is not possible, an acknowledgement of receipt of the complaint will be provided within 10 business-days from the time of receipt.
2)    Even if the complaint investigation does not result in a finding of an apparent deviation, there must still be a final response to the complainant explaining the results of the investigation.
3)    The final response should directly address the concerns or issues cited in the complaint. A final response should be courteous and concise, and, when possible, be free of generalities. The response should indicate if the FAA is taking additional action to address the issue and to prevent reoccurrence of the problem.
4)    Before replying to complaints concerning sensitive or significant issues, the responsible field office should discuss the form and manner of response with the appropriate Flight Standards Service Regional Office (RO) personnel.
5)    Due to the provisions of the Privacy Act, specific information regarding actual or possible Compliance Actions (CA) or enforcement actions should not be discussed within a response.

C.    Investigating a Complaint. Flight Standards Service personnel must follow the policy and procedures in Volume 7, Chapter 1 and Volume 14, Chapter 1 for addressing a potential problem. If the complaint investigation results in a finding of an apparent deviation, Flight Standards Service personnel will take appropriate action (i.e., CA or enforcement action) to address the problem and prevent reoccurrence of the deviation.

7-137    COMPLAINTS RECEIVED THROUGH THE FAA HOTLINE. Order 1070.1 identifies the procedures and guidelines used in responding to FAA Hotline items. The information in this paragraph provides an overview of the information contained in Order 1070.1.

A.    Office of Audit and Evaluation (AAE). The Administrator’s Hotline Operations Program, Aviation Safety Hotline, and Consumer Hotline were consolidated under AAE.

1)    Contact methods and hours of operations are described in subparagraph 7-136A. The general public, aviation industry, and FAA employees may contact the FAA Hotline.
2)    The hotline analyst inputs the information submitted by the reporting individual into the automated hotline tracking system, creates a hotline report, and provides an acknowledgement of receipt by phone or email back to the reporting individual. Acknowledgements for hotline reports sent out for investigation will include the assigned hotline number.
3)    The hotline report is transmitted by email along with any supporting documentation provided by the reporting individual to the principal point of contact (POC) for action or information.
4)    The FAA can receive information about a wide range of topics, including:

    Pilot examinations,

    Aircraft certification,

    Flight Service Stations (FSS),

    Advisory circulars (AC), and

    Foreign Civil Aviation Authorities (CAA).

5)    The Consumer Hotline also provides information to the general public on issues such as aircraft child restraints, carry-on baggage, and other topics that are monitored by the FAA:

    Apparent deviations from the Federal aviation regulations,

    Suspected use of unapproved parts,

    Nonadherence to operational procedures,

    Improper recordkeeping, and

    Unsafe aviation practices.

B.    Hotline Operation. Complaints are forwarded to the Office of Primary Responsibility (OPR) for evaluation and assignment to the appropriate office, region, or individual for investigation and reply.

1)    Confidentiality. Confidentiality is a significant feature of hotline operations.
a)    Action items may be received with or without caller identity. In addition, caller identification may be given with the stipulation that it not be divulged outside the Hotline Center. When requested, confidentiality must be retained. If a caller requests confidentiality at the time of the initial report, their name is withheld.
b)    Inspectors should guard against inadvertent disclosure of confidential sources during investigation of action items.
c)    Investigative reports provided to management should be limited to objective findings and appropriate verification of complaints.
2)    Investigation of Hotline Reports.
a)    The Investigative Results Report (IRR) is a summary report of the investigation results in memorandum format to the Reporting and Data Analysis Branch (AAE-300) manager, along with supporting documentation. The summary report includes, but is not limited to, a description of the issues/allegations made, the hotline report number, the name of the office that conducted the investigation, and responses to each allegation made in the hotline report. It should also include corrective or enforcement actions which have been initiated for any/all allegations that were substantiated in full or in part, a description of other actions taken as a result of the hotline report (e.g., policy change, remedial training, or counseling), and whether the reporting individual was contacted during the course of the investigation. Supporting documentation may include a grid copy of the memo to AAE and details of the investigation (e.g., PTRS reports, Enforcement Information System (EIS) numbers, emails, or reports of investigation) used in the preparation of the IRR.
b)    The principal POC forwards the hotline report for action to the appropriate office.

NOTE:  When a hotline report includes allegations of wrongdoing by FAA employees, the hotline investigation should be conducted by individuals who have no direct or indirect involvement in allegations or issues identified. This includes individuals named or working in the same office identified in the hotline report.

c)    The investigating office investigates hotline reports and prepares the IRR.
d)    Investigation of a hotline report includes addressing all allegations identified, reviewing any supporting documentation provided by the reporting individual, conducting interviews with any witnesses identified, and contacting the reporting individual when contact information is provided or available (in the case of confidential contacts) to ensure a complete understanding of the issue(s) being reported.
e)    If a hotline report is related to another hotline report or is part of an existing hotline investigation, the investigating office is responsible for notifying the principal POC and AAE. The hotline analyst will update the hotline record with a note including the related hotline record number(s). In such cases, only one IRR is required by the investigating office. The IRR should address allegations from all hotline reports.
f)    If the FAA Hotline receives multiple reports on the same issue, only one IRR will be created and the report will include copies of information provided by each of the reporting individuals.
g)    The IRR submitted by the investigating office should be carefully reviewed to ensure it clearly indicates if the allegations were substantiated in full or in part, or unsubstantiated. If substantiated, the IRR should indicate whether or not allegations violate 14 CFR or any FAA order, standard, or policy. The IRR should also clearly state if any corrective or administrative actions have been taken to resolve the matter. In cases where a violation of FAA regulations or policy has taken place and no corrective actions have been identified, the IRR must include an explanation of why no corrective actions are necessary.
3)    Due Date Extension. The investigating office may request a due date extension by contacting the principal POC or AAE (if the principal POC is not available) via email in the event the investigation cannot be completed on time. Extension requests will include how long an extension is needed in terms of days or a newly proposed due date. The suspense date is 45 business-days for regular hotline reports. The suspense date for suspected unapproved parts (SUP) reports is 180 business-days. The suspense date for aeromedical-related hotlines is 90 business-days.

C.    Responsibilities. Refer to Order 1070.1.

7-138    COMPLAINTS WITHIN FAA RESPONSIBILITIES. When the problem appears to require district office action, the inspector obtains a complete statement from the complainant.

A.    How to Take Statements During the Complaint Investigation. This paragraph contains information on interviewing, which may be helpful in obtaining statements from complainants or witnesses.

1)    The demeanor of the inspector is very important. It is critical to remain objective and emotionally detached from the issues concerning the complaint. Even if the occurrence or the potential consequences are serious, the inspector must never personalize the case. This is true even when the facts seem clear and emergent. A case that may eventually require substantiation for formal proceedings must be built on a carefully, objectively, and thoroughly constructed assemblage of the facts. Sometimes a long period of time elapses between the occurrence and the formal proceeding, and many facts may be forgotten or unobtainable by then. Objectivity and clear thinking allow the inspector to gather seemingly unrelated pieces of information that may be relevant later. It is best to deliver comprehensive evidence with a technical viewpoint.
2)    It is essential to take complete and accurate information from the person initiating the complaint. At a minimum, a complete report includes:
a)    The name, address, and daytime and home telephone numbers of the person initiating the complaint. Sometimes the inspector must investigate an anonymous complaint; however, it is preferable to be able to maintain contact with the source.
b)    Information concerning the witness’s occupation, particularly any aviation experience.
c)    A complete statement of the specific incident, including the following: What happened? Who was involved? Does the complainant have information about the aircraft, especially the aircraft registration number? What were the date, time, and location of the occurrence? What airport was involved? Were any photographs or videos taken? For incidents involving UAS, does the complainant know, or did he or she see, the UAS operator?
d)    The signature of the witness or complainant, when practicable.
3)    The inspector should request any relevant physical evidence, such as photographs, charts, maps, and diagrams. The witness may present the information or may know of another source of the information which the inspector may contact. In any case, the inspector either receives or gathers any supporting evidence. How much evidence to gather, in what form, and who may be informally contacted are areas of inspector judgment.

B.    Interdependence. Sometimes the inspector needs the support and assistance of others in order to gather information about the complaint. Inspectors may use the assistance of local law enforcement persons, the airport manager, air operator, or other contacts.

7-139    PREREQUISITES AND COORDINATION REQUIREMENTS.

A.    Prerequisites. This task requires knowledge of 14 CFR, FAA policy and orders, and the investigative process and qualification as an ASI.

B.    Coordination. This task may require coordination with a variety of contacts, including:

    The airworthiness unit,

    Other district offices,

    The RO operations branch,

    Law enforcement agencies,

    ATC,

    The Armed Forces,

    The airport manager,

    Other Federal Government agencies, or

    Local or state governments.

7-140    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    Any related 14 CFR parts.

    Volume 7, Investigation.

    Volume 14, Compliance and Enforcement.

    FAA Order 1070.1, FAA Hotline Program.

    FAA Order 2150.3, FAA Compliance and Enforcement Program.

    FAA Order 8020.11, Aircraft Accident and Incident Notification, Investigation, and Reporting.

    Job Task Analyses (JTA): Air Transportation (AT) JTA 1.3.17 (OP) or General Aviation (GA) JTA 1.3.17 (OP), Investigate a Complaint, located on the Flight Standards Information Management System (FSIMS).

B.    Forms:

    FAA Form 1360-33, Record of Visit, Conference, or Telephone Call.

    FAA Form 8000-36, Program Tracking & Reporting System Data Sheet.

C.    Job Aids. Sample responses and figures, Figures 7-18 through 7-20.

7-141    PROCEDURES.

A.    Initial Notification. Upon receipt of a telephone call, office visit, or written complaint, determine the nature of the complaint.

1)    Assess whether it can be immediately resolved, warrants further action in the district office, or should be referred.
2)    If the complaint is received verbally, be sure to record the specifics of the complaint. At a minimum, collect the applicable information in Figure 7-18, Sample Witness Statement and Referral Job Aid. FAA Form 1360-33 may be used as a record.

B.    PTRS. Open a PTRS record.

C.    Determine Appropriate Initial Action.

1)    No Action. If complaint can be resolved upon contact by explanation, fill out the PTRS record with the name and contact information of the caller, visitor, or correspondent. Enter a description of the complaint in the remarks section. Close the PTRS record with a “No Action.”
2)    Make Appropriate Referrals. If necessary, refer the complaint to the appropriate FAA office or other government agency. Refer to the listing of U.S. Government agencies at
https://www.usa.gov/federal-agencies/a.
a)    Refer complaints about noise to the local airport noise abatement office, airport manager, or city noise office and to the FAA regional noise abatement specialist.
b)    Refer complaints about agricultural chemicals sprayed by part 137 operators to the local extension office or EPA office when no aviation safety issues are involved.
c)    For consumer complaints concerning air operators, inform the complainant that he or she must contact the operator of the air carrier directly. If possible, provide the address or telephone number. Inform the complainant that he or she may also contact the Office of Intergovernmental and Consumer Affairs within the DOT, and provide that address and telephone number.
d)    Refer complaints involving flight procedures to the regional flight procedures office.
e)    Refer complaints about faulty NAVAIDs to airways facilities or FSS.
f)    Refer complaints about air traffic procedures to the appropriate air traffic facility manager.
g)    Refer complaints about hazardous airport conditions to the Airports Division of the appropriate FAA RO or the nearest airports district office.
h)    Refer complaints about airport security to the nearest Civil Aviation Security Field Office (CASFO) or the local airport security office.
i)    For complaints involving military airports or military personnel, contact the appropriate military base or the FAA regional military representative (see Volume 7). If a pilot deviation (PD) is determined from the investigation, see Volume 7, Chapter 1, Section 2.
j)    Refer complaints concerning alleged criminal activity to the appropriate law enforcement agency, such as local law enforcement, the Federal Bureau of Investigation (FBI), or the Drug Enforcement Agency (DEA), as appropriate.

D.    Complaints Requiring District Office Action. Advise the complainant that you or another inspector in the district office will investigate the complaint.

1)    If able, and if not already accomplished, collect the information described by the witness statement (Figure 7-18).
2)    Discuss the complaint with the unit supervisor for assignment and coordination.

E.    Investigation of Complaints. When the inspector is assigned a case to handle:

1)    Use the policy and procedures for investigating potential instances of deviations found in Volume 14, Chapter 1. Address any deviations with recommendations, CAs, or enforcement actions, as necessary.
2)    Depending on the nature of the complaint and investigation, the inspector may need to see additional sections of Volume 7 for additional policy and procedures.

F.    Follow Up with Complainant. Advise the complainant of the results of the inspector’s preliminary investigation (Figure 7-19, Sample Response of Closing Out a Complaint That Requires Further Action, or Figure 7-20, Sample Response of Closing a Complaint Without Further Action, as appropriate).

1)    If there is not enough information to proceed with an investigation, inform the complainant and indicate what additional information is required from the complainant. Provide the complainant with a suspense date for the additional information. If that information is not received by the suspense date, close out the complaint in the PTRS.
2)    If the inspector is proceeding with additional investigation, inform the complainant that the matter is being investigated by the office and appropriate action will be taken based on the findings. Indicate that the complainant will be informed of the disposition of the investigation.
3)    When the investigation of the complaint is complete, the complainant will be notified of the results of the investigation. Specific information regarding potential or actual CAs or enforcement actions should not be provided.
4)    The inspector must document the followup with the complainant in the PTRS comments.

G.    Prepare Office File. Prepare a file which includes any evidence, correspondence, witness statements, and the disposition of the complaint.

H.    PTRS. Close the PTRS record with explanatory remarks as to whether the case was closed with no further action, referred, or further investigative action was taken.

7-142    TASK OUTCOMES. Completion of this task results in one or more of the following:

    A response to the complainant indicating the disposition of the complaint;

    Initiation of additional action (such as a CA or enforcement action); or

    Referral of the complaint to another agency or another area of the FAA.

7-143    FUTURE ACTIVITIES.

    Possible followup on any CA or enforcement action, which may include additional surveillance or inspection-related tasks;

    Coordination with other offices; or

    Response to related complaints from different complainants.

Figure 7-18.  Sample Witness Statement and Referral Job Aid

WITNESS STATEMENT:

Date and time of complaint: __________________________

Name of Caller: _____________________________________

Home phone number: __________________

Daytime phone number: _____________________

Occupation: ____________________________

Aviation Experience: ______________________

Name of Person Involved: ___________________________________

Aircraft Registration No.: _____________________________

(or description)

Description of Complaint:

Figure 7-19.  Sample Response of Closing Out a Complaint That Requires Further Action

FAA LETTERHEAD

Date

Name

Address

Dear ________,

This letter is in response to your inquiry on [insert date complaint was received] regarding [insert brief description of the nature of the complaint]. Our findings indicate that further action may be warranted and we will investigate. If you have any additional information, please contact the district office as soon as possible.

Thank you for your concern and cooperation in this matter.

Sincerely,

[Principal Operations Inspector’s signature]

Figure 7-20.  Sample Response of Closing a Complaint Without Further Action

FAA LETTERHEAD

Date

Name

Address

Dear __________,

This letter is in response to your inquiry on [insert date complaint was received] regarding [insert brief description of the nature of the complaint]. We have found insufficient evidence to proceed with additional action, and we consider this matter closed. However, if you have any further information that would assist the Federal Aviation Administration (FAA) in pursuance of an action, please contact this Flight Standards District Office (FSDO).

Thank you for your concern and cooperation in this matter.

Sincerely,

[Principal Operations Inspector’s signature]

RESERVED. Paragraphs 7-144 through 7-160.