FAA/Aviation Industry Agenda for
OpSpec Working Group (OSWG) 2005-04
October 18, Tuesday, Industry Meeting 9:30 to 12:00
OSWG Meeting 1:00 to 5:00
October 19, Wednesday, OSWG Meeting 8:30 to Noon
Hosted by: Air Transport Assn. (ATA)
Paul Railsback, 202-626-4101
Meeting Location: Hogan and Hartson Conference Room, Downstairs from the lobby,
555 13th St NW, Washington, DC.
October 18-19, 2005 OSWG 2005-04
ATA host @ Hogan and Hartson Conference Room, Downstairs from the lobby, 555 13th St NW, Washington, DC.
January 24-25, 2006 OSWG 2006-01
AmeriJet host @ Miami
April 25-26, 2006 OSWG 2006-02
NACA @ Washington, DC
July 25-26 , 2006 OSWG 2006-03
ComAir Host in Cincinnati
Chairpersons: Casey Seabright, NWA, Industry Chair
John Cowan, UAL, Industry Vice Chair
Connie Streeter, FAA Chair
1. Convene :
a. Roster: A copy of this meeting’s Roster will be sent in a separate electronic file to all those on the OSWG email list.
b. The OSWG SPEC is now called the OSWG Procedures Guide. It is on the www.opspecs.com website under POLICY/OSWG Meetings. All are encouraged to review this procedures guide.
c. General Information in Regard to Agenda Items:
(1) Proposed changes to an OpSpec or to the guidance that would constitute "policy changes" to an OpSpec will generally need to be presented to the OSWG and AFS-260 in HBAT format which includes appendices containing the appropriate revision to the guidance for the OpSpec in 8400.10/8300.10 and a sample of the proposed OpSpec revision and/or guidance.
(2) If you have a proposal, email Connie Streeter and she will provide you with a sample template for the proposal.
2. Status of Assigned Action Items : Chairpersons
Ø Reviewed, amended, and adopted agenda
Ø Bob Hall has retired.
Bob writes: Connie - Well, good news for me. I will be retiring from ALPA effective October 1, 2005. (see the "press release" from the Engineering and Air Safety Director below). Unfortunately I will be retired before OSWG 2005-04. So please pass this announcement on to all of OSWG members and relay my best wishes to all of them. It has been my pleasure working with the OSWG. Although I will be retiring, Chris Stevens (UAL Captain) will continue to represent ALPA at OSWG meetings.
As many of you already know Bob Hall retired after almost 20 years of service to ALPA and its membership. That is a long time for a second career. Because it has been a long time we thought that we would provide more details not only on Bob’s ALPA career but also on his career in the US Air Force.
ALPA hired Bob in January 1986 directly from the US Air Force after 27 years as a fighter pilot and safety officer. Bob’s most impressive accomplishment during his Air Force career was that he survived 118 combat missions over North Vietnam flying the F-105 “Wild Weasel”. The “Wild Weasel” mission was to make the skies safe for other US combat aircraft. It involved “Hunter – Killer” tactics with the role of finding and either suppressing or destroying enemy radar controlled anti-aircraft or surface-to-air missile (SAM) sites. The “Wild Weasel” motto was “First in and Last out”.
As a staff engineer in the Engineering and Air Safety Department Bob originally provided support to two ALPA Air Safety Technical committees: the Airworthiness and Performance (A&P) Committee and the New Aircraft Evaluation and Certification Committee (NAECC). He was well suited to support these two committees due to his Masters Degree in Aeronautical Engineering from the Georgia Institute of Technology (Georgia Tech), and his developmental testing experience as a pilot and Test Programming Engineer at the Air Force Armament Development Test Center at Eglin AFB, Florida. During the last half of Bob’s ALPA career, he worked OpSpecs, MMEL issues and provided staff support for the Operations Committee (OPSCOM).
One of Bob’s biggest thrills during his ALPA career occurred during a NAECC visit to Airbus in Toulouse, France. Bob accompanied the NAECC on their test flight evaluation of the A-320, which was in the final stages of development at that time. After the pilots had finished their evaluation, there was a little time left. Bob got to shoot a touch and go landing (yes, in the A-320 aircraft, not in the Simulator) - Pretty exciting for a “desk jockey”.
Probably Bob’s most valuable contribution to ALPA, and all airline pilots in general, is his work on Master Minimum Equipment Lists (MMELs). Bob was part of the original FAA / Industry working group (started in the late 1980s and continuing today) that crafted FAA policy for what is allowed to be inoperative on an aircraft and still be safe to fly. MMELs affect almost every flight flown by our members.
Bob and his wife Shirley live in a “Victorian” house (built in1890) in the Historic District of Leesburg, VA and Bob has invited everyone to stop by for a visit if you are in Leesburg and you want to see a truly unique and creatively decorated home containing lots of English antiques. After ALPA retirement Bob is looking forward to spending more time working on his house, tinkering with (and driving) his antique cars, and continuing his trips to England, Colorado, Santa Fe, NM, and other exciting places (like skiing in Canada).
3. OpSpec D072, CAMP
FAA Lead : AFS-300
Industry Lead: none
Background : OpSpec D072 authorizes certificate holders and Part 91K program managers to use a CAMP.
Change 21 to Order 8300.10, vol. 2, chapter 84, removed the requirement for the "CAMP revision number" and the "CAMP revision date" columns. This is a Non-Mandatory change.
4. OpSpec D084, S pecial Flight Permit with Continuous Authorization to Conduct Ferry Flights.
FAA Lead: AFS-300
Industry Lead: None
Background : A revision to D084 is necessary because the language in paragraph g of the current ops spec only applies to ferry flights with one engine inoperative. These ferry flights are not conduced under the authorization of D084, they are conducted by 91.611. Therefore the language must be removed.
Desired Outcome This would be a Mandatory change with a 90-day compliance date to correct this OpSpec. OpSpec D084 is would to be revised with the release of Change 22 to Order 8300.10.
5. Non-Std OpSpec 384, RNP SAAAR
FAA Lead: AFS-410/AFS-220—
Industry Lead: Alaska Airlines
Background: The concept of required navigation performance (RNP) is a significant enhancement to navigable airspace design, use, and management. RNP was developed by the International Civil Aviation Organization (ICAO) Special Committee on Future Air Navigation Systems (FANS) and is an integral part of the communication, navigation, surveillance, and air traffic management (CNS/ATM) plan envisioned by the Special Committee.
The RNP SAAAR instrument approach procedures are developed under the criteria of AC 90-RNP SAAAR and are approved for use without requiring the proponent to prove criteria sufficiency for use in the development of special (non-14 CFR Part 97) instrument approach procedures based on RNP using RNAV avionics systems .
Desired Outcome: NonStandard OpSpec C384 is now in the live part 121 DB [only]. We are still working on the development of guidance. However, the intent is for this OpSpec to remain a nonstandard authorization requiring AFS-200 and AFS-400 concurrence for it to be issued. We will provide the OpSpec/MSpec in other DBs as it becomes necessary as a result of qualified applicants.
“I have just finished signing the first US Air Carrier operations specifications for RNP SAAAR. Alaska Airlines will begin using the new DCA approach on Thursday September 29, 2005. This is clearly two full days ahead of the post.
This was a true teamwork effort, my hat is off to all of you for your diligence, patients and willingness to do the right things. Thank you all for allowing Flight Standards to achieve its goal in a fashionable style.”
Respectfully, Tim D. Miller
Supervisory Principal Operations Inspector for Alaska Airlines
6. OpSpec C063, IFR RNAV Departure Procedures (DP) and Standard Terminal Arrivals (STAR)
FAA Lead: AFS-400/AFS-200
Background: HBAT 05-04, U.S. Area Navigation (RNAV) Instrument Departure Procedures (DP), RNAV Routes, and RNAV Standard Terminal Arrivals (STARs); Revision to OpSpec/MSpec C063 was published 06/09/05.
During the implementation of various RNAV terminal procedures from 2001 through 2004, several operational problems became apparent. Some of the relevant issues involved aircraft RNAV system architecture, procedure design and coding, and pilot/controller guidance and procedures.
A. Regarding the latter concern, pilots in several cases did not fly with adequate precision to meet controller expectations. In a few instances, this inconsistency resulted from pilots not following available flight guidance, such as a flight director. In more limited cases, pilots did not enter the correct departure runway into their RNAV system.
B. In an effort to harmonize RNAV system functionality, FAA design criteria, and operational guidance for RNAV terminal procedures and routes (except for instrument approach procedures), the FAA published A dvisory Circular (AC) 90-100, U.S. Terminal and En Route Area Navigation (RNAV) Operations, current edition (available at: http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs400/afs410/policy_guidance /). To reflect the terminology of AC 90-100, RNAV terminal procedures will be charted as either RNAV “Type A” or “Type B” DPs and STARs after September 2005.
Desired Outcome: Please note that HBAT 05-04 states that OpSpec C063 [mostly for the part 135s] probably needs to be archived for many certificate holders until it is verified that the qualifications are met for the new OpSpec C063:
A. OpSpec C063 for certificate holders is revised to authorize RNAV “Type A” or “Type B” DPs and STARs, as well as domestic U.S. RNAV routes and is no longer used for rho-theta navigation principles. MSpec C063 is new and now available for part 91K program managers. The new OpSpec/MSpec C063 is available in the Operations Safety System (OPSS).
B. If an operator’s aircraft are not eligible and/or its flightcrews are not appropriately trained to conduct RNAV “Type A” or “Type B” DPs and STARs, OpSpec/MSpec C063 should not be issued.
C. For certificate holders currently issued the old OpSpec C063, the active documents should be archived and the appropriate RNAV authorization(s) should be selected in OpSpec/MSpec C052.
To archive the active OpSpec C063 in the OPSS:
(1) Open the certificate and go to the certificate holder's grid;
(2) Highlight the active C063;
(4) On the menu bar select "paragraph" and under the drop-down menu select "change status" and "change to archive".
7. OpSpec C074, Category I ILS, MLS, or GLS Approaches
FAA Lead: Robert Davis, AFS-220
Background: Order 8400.13 was again revised as of February 2005. The OpSpec C074 and C059 could be affected by the change.s again revised as of February 2005. The OpSpec C074 and C059 could be affected by the change.
Desired Outcome: A decision to revise OpSpec C074 to agree with Order 8400.10--maybe. The revised Order 8400.13 added the use of a flight director for conducting operations to certain airports/runways without CL, TDZ, or ALSF-II.
8. OpSpec A527 and A528
FAA LEAD: AFS-220
Industry LEAD :
Background: A527 was put into the OPSS for Hurricane Katrina relief efforts; A528 was put into the OPSS for Hurricane Rita relief. Both have been archived.
Desired Outcome: For those certificate holders that had it (and/or A527) issued, the active template in the certificate holder's grid must also be archived. To archive the OpSpec in the OPSS when the template was archived by HQ:
(1) Open the certificate and go to the certificate holder's grid,
(2) Click on the "filter" and ensure that the "Active-Archived Decommissioned" box is checked & click OK
(3) The OpSpec will appear (dark green); Highlight the A527 and/or A528;
(4) On the menu bar select "paragraph" and under the drop-down menu select "change status" and "change to archive".
If you have any questions or encounter any problems please contact the OPSS Help Desk at 405-954-7272.
9. OpSpec C359, Special Authorization for Certain Category II Operations at Specifically Approved Facilities
FAA Lead : AFS-410/AFS-200
Industry Lead: Jim Johnson, AA
Background: Order 8400.13 was published November 2002. It was revised to Order 8400.13B on February 15, 2005. When OpSpec C059 for CAT II operations was revised, OpSpec C359 was put into place because of the requirements of Order 8400.13 for CAT II operations. Even though this OpSpec is in the “300” series, for authorization the operator does not have to follow the “nonstandard OpSpec process” for its authorization. s published November 2002. It was revised to Order 8400.13B February 15, 2005. When OpSpec C059 for CAT II operations was revised, OpSpec C359 was put into place because of the requirements of Order 8400.13 for CAT II operations. Even though this OpSpec is in the “300” series, for authorization the operator does not have to follow the “nonstandard OpSpec process” for its authorization. r CAT II operations. Even though this OpSpec is in the “300” series, for authorization the operator does not have to follow the “nonstandard OpSpec process” for its authorization. C359?
1. Need to revise the present C359 to match the revisions to 8400.13B. And, Bruce Montigney requested that the subparagraph c be removed for “training and checking” because he felt the real intent was not to train this separately which that statement implies.
2. Order 8400.13 appendices provide the Checklists for requesting runway approvals. If you have any runways that are in question send msg to Dick Temple and he will do a “desk audit” on them. Dick Temple will work with Lyle Wink on the status of these airports and determine which approach procedures are now published as Part 97s.
DISCUSSION: Since Bruce was not at the meeting, there was no further discussion on this subject.
Action/Outcome: Bruce and other POIs will review the necessity of having a separate paragraph at all for this authorization C359.
Bruce will work on merging the limited value of C359 into C059 and then allowing for the elimination of C359. He owes Connie the proposal and updated HBAT.
10. OpSpec A031, Contract Training Centers
Industry Lead = None
FAA Lead = AFS-210, Hop Potter/Dan Jenkins
Background: Jim Kerr (OKC academy) has some suggestions regarding FAA OpSpecs. He writes: There is confusion among the POI work force regarding the audit interval required in OpSpec paragraph A031. The audit verbiage is tied to the curriculum. Operators are adding/changing curriculums on a somewhat regular basis. This in turn makes the anniversary date for audit difficult to determine.
September OpSpec A031 was inadvertently rolled with a minor change. This still did not take care of the “audit” issue.
Desired Outcome: (Jim Kerr, OKC academy) would like to suggest that the audit language be tied to the original date the POI authorized the use of outsourced training at training centers. Justification is that the audit date would remain fixed and there would be less confusion for the POIs and operators when an audit would be required.
DISCUSSION: Because it was pointed out that all certificate holders are responsible for conducting a biennial audit on their out-sourced training, some of the industry participants recommended that a n audit must be completed within the calendar year in which it is due.
11. OpSpec B036, Class II Navigation/OpSpec B034 Audits
Industry Lead: None
FAA Lead: AFS-200
The only aircraft that can receive RNP-4 authorization for Oceanic and Remote airspace will be GNSS aircraft. The time limits and the requirements for additional Communications such as CPDLC and ADS in the applicable airspace means that it is for FANS aircraft only.
12. Customer Survey. Connie Streeter asked each meeting participant to fill out an OSWG Customer Survey. This is a new requirement for FAA personnel. Results of previous survey are at the end of this agenda.
13. OpSpec C052. Instrument Approach Procedures.
Industry Lead: United Airlines , Captain John Cowan
FAA Lead: AFS-220/AFS-410
Background : We had a SNAFU concerning our OPSPEC authorizations recently when the JAC VOR unexpectedly went out of service (lightning strike on 9/10). Although we are authorized to conduct arrival, approach and departure procedures with the basic underlying NAVAID out of service, it's difficult to do if Center (SLC) denies you the procedure or if it's NOTAMed "NA". Here are a few of the obstacles we faced:
- AVN evidently has a policy that when a primary NAVAID is OTS, they NOTAM each affected procedure as "NA". Example:
JAC NO 9/2 JAC VOR OTS
JAC NO 9/10 JAC TETON TWO DEPARTURE... PROCEDURE NA.
JAC NO 13/2 FDC 5/8234 ILS OR LOC RWY 19, JEPCO. PROCEDURE NA.
Such NOTAMs cripple our ability to fly the procedure using our (OPSPEC authorized) RNAV capabilities. How do we resolve this?
To temporally get back into business, we took the highly unusual step of issuing the following company NOTAM:
GPS EQUIPPED A319/A320 AIRPLANES SHOULD NOT BE IMPACTED BY THE JAC VOR BEING OTS. THESE AIRPLANES ARE FAA OPSPEC AUTHORIZED TO CONDUCT THE FOLLOWING PROCEDURES, EXACTLY AS PUBLISHED: LOC RWY 19, VOR DME RWY 1 AND/OR RWY 19, TETON 2 DEPT AND THE GEYSER 3 DEPT. LOCAL JAC NOTAMS INDICATING "PROCEDURE NA", OR ADDING RESTRICTIONS TO THE GEYSER 3 (E.G., "CROSS NALSI AT OR ABOVE 14,000") DO NOT APPLY. NOT ALL AGENCIES UNDERSTAND PART 121 OPSPECS AND DELAYS ARE POSSIBLE. IF THIS OCCURS, CONTACT DISPATCH FOR ASSISTANCE.
Manager, Flight Operations Manual
Flight Standards and Technology, DENTK
Desired Outcome: - - When you consider that for years numerous Air Carriers have had airplanes flying NDB approaches without an ADF receiver, and that many of our expensive advanced navigation systems don't look at VOR radials when navigating (i.e., don't actually track the radio signal), we are at a loss to understand these systemic failures.
Ø ATC Center would not clear the pilots for the LOC approach because the VOR was OTS (used for the missed). How do we prevent this?
Ø The ATC Tower manager says he is prohibited from using a procedure name (e.g., TETON ONE) in a clearance if the navaid is OTS. How do we resolve this?
Ø FAA HQ Staff seemed to be caught by surprise when we explained our RNAV authorizations. How do we resolve this?
Ø Your assistance in facilitating resolution to these issues would help move all of us together into the 21st Century and would be greatly appreciated.
14. OpSpecs C060—Part 97 CAT II/CAT III Restrictions
Industry Lead: UPS
FAA Lead: AFS-410/AFS-220
Background : For several years the OSWG members requested the removal of the requirement for listing the Part 97 CAT III runways in the OpSpec.
Desired Outcome: Suggestion sent in by Bill Cook, UPS:
g. Authorized CAT III Runways.
(1) The certificate holder is authorized to conduct Part 97 CAT III instrument approach procedures at runways approved for such operations. CAT III operations into Restricted U. S. Facilities are authorized with the approval of AFS-400 as provided in AC 120-28D, appendix 8, current edition. Additional analysis or flight demonstrations are required for each aircraft type prior to approval of CAT III operations. CAT III operations are authorized for U. S. ILS facilities and aircraft listed below:
CINCINNATI, OH, USA/CINCINNATI-NORTHERN KENTUCKY INTL (KCVG/CVG)
Cat III approach authorized for B767/B757 only.
DENVER, CO, USA/DENVER INTL (KDEN/DEN)
Cat III approach authorized for B767/B757 only.
PITTSBURGH, PA, USA/GREATER PITTSBURGH INTL (KPIT/PIT)
CAT III approach authorized for B767/B757 only.
SEATTLE, WA, USA/SEATTLE TACOMA INTL (KSEA/SEA)
CAT III approach authorized for B767/B757 only.
DISCUSSION: After the recently revised C060 was rolled, the UPS POI called and asked where he was to put any Part 97 CAT III runway restrictions since we no longer require them to be listed routinely in C060. The group felt that two tables may be best, a domestic table for runways with comments or restrictions and an International table. Additionally it was suggested that a “dropdown” selection menu be added to the tables which would eliminate the need for the user to go to the website.
Action/Outcome: Connie will redraft to clarify how to capture and maintain known restrictions to domestic runways and develop an additional domestic table for runways with comments or restrictions with a “dropdown” selection menu. Look for a revised HBAT 05-02 to be posted on www.opspecs.com.
15. 10:00 AM-- Nav Evolution Decommissioning Update Tom Meyer/Harry Kane.
FAA Lead: Harry Kane
Background : Several times we have been asked about the NDB Decommissioning Plan. Mr. Kane and Mr. Meyer have some information to share.
16. OpSpec B043 Fuel Reserves in International Operations :
FAA Lead: Gordy Rother / Jerry Ostronic/Robert Davis
Industry Lead(s): Jim Johnson, American Airlines
Desired Outcome: Update B043 with a “correction” to the requirement for an alternate during supplemental operations, while the FAA continues to debate the definition of “class 1 navigation”.
DISCUSSION: Industry is concerned that attempts will erode the definition of Class 1 navigation as provided in B032.
ACTION/Outcome: Knowing that any attempts to erode the definition of Class 1 navigation as provided in B032 will meet with serious Industry opposition, Gordy will attempt to be creative in recommending an appropriate resolution.
17. OpSpec A012, Domestic Regulations for Flag Operations
FAA Lead: AFS-220
Industry Lead: none
Background : Previous POI's at ASA have been of the opinion that we cannot list an airport in A012 if that airport is in a non-radar environment. The current POI is reluctant to allow a change because of the guidance in 8400.10 VOL 3 Chapter 1 Section 3 paragraph 64 OPSPEC A012 A. (3) The flight operations have the capability of being surveiled by radar or other surveillance technology equivalent to radar such as ADS or ADS-B.
DISCUSSION: The two airports that are in question for us at ASA are MBPV Providenciales I, Caicos Is, and MYGF Freeport, Bahamas. Flights to both airports are in a radar environment (Miami Center) until you arrive at the airports which both have a non-radar approach control facility. We (ASA) have been operating flights to both airports as FLAG operations but have recently discovered that all the other airlines operating to these airports operate their flights under domestic rules using A012.
My question is the above reference from the 8400.10 correct and we cannot list an airport in A012 that has a non-radar approach control facility, or are we simply interpreting this wrong and it only applies to the en route section of the flight (this is what I have been told by other carriers who list there airports in A012).
Desired Outcome: Remove or revise the requirement to be under radar surveillance at all times: (3) the flight operations have the capability of being surveilled by radar or other surveillance technology equivalent to radar such as ADS or ADS-B.
Action/Outcome: Jerry Ostronic agreed to review 8400.10 VOL 3 Chapter 1 Section 3 paragraph 64 OPSPEC A012 A and consider removal of this requirement. The entire group was unable to recall why such a requirement might have been included in 8400.10. AFS-200 will remove or revise the statement in the 8400.10 guidance in a future change:
A change is in coordination that could revise the statement to read: “ (3) The flight operations have rapid and reliable communications capability in accordance with part 121 section 121.99 and the flight operations have the capability of being surveilled by radar or other surveillance technology equivalent to radar such as ADS or ADS-B in the en route environment . ”
18. OpSpec A021, Helicopter Emergency Medical Services (HEMS) Loss of Control (LOC) and Controlled Flight into Terrain (CFIT) Accident Avoidance Programs
Industry Lead: none
FAA Lead: AFS-220, Robert Davis/AFS-800, Hooper Harris.
Background : OpSpec A021 authorizes a certificate holder operating in accordance with part 135 to conduct VFR emergency medical service (EMS) operations in helicopters. HEMS operate in a demanding environment: they provide an invaluable service to the public by providing crucial, safe, and efficient transportation of critically ill and injured patients to tertiary medical care facilities. While the contribution of HEMS is a profound component of the nation’s medical infrastructure, from an operational standpoint, it is a commercial aviation activity performed by FAA-certificated air carrier operators. HEMS operations have recently suffered an increasing accident rate, especially in accidents involving LOC and CFIT.
The guidance for HEMS and the OpSpec will be revised. Two draft HBATs are on the http://www.opspecs.com/ website for your review.
19. [Standing agenda item] OpSpec C050, Special PIC Qualification Airports—14 CFR Section 121.445 Airport List Review & Recommendation of OSWG to AFS-220:
Industry Lead: Casey Seabright, NWA
FAA Lead: AFS-220/260
Background: Advisory Circular 121.445 was cancelled and replaced with OpSpec C050 and guidance that directs the OSWG members to present additions and deletions to the 14 CFR Section 121.445 Special PIC Qualification Airport List. The recommendation must include the airport information on the completed Airport Assessment Form found in association with OpSpec C050 and on the www.opspecs.com website. The OSWG members should review the assessment and make a recommendation to FAA Headquarters, specifically AFS-220. This recommendation will become a part of the OSWG minutes and presented to AFS-220 within 2 weeks of the quarterly OSWG meeting. The Airport Assessment Form for each specific airport recommendation will also be forwarded to AFS-220. AFS-220 will make the final determination in regard to the request and recommendation. If a change in the Special PIC Qualification Airport List is to be made, the OSWG members will be notified by email, the revised List will be posted on the public website at http://www.opspecs.com and in the OPSS guidance subsystem in association with both OpSpec C050 and C067, and reported at the next quarterly OSWG meeting.
Desired Outcome : A known process for updating the Special PIC Qualification Airport List. A consistent process for updating the Special PIC Qualification Airport List.
Additional processes that are included in the FAA/Industry SPEC for this process:
1) Should have a minimum of 1 week lead time before the OSWG quarterly meeting
2) OSWG Members can vote at the meeting or they can send their recommendation to Connie Streeter for submittal at the meeting.
3) Notification to certificate holders:
¨ Put a Note on the OPSS Splash Screen for first line of notification
¨ Change the Special PIC airport List in guidance subsystem in association with
OpSpecs C050 and C067
¨ Change the Special PIC airport List on the http://www.opspecs.com/ website
¨ Send email message to OSWG members
¨ Discussion of each individual assessment
¨ Recommendation for AFS-200