GAO-10-678, Aviation Safety: Improved Planning Could Help FAA Address Challenges Related to Winter Weather Operations


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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

July 2010: 

Aviation Safety: 

Improved Planning Could Help FAA Address Challenges Related to Winter 
Weather Operations: 

GAO-10-678: 

GAO Highlights: 

Highlights of GAO-10-678, a report to congressional requesters. 

Why GAO Did This Study: 

Ice formation on aircraft can disrupt the smooth flow of air over the 
wings and prevent the aircraft from taking off or decrease the pilot’s 
ability to maintain control of the aircraft. Takeoff and landing 
operations can also be risky in winter weather. Despite persistent 
efforts by the Federal Aviation Administration (FAA) and others to 
mitigate icing risks, icing remains a serious concern. GAO reviewed 
(1) the extent to which commercial airplanes have experienced 
accidents and incidents related to icing, (2) FAA’s inspection and 
enforcement activities related to icing, (3) the efforts of FAA and 
others to improve safety in winter weather, and (4) the challenges 
that continue to affect aviation safety in winter weather. GAO 
analyzed data obtained from FAA, the National Transportation Safety 
Board (NTSB), the National Aeronautics and Space Administration 
(NASA), and others. Further, GAO obtained information from FAA and 
NTSB officials and representatives of key aviation industry 
stakeholders. 

What GAO Found: 

According to NTSB’s aviation accident database, from 1998 to 2009 
large commercial airplanes were involved in six nonfatal accidents 
related to icing (including in-flight and runway). However, FAA and 
others recognize that incidents are potential precursors to accidents. 
Although large commercial airplanes have experienced few icing-related 
accidents in the last decade, the several hundred icing-related 
incidents involving these airplanes contained in FAA and NASA 
databases suggest that they face ongoing risks from icing. 

Based on multiple inspections, FAA assesses each large carrier’s 
ground deicing program to ensure that it meets relevant safety 
regulations. For fiscal years 2005 to 2009, FAA largely met its own 
requirements for inspecting carriers’ ground deicing programs. When a 
carrier violates a safety regulation, FAA can take enforcement action 
against the carrier. For fiscal years 2005 to 2009, FAA initiated 
enforcement actions against large commercial carriers in 274 cases for 
violations of icing-related regulations. 

FAA and other aviation stakeholders have undertaken many efforts to 
improve safety in icing conditions. For example, in 1997, FAA issued a 
multiyear plan for improving the safety of aircraft operating in icing 
conditions and has since made progress on the objectives specified in 
its plan by issuing regulations, airworthiness directives, and 
voluntary guidance. However, FAA has not formally updated its 1997 in-
flight icing plan, meaning the stakeholders do not have a consolidated 
and readily accessible source of information on the key in-flight 
icing actions FAA has under way or planned. NTSB has issued numerous 
recommendations as a result of its aviation accident investigations, 
and NASA has contributed to research related to icing. In addition, 
the private sector has deployed various FAA-required technologies on 
aircraft, such as wing deicers, and operated ground deicing and runway 
clearing programs at airports. 

GAO’s interviews with government and industry stakeholders identified 
challenges related to winter weather operations that, if addressed, 
could improve safety. Among others, these challenges include improving 
the timeliness of FAA’s winter weather rulemaking efforts, ensuring 
the availability of resources for icing-related research, and 
developing a more integrated approach to effectively manage winter 
operations. With respect to an integrated approach, FAA said it needs 
to begin focusing on winter operations holistically because there are 
many vital elements to safe operations in winter weather, such as 
airport surface conditions, aircraft ground deicing, aircraft in-
flight icing and icing certification, and air traffic handling of 
aircraft in icing conditions. A plan that addresses both in-flight and 
ground icing issues, as well as the challenges stakeholders identified 
for this report, would help FAA measure its ongoing and planned 
efforts against its goals for improving safety. Furthermore, a 
comprehensive plan could help identify gaps or other areas for 
improvement and assist FAA in developing an integrated approach to 
winter operations. 

What GAO Recommends: 

To help facilitate FAA’s efforts to address challenges to improving 
safety in winter weather conditions, GAO recommends that FAA develop a 
plan focused on winter operations holistically that includes detailed 
goals and milestones. In response, the Department of Transportation 
agreed to consider GAO’s recommendation and provided technical 
comments, which were incorporated as appropriate. 

View [hyperlink, http://www.gao.gov/products/GAO-10-678] or key 
components. To view the e-supplement online, click on [hyperlink, 
http://www.gao.gov/products/GAO-10-679SP]. For more information, 
contact Gerald L. Dillingham, Ph.D. at (202) 512-2834 or 
dillinghamg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Although Large Commercial Airplanes Have Experienced Few Icing-Related 
Accidents Since 1998, the Many Reported Icing Incidents Suggest That 
Icing Is an Ongoing Risk to Aviation Safety: 

FAA Largely Met Its Own Inspection Requirements Related to Icing: 

FAA and Other Aviation Stakeholders Have Undertaken a Variety of 
Efforts Aimed at Improving Safety in Icing and Winter Weather 
Conditions: 

Continued Attention to Regulation, Training, and Coordination Issues 
Could Further Mitigate the Risks of Winter Weather Operations: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: FAA's Funding to the Airport Improvement Program for 1999 
to 2009, by State and City: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Description of Tools and Processes Used for Ground Deicing 
and Anti-Icing: 

Table 2: Description of Aircraft Systems for In-flight Ice Protection: 

Table 3: Icing and Winter Weather-Related Incident Reports for Large 
Commercial Airplanes by Category of Incident, 1998 to 2007: 

Table 4: Icing and Winter Weather-Related Accidents and Fatalities for 
1998 to 2009, Incidents from 1998 to 2007: 

Table 5: Assessment Results of FAA's Inspections of Large Commercial 
Carriers' Ground Deicing Programs (December 2007 through End of Fiscal 
Year 2009): 

Table 6: Industry Groups We Contacted: 

Figures: 

Figure 1: Effect of Ice Build-up on Aircraft Wings: 

Figure 2: Assessment Results of FAA's Inspections of Large Commercial 
Carriers' Ground Deicing Programs by Type of Inspection (December 2007 
through End of Fiscal Year 2009): 

Figure 3: Aircraft Ice Protection Systems: 

Figure 4: Example of Ground Deicing to Help Ensure Clean Aircraft: 

Figure 5: FAA's Rulemaking Process for Significant Rules: 

Figure 6: NASA Funding and Staffing for Icing-Related R&D, Fiscal 
Years 2005-2013, as of February 2010: 

Abbreviations: 

AIP: Airport Improvement Program: 

AIRA: Aircraft Icing Research Alliance: 

APA: Administrative Procedure Act: 

ARAC: Aviation Rulemaking Advisory Committee: 

ASRS: Aviation Safety Reporting System: 

ATOS: Air Transportation Oversight System: 

CIP: Current Icing Product: 

EMAS: Engineered Materials Arresting System: 

EPA: Environmental Protection Agency: 

FAA: Federal Aviation Administration: 

FIP: Forecast Icing Potential: 

IG: Inspector General: 

MTOW: Maximum Takeoff Weight: 

NASA: National Aeronautics and Space Administration: 

NCAR: National Center for Atmospheric Research: 

NextGen: Next Generation Air Transportation System: 

NOAA: National Oceanic and Atmospheric Administration: 

NSF: National Science Foundation: 

NTSB: National Transportation Safety Board: 

PTRS: Program Tracking and Reporting Subsystems: 

R&D: research and development: 

[End of section] 

United States Government Accountability Office: 

Washington, DC 20548: 

July 29, 2010: 

Congressional Requesters: 

Icing can be a significant hazard for aviation operations of all 
types, including commercial flights.[Footnote 1] As shown in figure 1, 
when there is ice on an aircraft's wings, it can disrupt the smooth 
flow of air over the wings and prevent the aircraft from safely taking 
off or decrease the pilot's ability to control the aircraft in flight. 
Depending on the location of the ice, the shape of the wing, and the 
phase of flight, even small, almost imperceptible amounts of ice can 
have a significant detrimental effect. Despite a variety of 
technologies designed to prevent ice from forming on wings or other 
critical surfaces or to remove ice that has formed, as well as 
persistent efforts by the Federal Aviation Administration (FAA) and 
other stakeholders to mitigate icing risks, icing remains a concern. 
Furthermore, runways that have not been cleared of snow or ice 
(referred to as contaminated runways) can be hazardously slick for 
planes during takeoff and landing. 

Figure 1: Effect of Ice Build-up on Aircraft Wings: 

[Refer to PDF for image: illustration] 

Normal conditions: 
In normal conditions, air flows smoothly over the wings, creating lift. 

When icing occurs: 
Ice disrupts smooth airflow on a wing, increasing drag and decreasing 
lift. 

Sources: GAO and FAA. 

[End of figure] 

This report describes the risks to aviation safety posed by icing and 
winter weather conditions and the steps taken and challenges faced by 
aviation stakeholders in their efforts to mitigate those risks. As 
such, we reviewed (1) the extent to which large commercial airplanes 
have experienced accidents and incidents related to icing and 
contaminated runways, (2) FAA's inspection and enforcement activities 
related to icing, (3) the efforts of FAA and other aviation 
stakeholders to improve safety in icing and winter weather operating 
conditions, and (4) the challenges that continue to affect aviation 
safety in icing and winter weather operating conditions. 

To review the extent to which large commercial airplanes have 
experienced accidents and incidents related to icing and contaminated 
runways, we analyzed data obtained from FAA, the National 
Transportation Safety Board (NTSB), and the National Aeronautics and 
Space Administration (NASA). To review FAA's inspection and 
enforcement activities related to icing we obtained FAA's inspection 
and enforcement policies and analyzed data from FAA's inspection and 
enforcement databases. For example, we obtained data from FAA's Air 
Transportation Oversight System to assess the timeliness of FAA's 
inspections of large commercial carriers' ground deicing programs. To 
review FAA's efforts to improve safety in icing and winter weather 
operating conditions and the challenges that remain, we obtained 
information from FAA, NTSB, NASA, the National Oceanic and Atmospheric 
Administration (NOAA), and the National Center for Atmospheric 
Research (NCAR). In addition, we interviewed representatives from the 
Flight Safety Foundation, an academic expert, and a diverse group of 
aviation industry stakeholders and associations.[Footnote 2] We 
provided a draft of this report to the Department of Transportation 
(which contains FAA), the Department of Commerce (which contains 
NOAA), NTSB, NASA, and the National Science Foundation (which contains 
NCAR) for their review and incorporated their comments as appropriate. 

We performed this work from August 2009 to July 2010 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. Further, we assessed the 
reliability of the data used in this report and determined that the 
data were sufficiently reliable for our purposes. To assess the 
reliability of the inspection and enforcement data that we received 
from FAA, we performed electronic testing of the data elements that we 
used, obtained and reviewed documentation about the data and the 
systems that produced them, and interviewed knowledgeable FAA 
officials. To assess the reliability of the accident data we received 
from NTSB and the incident data we received from FAA and NASA, we 
obtained and reviewed documentation about the data and the systems 
that produced them. Appendix I contains a more detailed discussion of 
our objectives, scope, and methodology, including a complete list of 
industry stakeholders we interviewed. 

Background: 

Deicing operations include removing ice from aircraft, applying 
chemicals to prevent initial icing or further icing (anti-icing), and 
removing (and preventing) ice from airfield pavement (runways, 
taxiways, aprons, and ramps). Prior to departure, the removal of ice, 
snow, slush, or frost from an aircraft's critical surfaces can be 
accomplished by mechanical means, using heat, using a heated fluid, 
using forced air, or a combination thereof. When frost, snow, or ice 
adheres to an aircraft surface, the surface must be heated or sprayed 
with pressurized fluid to remove the contaminant. Anti-icing on the 
ground is accomplished by applying a freezing point depressant to a 
surface either following deicing or in anticipation of subsequent 
winter precipitation; it is intended to protect the critical surfaces 
from ice adherence for a limited period of time. The fluid is capable 
of absorbing freezing or frozen precipitation until the fluid freezing 
point coincides with the ambient temperature. Once this fluid freezing 
point has been reached, the fluid can no longer protect the aircraft 
from ground icing conditions. During in-flight operations, an anti- 
icing system is expected to keep ice from forming in all but severe 
icing conditions and is accomplished with the use of engine bleed air, 
electro-thermal heaters, or fluid freezing point depressants. Table 1 
describes the tools and processes used for ground deicing and anti- 
icing procedures on aircraft; table 2 describes systems found on 
aircraft for in-flight ice protection. 

Table 1: Description of Tools and Processes Used for Ground Deicing 
and Anti-Icing: 

Anti-ice and deicing fluid application: 
Prior to takeoff, deicing and anti-icing fluids are used to remove ice 
from the aircraft and to prevent future ice formation. Once anti-icing 
fluids are applied to an aircraft, the aircraft has a finite amount of 
time--known as a holdover time--that the fluid will remain effective. 
These holdover times are established as a guide for the amount of time 
anti-icing fluid will provide protection. Deicing facilities can be 
located at the terminal area or at "centralized deicing pads" which 
restrict aircraft deicing to a specific area, minimizing the volume of 
deicing waste water and allowing for the capture of deicing waste. 

Infrared heat deicing: 
A method of deicing using infrared thermal energy. Aircraft using this 
method enter a drive-through structure designed to rapidly melt the 
accumulated ice, frost and snow off all critical surfaces of the 
aircraft. As a result, the aircraft come out of the system clean and 
dry. Currently, such systems are in place at two airports: 
Rhinelander, Wisconsin, and John F. Kennedy Airport in New York. The 
infrared system is powered by natural gas and thought to be less 
harmful to the environment than the use of deicing fluid. These 
systems can handle any size aircraft and are fully automated. After 
the aircraft goes through the infrared deicing process, a small amount 
of anti-icing fluid is applied to the plane so that new ice does not 
develop prior to takeoff. 

Forced air deicing: 
A method of deicing using forced air to blow frozen contaminants off 
an aircraft surface. Some forced air deicing systems use high-pressure 
air or a mix of air and deicing fluid, while others are based on 
delivering large air volumes at low pressure. 

Critical surface inspection: 
A critical surface inspection is a preflight external inspection of 
critical surfaces conducted by a qualified person, to determine if 
they are contaminated by frost, ice, snow or slush. This inspection is 
mandatory whenever ground icing conditions exist and, if the aircraft 
is deiced with fluid, must take place immediately after the final 
application of fluid, or when an approved alternative method of 
deicing is used, upon completion of this process. After the 
inspection, a report completed by a qualified individual must be 
submitted to the pilot-in-command. 

Source: GAO analysis of NASA and industry information. 

[End of table] 

Table 2: Description of Aircraft Systems for In-flight Ice Protection: 

Pneumatic deicers: 
A common deicing system uses pneumatically inflated rubber boots on 
the leading edges of airfoil surfaces, typically including the leading 
edges of the wings and tail surfaces. The system uses relatively low 
pressure air to rapidly inflate and deflate the boot. This is usually 
done in a sequence of segments--for example, the outer wings followed 
by the inner wings followed by the horizontal stabilizer. Depending on 
the manufacturer's specifications, the system may be operated either 
automatically, through a timing circuit, or manually, using a cockpit 
control to initiate the boot cycle sequence. 

Weeping wing: 
An anti-icing system that pumps fluid from a reservoir through a 
porous panel embedded in the leading edges of the wings and tail. 
Activated by a switch in the cockpit, the liquid flows all over the 
wing and tail surfaces, anti-icing as it flows. It can also be applied 
to the prop and the windshield. 

Thermal systems: 
Some aircraft use electronically heated surfaces on critical 
components of the aircraft (e.g., windshield, pitot/static tubes, and 
propeller blades). These systems operate in-flight to rid the aircraft 
of ice buildup and to prevent ice accumulation. Large aircraft may use 
a hot "bleed air system" from the compressor stages of a turbine 
engine to periodically break the bond between accreted ice and the 
surface of the airframe.[A] 

Source: GAO analysis of NASA, the Aircraft Owners and Pilots 
Association, and industry information. 

[A] Ice accretion is the process by which a layer of ice builds up on 
solid objects that are exposed to weather conditions such as freezing 
precipitation. 

[End of table] 

FAA issues regulations, airworthiness directives, and other guidance 
and monitors industry compliance as part of its mission to ensure 
safe, orderly, and efficient air travel in the national airspace 
system. FAA regulations contain a number of parts, and different parts 
apply to aircraft based on their size and type and the activities they 
are used for. In this report we use the term "large commercial 
airplanes" to refer to those airplanes operating under part 121 of 
title 14 of the United States Code of Federal Regulations. Among other 
things, part 121 applies to air carrier operations involving turbojet 
airplanes or any airplane with a seating capacity of more than nine 
passenger seats or a maximum payload capacity of more than 7,500 
pounds. We use the term "small commercial airplanes" to refer to those 
airplanes operating under part 135 of title 14. Among other things, 
part 135 covers certain commuter and on-demand operations on 
airplanes, other than turbojet powered airplanes, with nine passenger 
seats or less, and a payload capacity of 7,500 pounds or less. Some 
commuter and most air tour operators and medical services (when a 
patient is on board) fall under the purview of part 135. By 
"noncommercial airplanes," we mean airplanes that are privately 
operated under part 91 of title 14. These types of operations are 
often referred to as "general aviation" and include, among other 
things, flights for recreation and training and certain business 
flights. Although noncommercial flights usually involve small 
aircraft, the definition we are using depends on the nature of the 
operation, not the size of the aircraft. 

In developing regulations, FAA follows the rulemaking process used by 
all federal agencies, which is established in the Administrative 
Procedure Act (APA).[Footnote 3] This act establishes procedures and 
broadly applicable federal requirements for informal rulemaking, also 
known as notice and comment rulemaking. This process is designed to 
provide the opportunity for public participation in rulemakings by 
submission of written comments and to ensure that all aspects of any 
regulatory change are fully analyzed before the change goes into 
effect. Starting early in a rulemaking, FAA may seek input from its 
Aviation Rulemaking Advisory Committee (ARAC), and during the course 
of a rulemaking it may conduct research related to the rulemaking. In 
addition, the APA generally requires agencies to publish a notice of 
proposed rulemaking in the Federal Register. During the public comment 
period that follows the publication of the proposed rule, interested 
parties may submit written comments, which FAA examines and may 
consider when making any changes before publishing the final rule. The 
final rule is then incorporated into the United States Code of Federal 
Regulations, but it may not take effect immediately. For example, FAA 
may phase in requirements over time or it may give industry time-- 
sometimes several years--to implement changes. 

FAA can also issue airworthiness directives.[Footnote 4] An 
airworthiness directive is a legally enforceable rule that may apply 
to an aircraft or its parts, such as engines and propellers. FAA 
issues an airworthiness directive when it determines that (1) an 
unsafe condition exists in the product and (2) the condition is likely 
to exist or develop in other products of the same type design. 

NTSB investigates and reports on civil aviation accidents, which it 
defines as occurrences whereby a person suffers death or serious 
injury, or in which the aircraft receives substantial damage. FAA and 
NTSB also investigate aviation incidents, which NTSB defines as 
occurrences other than an accident associated with the operation of an 
aircraft that affects or could affect the safety of operations. FAA 
maintains an incident database generated by its investigations. NASA 
also administers a voluntary reporting system on aviation incidents, 
called the Aviation Safety Reporting System (ASRS). It contains 
voluntary reports, which are later de-identified, from pilots, 
controllers, maintenance technicians, and other operating personnel 
about human behavior that resulted in unsafe occurrences or hazardous 
situations. NASA seeks to avoid double counting of incidents by 
ensuring that multiple reports for a single incident are grouped 
together under that incident. Because ASRS reporting is voluntary, it 
is unlikely to cover the universe of safety events. It is also 
possible that ASRS incident data may overlap with FAA incident data 
because a single incident may be entered into FAA's incident database 
by an FAA inspector and reported to ASRS by a pilot or bystander. 
However, the extent to which overlap occurs is unknown. 

When airlines and airports conduct deicing operations on aircraft and 
airfield pavement, the large amounts of chemicals used for deicing 
operations may drain off airport facilities to nearby rivers, lakes, 
streams, and bays and can have major impacts on water quality. In 
August 2009, the Environmental Protection Agency (EPA) issued a 
proposed rule on the use of deicing fluids at airports.[Footnote 5] 
According to EPA, the proposed rule would require 218 airports to 
collect spent deicing fluid and treat the associated wastewater, and 6 
major airports would likely need to install centralized deicing pads 
to comply with the rule. Additionally, some airports would be required 
to reduce the amount of ammonia discharged from urea-based airfield 
pavement deicers or use more environmentally friendly airfield deicers 
that do not contain urea.[Footnote 6] EPA plans to issue a final rule 
in December 2010. 

Although Large Commercial Airplanes Have Experienced Few Icing-Related 
Accidents Since 1998, the Many Reported Icing Incidents Suggest That 
Icing Is an Ongoing Risk to Aviation Safety: 

According to NTSB's aviation accident database, from 1998 to 2009 one 
large commercial airplane was involved in a nonfatal accident after 
encountering icing conditions during flight and five large commercial 
airplanes were involved in nonfatal accidents related to snow or ice 
on runways. Although there have been few accidents, FAA and others 
recognize that incidents are potential precursors to accidents. Data 
on hundreds of incidents that occurred during this period reveal that 
icing, contaminated runways, and other winter weather conditions pose 
substantial risk to aviation safety. FAA's database of incidents 
includes 120 incidents related to icing, contaminated runways, 
taxiways, or ramps, or other winter weather conditions involving large 
commercial airplanes that occurred from 1998 through 2007.[Footnote 7] 
These data covered a broad set of events, such as the collision of two 
airplanes at an ice-covered gate, and an airplane that hit the right 
main gear against the runway and scraped the left wing down the runway 
for about 63 feet while attempting to land with ice accumulation on 
the airplane. During this same time period, NASA's ASRS received over 
600 icing and winter weather-related incident reports involving large 
commercial airplanes. These incidents reveal a variety of safety 
issues such as runways contaminated by snow or ice, ground deicing 
problems, and in-flight icing encounters. These incidents thus also 
suggest that risks from icing and other winter weather operating 
conditions may be greater than indicated by NTSB's accident database 
and by FAA's incident database. FAA officials point out that there is 
no defined reporting threshold for ASRS reports and because they are 
developed from personal narrative, they can be subjective. However, 
these officials agree that the ASRS events must be thoroughly reviewed 
and evaluated for content to determine the relevancy to icing and the 
extent and severity of the safety issue. The contents of the ASRS data 
system also demonstrate the importance of aggregating data from all 
available sources to understand a safety concern. See table 3 for the 
number of icing and winter weather-related incident reports from ASRS 
for large commercial airplanes. 

Table 3: Icing and Winter Weather-Related Incident Reports for Large 
Commercial Airplanes by Category of Incident, 1998 to 2007: 

Category: Anti-icing or deicing incident/procedure[A]; 
Number of reports: 179. 

Category: Controllability issue--ground; 
Number of reports: 72. 

Category: In-flight encounter--aircraft equipment problems; 
Number of reports: 72. 

Category: In-flight encounter--airframe and/or flight control icing; 
Number of reports: 69. 

Category: Other winter weather incident; 
Number of reports: 42. 

Category: Surface marking and signage obstruction; 
Number of reports: 41. 

Category: Runway, ramp, or taxiway excursion[B]; 
Number of reports: 36. 

Category: Runway, ramp, or taxiway incursion[C]; 
Number of reports: 34. 

Category: Controllability issue--air; 
Number of reports: 32. 

Category: Maintenance incident; 
Number of reports: 19. 

Category: Ramp safety--personnel risk or injury; 
Number of reports: 17. 

Category: In-flight encounter--sensor type incident; 
Number of reports: 15. 

Category: Total; 
Number of reports: 628. 

Source: GAO analysis of NASA ASRS data on incidents due to winter 
weather conditions. 

[A] An anti-icing or deicing incident/procedure is an event involving 
the process of preventing or removing accumulations of ice, snow, 
frost, etc., on aircraft critical surfaces by means of aircraft 
equipment deployment or application of specified fluids. Anti-icing 
means that ice, snow, or frost formation was prevented, either by on- 
ground means or by aircraft equipment in flight. Deicing means that 
ice, snow, or frost was removed, either by on-ground means or by 
aircraft equipment in flight. 

[B] An excursion occurs when an aircraft unintentionally exits a 
runway, ramp, or taxiway. 

[C] An incursion occurs when an aircraft enters a runway, ramp, or 
taxiway without authorization. 

[End of table] 

While our review focused on large commercial airplanes, small 
commercial airplanes and noncommercial airplanes experienced more 
icing-related accidents and fatalities than did large commercial 
airplanes from 1998 to 2007, as shown in table 4. They did so largely 
because, compared to large commercial airplanes, small commercial 
airplanes and noncommercial airplanes (1) may be performance-limited 
and therefore operate for longer periods at lower altitudes that more 
frequently have icing conditions, (2) have a higher icing collection 
efficiency due to their smaller scale, (3) are more greatly impacted 
by ice as a result of their smaller scale, (4) tend to have deicing 
equipment (e.g., pneumatic deicing boots) rather than fully 
evaporative anti-icing equipment, and (5) may not be approved for 
flight in known icing conditions. If an airplane is not approved for 
flight in icing conditions, it may either not have an ice protection 
system installed, or it may have an ice protection system that is not 
certified. 

Table 4: Icing and Winter Weather-Related Accidents and Fatalities for 
1998 to 2009, Incidents from 1998 to 2007: 

Icing-related accidents, including in-flight and runway: 
Large commercial airplanes: 6; 
Small commercial airplanes: 49; 
Noncommercial airplanes: 510. 

Fatalities in icing-related accidents: 
Large commercial airplanes: 0; 
Small commercial airplanes: 27; 
Noncommercial airplanes: 202. 

Icing-related incidents in FAA's database: 
Large commercial airplanes: 120; 
Small commercial airplanes: 86; 
Noncommercial airplanes: 319. 

Icing-related incidents in NASA's ASRS database: 
Large commercial airplanes: 628; 
Small commercial airplanes: 102; 
Noncommercial airplanes: 422. 

Sources: GAO analysis of NTSB data for accidents and fatalities; GAO 
analysis of FAA and NASA data for incidents. 

Notes: For all three types of airplanes, accident data for 2008 and 
2009 are incomplete because NTSB has not completed all of its accident 
investigations that occurred during those years. For small commercial 
and noncommercial airplanes, the number of accidents and incidents 
also includes carburetor icing. 

In December 2005, a passenger jet landed on a snowy runway at 
Chicago's Midway Airport, rolled through an airport perimeter fence 
onto an adjacent roadway, and struck an automobile, killing a child 
and injuring 4 other occupants of the automobile and 18 airline 
passengers. NTSB concluded that the probable cause of the accident was 
not related to icing or winter weather, but rather to the pilot's 
failure to use available reverse thrust in a timely manner to safely 
slow or stop the airplane after landing, which resulted in a runway 
overrun. 

[End of table] 

FAA Largely Met Its Own Inspection Requirements Related to Icing: 

As part of its Air Transportation Oversight System (ATOS), FAA 
assesses large carriers' ground deicing programs to ensure that they 
meet relevant safety regulations.[Footnote 8] FAA requires itself to 
assess the design of each carrier's program twice every 5 years, with 
one of the assessments focused on ground crews and the other on flight 
crews. FAA also requires itself to assess the performance of each 
carrier's program twice each year, again with one assessment focused 
on ground crews and the other on flight crews. Design assessments 
ensure that an air carrier's operating systems comply with regulations 
and safety standards. Performance assessments confirm that an air 
carrier's operating systems produce intended results, including 
mitigation or control of hazards and associated risks. FAA bases each 
assessment of a carrier's performance on multiple inspections, which 
are typically conducted at several of the various locations where the 
carrier operates.[Footnote 9] FAA considers assessments to be on-time 
if they are completed within 30 days of the end of the quarter in 
which they are scheduled for completion. From December 2007, when it 
first completed these assessments, through fiscal year 2009, FAA 
completed 103 of 108 design assessments on time (95 percent) and 303 
of 315 required performance assessments on time (96 percent). 

While this review focused on FAA's inspections related to ground 
deicing, the Department of Transportation Inspector General (IG) in 
March 2010 issued an initial report based on its broader ongoing 
review of FAA's inspections under ATOS.[Footnote 10] The IG reported 
that FAA does not have an effective process for ensuring the timely 
completion of inspections. In particular, the IG found that FAA does 
not assign inspectors to all scheduled inspections, does not 
nationally track these unassigned inspections, and that these 
inspections could therefore "remain uncompleted for months or even 
years, and any associated risks within air carrier programs would 
remain unknown." The IG plans to issue a subsequent report with 
recommendations to FAA later this year. 

For each design or performance inspection, an FAA inspector answers a 
series of questions about whether the carrier is in compliance with 
FAA's safety requirements. For inspections of large commercial 
carriers' ground deicing programs focused on ground crews in fiscal 
years 2005 through 2009, FAA inspectors indicated that carriers were 
meeting the requirement in 16,867 out of 20,513 cases (82 percent), 
were not meeting the requirement in 3,569 cases (17 percent), and that 
the question was not applicable in 77 cases (0.4 percent). For 
inspections of large commercial carriers' ground deicing programs 
focused on flight crews in fiscal years 2005 through 2009, FAA 
inspectors indicated that carriers were meeting the requirement in 
13,734 out of 16,266 cases (84 percent), were not meeting the 
requirement in 2,122 cases (13 percent), and that the question was not 
applicable in 410 cases (3 percent). 

For each design and performance assessment, FAA scores the carrier on 
a six-part scale ranging from "no issues observed--no action required" 
to "persistent, systemic safety and/or regulatory issues observed--
system reconfiguration by air carrier required." Of the 423 
assessments following inspections of ground deicing programs that FAA 
completed from December 2007 through the end of fiscal year 2009, 290 
(69 percent) did not require any corrective action by the carrier, 
while 133 (31 percent) required some form of corrective action. Table 
5 presents additional information on the results of these assessments. 

Table 5: Assessment Results of FAA's Inspections of Large Commercial 
Carriers' Ground Deicing Programs (December 2007 through End of Fiscal 
Year 2009): 

Assessment result: No issues observed--no action required; 
Number of assessments: 221; 
Percent: 52. 

Assessment result: Minor issues observed--no action required; 
Number of assessments: 69; 
Percent: 16. 

Assessment result: Minor issues observed--action required; 
Number of assessments: 65; 
Percent: 15. 

Assessment result: Issues of concern observed--action required; 
Number of assessments: 40; 
Percent: 9. 

Assessment result: Safety and/or regulatory issues observed--action 
required; 
Number of assessments: 26; 
Percent: 6. 

Assessment result: Persistent, systemic safety and/or regulatory 
issues observed--system reconfiguration by air carrier or applicant is 
required; 
Number of assessments: 2; 
Percent: Less than 1. 

Assessment result: Total; 
Number of assessments: 423; 
Percent: 100. 

Source: GAO analysis of FAA data. 

Note: Percents do not sum to 100 percent due to rounding. 

[End of table] 

Carriers generally did better on the performance assessments than the 
design assessments. Carriers also generally did better on the 
assessments related to flight crews than on those related to ground 
crews. Figure 2 presents additional details on the assessment results 
of FAA's ground deicing inspections. 

Figure 2: Assessment Results of FAA's Inspections of Large Commercial 
Carriers' Ground Deicing Programs by Type of Inspection (December 2007 
through End of Fiscal Year 2009): 

[Refer to PDF for image: horizontal bar graph] 

FAA assessment result: No issues observed - no action required; 
Design inspections - ground crews: 23.1%; 
Design inspections - flight crews: 37.5%; 
Performance inspections - ground crews: 50.6%; 
Performance inspections - flight crews: 69.3%. 

FAA assessment result: Minor issues observed - no action required; 
Design inspections - ground crews: 23.1%; 
Design inspections - flight crews: 10.7%; 
Performance inspections - ground crews: 19.1%; 
Performance inspections - flight crews: 13.1%. 

FAA assessment result: Minor issues observed - action required; 
Design inspections - ground crews: 30.8%; 
Design inspections - flight crews: 35.7%; 
Performance inspections - ground crews: 12.3%; 
Performance inspections - flight crews: 5.9%. 

FAA assessment result: Issues of concern observed - action required; 
Design inspections - ground crews: 13.5%; 
Design inspections - flight crews: 5.4%; 
Performance inspections - ground crews: 10.5%; 
Performance inspections - flight crews: 8.5%. 

FAA assessment result: Safety and/or regulatory issues observed - 
action required; 
Design inspections - ground crews: 9.6%; 
Design inspections - flight crews: 10.7%; 
Performance inspections - ground crews: 7.4%; 
Performance inspections - flight crews: 2%. 

FAA assessment result: Persistent, systemic safety and/or regulatory 
issues observed - system reconfiguration by air carrier or applicant 
required; 
Design inspections - ground crews: 0; 
Design inspections - flight crews: 0; 
Performance inspections - ground crews: 0; 
Performance inspections - flight crews: 1.3%. 

Source: GAO analysis of FAA data. 

[End of figure] 

Because not all large commercial carriers were covered by ATOS until 
April 2008, FAA also inspected some large commercial carriers' ground 
deicing programs under the agency's National Work Program Guidelines 
(NPG). FAA's policy was to conduct these inspections of each carrier 
once a year. In fiscal years 2005 and 2006, FAA completed 327 out of 
345 required inspections (95 percent) of large commercial carriers' 
ground deicing programs under NPG. An FAA official told us that 
resource constraints prevented the agency from being able to complete 
all the required inspections, and that some were not completed under 
NPG because the carriers were transitioned to ATOS. In fiscal years 
2007 and 2008, FAA conducted far fewer of these inspections as the 
agency completed its transitioning of large commercial carriers from 
NPG to ATOS. Under NPG, FAA also plans additional inspections of some 
carriers on an "as resources allow" basis, and conducts other 
additional inspections that were not planned. In fiscal years 2005 
through 2009, FAA completed 3,757 out of 3,946 planned inspections (95 
percent) of large commercial carriers' ground deicing programs under 
NPG, and it completed an additional 1,704 inspections that were not 
planned. 

When FAA determines that a carrier has violated a safety regulation 
(through inspections or other means such as accident investigations or 
public complaints), the agency can take enforcement action against the 
carrier, which may include imposing monetary fines or temporarily or 
permanently shutting down the carrier's operations.[Footnote 11] In 
fiscal years 2005 through 2009, FAA initiated enforcement actions 
against large commercial carriers in 274 cases following one or more 
violations of icing-related regulations. FAA had closed 254 of these 
actions by March 2010; of these, 226 were administrative actions, such 
as letters to carriers specifying required corrective actions; 22 were 
monetary fines, with a median amount of $20,000 and ranging from $675 
to $175,000; 3 were closed with no action taken; 2 were suspensions of 
operating certificates, 1 for 60 days and the other for 90 days; and 1 
was a revocation of an operating certificate. 

FAA also inspects commercial carriers that operate small airplanes 
(small commercial carriers) to check whether they are complying with 
FAA's safety regulations. For inspections that cover areas that FAA 
deems critical to safety, including ground deicing programs, FAA 
requires that each carrier be inspected once every 12 months. For less 
critical areas, FAA establishes inspection annual plans for each 
carrier that includes what the agency believes are the most important 
areas for that carrier. In fiscal years 2005 through 2009, FAA 
completed 942 of 1,026 required inspections (92 percent) of small 
commercial carriers' ground deicing programs. In addition, over the 
same time period, FAA completed 2,029 out of 2,099 planned inspections 
(97 percent) of small commercial carriers' ground deicing programs 
under NPG, and it completed an additional 431 inspections that were 
not planned. 

In fiscal years 2005 through 2009, FAA initiated enforcement actions 
against small commercial carriers in 274 cases following one or more 
violations of icing-related regulations. FAA had closed 209 of these 
actions by March 2010; of these, 112 were administrative actions, such 
as letters to carriers specifying required corrective actions; 29 were 
monetary fines, with a median amount of $5,800 and ranging from $1,000 
to $186,150; 28 were closed with no action taken; 28 were suspensions 
of operating certificates, with a median duration of 60 days and 
ranging from 7 to 270 days; and 12 were revocations of operating 
certificates. 

In fiscal years 2005 through 2009, FAA completed 256 inspections 
covering icing-related requirements of private operators, 2 of which 
were required, 125 of which were planned, and 129 of which were not 
planned. During this time period, FAA did not take any enforcement 
actions against private operators related to violations of icing- 
related regulations. 

FAA and Other Aviation Stakeholders Have Undertaken a Variety of 
Efforts Aimed at Improving Safety in Icing and Winter Weather 
Conditions: 

FAA and others have undertaken many efforts to improve safety in icing 
and winter weather conditions. In addition to conducting inspection 
and enforcement activities as we previously described, FAA's efforts 
include issuing a multiyear plan in 1997 related to in-flight icing 
and providing funding for icing-related purposes. Other government 
entities that have taken steps to increase aviation safety in icing 
conditions include NTSB, which has issued numerous recommendations as 
a result of its aviation accident investigations, and NASA, which has 
contributed to research related to icing. In addition, the private 
sector has deployed various FAA-required technologies on aircraft, 
such as wing deicers and ice detectors, and operated ground deicing 
and runway clearing programs at airports. 

FAA Has Taken Actions to Implement Objectives of a Safety Plan Issued 
in 1997, but Information about Recent Initiatives to Promote Safety in 
Icing Conditions Has Not Been Readily Accessible: 

Following the 1994 fatal crash of American Eagle Flight 4184 in 
Roselawn, Indiana, FAA issued a multiyear plan in 1997 for improving 
the safety of aircraft flying in icing conditions.[Footnote 12] FAA 
distributed the plan to a broad range of aviation stakeholders, 
including airlines, airports, and pilot organizations, asking for 
their support in implementing the plan. It also posted the plan on its 
public Web site, and it created an icing steering committee to monitor 
the progress of the planned activities. The steering committee is 
composed of FAA icing specialists who work together to resolve 
aircraft icing issues. 

Over the last decade, FAA made progress on the implementation of the 
objectives specified in its multiyear plan by issuing or amending 
regulations, airworthiness directives, and voluntary guidance to 
provide icing-related safety oversight. For example: 

* In August 2007, FAA issued a final rule for new airworthiness 
standards to establish comprehensive requirements for the performance 
and handling characteristics of transport category airplanes in icing 
conditions.[Footnote 13] 

* In January 2009, FAA also issued a proposed rule that would amend 
the regulations for crewmember and dispatcher training programs, 
requiring many new training elements and procedures for air carriers 
including some relevant to icing training.[Footnote 14] 

* In August 2009, FAA issued a final rule requiring a means to ensure 
timely activation of the ice protection system on transport category 
airplanes.[Footnote 15] 

* In November 2009, FAA issued a proposed rule that would require the 
timely activation of ice protection equipment on commercial aircraft 
during icing conditions and weather conditions conducive to airframe 
icing.[Footnote 16] 

* In June 2010, FAA issued a proposed rule to amend its standards for 
certain transport category airplanes and certain aircraft engines to 
address supercooled large droplet icing, ice crystal, and mixed phase 
icing conditions, which are outside the range of icing conditions 
covered by the current standards; FAA plans to issue the final rule by 
January 2012.[Footnote 17] 

* Since 1997, FAA has issued over 100 airworthiness directives to 
address icing safety issues involving more than 50 specific types of 
aircraft, including directives that require revising the FAA-Approved 
Airplane Flight Manual limitations to provide the flight crew with 
recognition cues and procedures for exiting severe icing conditions or 
inserting a copy of the airworthiness directive in the manual. 

* FAA has sponsored research and provided subsequent guidance material 
incorporating information on critical ice accretions that it believes 
has resulted in a significant increase in the level of safety of new 
airplanes. 

While FAA points to its actions to implement its 1997 plan as having 
contributed to a decline in icing-related accidents, the agency also 
acknowledges that additional steps were and still are needed to 
further reduce the risks that icing continues to pose to aviation 
safety. Since it issued the plan, FAA's icing steering committee has 
identified many additional actions to reduce risks from icing, such as 
researching and developing approaches to mitigate the risk of 
turboengine power loss from ice crystal ingestion. At our request, FAA 
provided us with a lengthy compilation of the tasks it is undertaking 
with respect to icing; however, its Inflight Aircraft Icing Plan has 
not been publicly updated since the initial release in 1997. FAA told 
us it has reported the status of key tasks in the icing plan to 
aviation stakeholders via different methods, such as during FAA Icing 
Conferences in 1999 and 2003; yet because FAA has not formally updated 
the plan, stakeholders do not have a consolidated and readily 
accessible source of information on the key in-flight icing actions 
FAA has under way or planned. Furthermore, because the plan only 
addresses initiatives related to in-flight icing, FAA is missing an 
opportunity to take a more holistic and coordinated approach to the 
broader range of issues related to winter weather, including ground 
icing and deicing and contaminated runways. 

While FAA's Inflight Aircraft Icing Plan does not cover ground icing, 
FAA officials said the agency has maintained a ground icing program 
whereby FAA provides guidance on ground winter operations on a yearly 
basis and conducts research on endurance times for deicing and anti- 
icing fluids. FAA said it also investigates new issues that may arise 
as a result of special industry concerns or changes in FAA policy. 
Regulations and guidance developed as a result of the ground icing 
program include a rule that no longer permits frost to be polished 
smooth on critical surfaces prior to takeoff and requires pilots to 
ensure that the wings of their aircraft are free of all frost prior to 
takeoff.[Footnote 18] 

FAA has also provided funding for a variety of icing-related purposes. 
For example, FAA has supported NASA research related to severe icing 
conditions and NCAR research related to weather and aircraft icing. 
Furthermore, FAA has provided almost $200 million to airports through 
the Airport Improvement Program (AIP) to construct deicing facilities 
and to acquire aircraft deicing equipment from 1999 to 2009. (See 
appendix II for a detailed listing of AIP icing-related funding by 
state, city, and year for 1999 to 2009.) Since runway safety is a key 
concern for aviation safety and especially critical during winter 
weather operations, FAA has also provided about $200 million per year 
in AIP funding for the creation of runway safety areas since 
2000.[Footnote 19] According to the Flight Safety Foundation, from 
1995 through 2008, 30 percent of global aviation accidents were runway-
related and "ineffective braking/runway contamination" is the fourth 
largest causal factor in runway excursions that occur during landing. 
In fiscal year 2000, FAA's Office of Airport Safety and Standards 
initiated a program to accelerate improvements in runway safety areas 
at commercial service airports that did not meet FAA design standards. 
According to FAA officials, of the 619 runways that FAA determined 
needed improvement, 465 (74 percent) have been completed and 154 (26 
percent) remain to be completed by 2015. The estimated cost to 
complete the remaining projects is about $835 million.[Footnote 20] In 
some cases where (1) land is not available, (2) it would be very 
expensive for the airport sponsors to buy land off the end of the 
runway, or (3) it is otherwise not possible to have the 1,000 foot 
safety area, FAA has approved the use of an Engineered Materials 
Arresting System (EMAS).[Footnote 21] FAA supports EMAS installations 
through AIP funding, and currently, EMAS installations have been 
completed for 44 runways at 30 airports in the United States, with 
seven more installations scheduled for 2010.[Footnote 22] To date 
there have been six successful EMAS captures of overrunning aircraft. 

Other Stakeholders Support and Augment FAA Efforts to Increase Safety 
in Icing and Winter Weather Conditions: 

Government and industry stakeholders, external to FAA, also contribute 
to the effort to increase aviation safety in icing and winter weather 
conditions. For example, as a result of its civil aviation accident 
investigations, NTSB issues safety recommendations to FAA and others, 
some of which it deems most critical and places on a list of "Most 
Wanted" recommendations.[Footnote 23] Since 1996, NTSB has issued 82 
recommendations to FAA aimed at reducing risks from in-flight 
structural icing, engine and aircraft component icing, runway 
condition and contamination, ground icing, and winter weather 
operations. NTSB's icing-related recommendations to FAA have called 
for FAA to, among other things, strengthen its requirements for 
certifying aircraft for flying in icing conditions, sponsor the 
development of weather forecasts that define locations with icing 
conditions, and enhance its training requirements for pilots. NTSB has 
closed 41 of these recommendations (50 percent) as having been 
implemented by FAA, and has classified another 22 (27 percent) as FAA 
having made acceptable progress.[Footnote 24] This combined 77 percent 
acceptance rate is similar to the rate for all of NTSB's aviation 
recommendations. A complete listing of and additional information on 
NTSB's icing-related recommendations made since 1996 can be viewed at 
GAO-10-679SP. 

For more than 30 years, NASA has conducted and sponsored fundamental 
and applied research related to icing. The research addresses icing 
causes, effects, and mitigations. For instance, NASA has conducted 
extensive research to characterize and simulate supercooled large 
droplet icing conditions to inform a pending FAA rule related to the 
topic. NASA participated in research activities, partially funded by 
FAA, that developed additional knowledge and strategies which allowed 
forecasters to more precisely locate supercooled large droplet icing 
conditions. Furthermore, NASA has an icing program, focused generally 
on research related to the effects of in-flight icing on airframes and 
engines for many types of flight vehicles. NASA has developed icing 
simulation capabilities that allow researchers, manufacturers, and 
certification authorities to better understand the growth and effects 
of ice on aircraft surfaces. NASA also produced a set of training 
materials for pilots operating in winter weather conditions. 

NOAA, the National Weather Service, and NCAR have efforts directed and 
funded by FAA related to predicting the location and severity of icing 
occurrences. The National Weather Service operates icing prediction 
systems and NCAR conducts research to determine more efficient methods 
to complete this task. In response to FAA's 1997 Inflight Aircraft 
Icing Plan, FAA sponsored NCAR's development of two in-flight icing 
weather products to improve icing diagnoses and forecasting. They are 
the (1) Current Icing Product (CIP), which combines satellite, radar, 
surface, lighting, and pilot report observations with model output to 
create a detailed three-dimensional diagnosis of the potential for the 
existence of icing, and (2) Forecast Icing Potential (FIP), which 
calculates the likelihood of icing and supercooled large droplet 
conditions. FIP allows meteorologists and airline dispatchers to 
advise pilots about icing hazards up to 12 hours in advance. The CIP 
and FIP are now fully operational and are available at NOAA's aviation 
weather Web site, as are maps showing advisories of severe and 
moderate icing conditions, pilot reports, and freezing-level graphics. 
FAA has also supported the development and use of operationally 
available sensors. Observational datasets from those sensors are used 
in the CIP algorithm. 

In commenting on a draft of this report, the National Science 
Foundation said that members from the Aircraft Icing Research Alliance 
(AIRA) conduct a significant amount of icing-related research in a 
collaborative manner. According to the AIRA Web site, its members 
include NASA; Environment Canada; Transport Canada; National Research 
Council, Canada; FAA; NOAA; National Defence, Canada; and Defence 
Science and Technology Laboratory, United Kingdom. AIRA's mission is 
to coordinate among the parties the conduct of collaborative aircraft 
icing research activities that improve the safety of aircraft 
operations in icing conditions. 

The private sector has also contributed to efforts to prevent 
accidents and incidents related to icing and winter weather 
conditions, as required by FAA. For example, as shown in figure 3, 
aircraft manufacturers have deployed various technologies such as wing 
deicers, anti-icing systems, and heated wings. In addition, airports 
operate ground deicing and runway clearing programs that help ensure 
clean wings (see figure 4) and runways. 

Figure 3: Aircraft Ice Protection Systems: 

[Refer to PDF for image: aircraft illustration] 

Depicted on the illustration are the following: 

Windshield wipers; 
Bypass duct deicer; 
Pneumatic leading edge deicers; 
Electronically heated propellor blade deicers; Electronically heated 
windshield; 
Pneumatic engine inlet lip deicer; 
Electronically heated pitot/static tubes; 
TAT sensor. 

Source: GAO, based on information from NTSB. 

Notes: Pneumatic leading edge deicers are inflatable rubber "boots" on 
the leading edges of airfoil surfaces (including wings, horizontal 
stabilizers, and vertical stabilizers) that can be rapidly inflated 
and deflated with air pressure to break up ice accumulation. Similar 
technology is used for the pneumatic engine inlet lip deicer (the 
engine inlet lip is the edge of the opening through which air enters 
the engine), and the bypass duct deicer (in turbofan engines, the 
bypass duct channels the outer airflow past the core engine, 
minimizing large inertia objects such as snow, ice, and water drops 
from entering the engine). The TAT (Total Air Temperature) sensor 
helps the pilot determine critical flight parameters such as true 
airspeed computation and static air temperature. Electronically heated 
propeller blade deicers, windshield, and pitot/static tubes operate in-
flight to rid the aircraft of ice buildup and to prevent ice 
accumulation. 

[End of figure] 

Figure 4: Example of Ground Deicing to Help Ensure Clean Aircraft: 

[Refer to PDF for image: photograph] 

Source: Gerald R. Ford International Airport. 

[End of figure] 

Continued Attention to Regulation, Training, and Coordination Issues 
Could Further Mitigate the Risks of Winter Weather Operations: 

While FAA and others are undertaking efforts to mitigate the risks of 
aircraft icing and winter weather operations, through our interviews 
and discussions with government and industry stakeholders, we have 
identified challenges related to these risks that, if addressed by 
ongoing or planned efforts, could improve aviation safety. These 
challenges include (1) improving the timeliness of FAA's winter 
weather rulemaking efforts; (2) ensuring the availability of adequate 
resources for icing-related research and development (R&D); (3) 
ensuring that pilot training is thorough, relevant, and realistic; (4) 
ensuring the collection and distribution of timely and accurate 
weather information; (5) addressing the environmental impacts of 
deicing fluids; and (6) developing a more integrated approach to 
effectively manage winter operations. 

Improving the timeliness of FAA's winter weather rulemaking efforts. 
FAA's rulemaking, like that of other federal agencies, is a 
complicated, multistep process that can take many years. One purpose 
of the rulemaking process is to ensure that all aspects of any 
regulatory change are fully analyzed before the change goes into 
effect. To begin a rulemaking, FAA may seek input from ARAC,[Footnote 
25] and it may conduct research and development to enhance existing 
technologies or to introduce new technologies. NTSB, the Air Transport 
Association, and other stakeholders have recognized that such research 
and development can be time-consuming. In addition, FAA generally is 
required to develop and publish each rule in the Federal Register--
first as a proposed rule and then as a final rule.[Footnote 26] During 
the public comment period that follows the publication of the proposed 
rule, interested parties may submit written comments, which FAA 
examines and may consider when making any changes before publishing 
the final rule. The final rule is then incorporated into the United 
States Code of Federal Regulations, but it may not take effect 
immediately. For example, FAA may phase in requirements over time or 
it may give industry time--sometimes several years--to implement 
changes. Figure 5 provides an overview of the federal rulemaking 
process as it applies to FAA. 

Figure 5: FAA's Rulemaking Process for Significant Rules: 

[Refer to PDF for image: Process illustration] 

Identify need for rulemaking: 

Internal sources of rulemaking efforts: FAA Administrator, program 
offices, Office of General Counsel, Office of the Secretary of 
Transportation (OST). 

External sources of rulemaking efforts: The Congress, President, 
National Transportation Safety Board, the public, industry. 

Develop proposed rule: 

* Initiate rulemaking, draft proposal, obtain management approval; 

* Draft, review, approve proposed rule; 

* OST review; 

* Office of Management and Budget review; 

* Publish proposed rule in the Federal Register; 

* Start of public comment period. 

Public comment period. 

Develop final rule: 

* End of public comment period; 

* Analyze and address comments; draft, review, approve final rule; 

* OST review; 

* Office of Management and Budget review; 

* Publish final rule in the Federal Register. 

Source: Based on FAA’s Rulemaking Manual, Dec. 1998. 

Notes: Executive Order 12866 (58 Fed. Reg. 51735, September 30, 1993) 
defines "regulatory action" as any substantive action by an agency 
that promulgates or is expected to lead to the promulgation of a final 
rule or regulation, including notices of inquiry, advance notices of 
proposed rulemaking, and notices of proposed rulemaking. The executive 
order defines a "significant" rulemaking as, among other things, one 
that is likely to result in a rule that may have an annual effect on 
the economy of $100 million or more or adversely affect in a material 
way the economy, a sector of the economy, productivity, competition, 
jobs, the environment, public health or safety, or state, local, or 
tribal governments or communities. The order states that agencies 
should submit detailed cost-benefit analyses to the Office of 
Management and Budget for all economically significant rulemakings. 

[End of figure] 

NTSB, FAA, and we have previously expressed concerns about the 
efficiency and timeliness of FAA's rulemaking efforts. In 2001, we 
reported that a major reform effort begun by FAA in 1998 did not solve 
long-standing problems with its rulemaking process, as indicated both 
by the lack of improvement in the time required to complete the 
rulemaking process and by the agency's inability to consistently meet 
the time frames imposed by statute or its own guidance.[Footnote 27] 
External pressures--such as highly-publicized accidents, 
recommendations by NTSB, and congressional mandates--as well as 
internal pressures, such as changes in management's emphasis, 
continued to add to and shift the agency's priorities. For some rules, 
difficult policy issues continued to remain unresolved late in the 
process. Our 2001 report contained 10 recommendations designed to 
improve the efficiency of FAA's rulemaking through, among other 
things, (1) more timely and effective participation in decision making 
and prioritization; (2) more effective use of information management 
systems to monitor and improve the process; and (3) the implementation 
of human capital strategies to measure, evaluate, and provide 
performance incentives for participants in the process. FAA has 
implemented 8 of our 10 recommendations.[Footnote 28] 

NTSB's February 2010 update on the status of its Most Wanted 
recommendations related to icing characterized FAA's related 
rulemaking efforts as "unacceptably slow." In December 2009, at FAA's 
International Runway Safety Summit, NTSB's Chairman commented, "How do 
safety improvements end up taking 10 years to deliver? They get 
delayed one day at a time ...and every one of those days may be the 
day when a preventable accident occurs as the result of something we 
were 'just about ready to fix.'" In particular, NTSB has expressed 
concern about the pace of FAA's rulemaking project to amend its 
standards for transport category airplanes to address supercooled 
large droplets, which is outside the range of icing conditions covered 
by the current standards. FAA began this rulemaking effort in 1997 in 
response to a recommendation made by NTSB the prior year, and the 
agency currently expects to issue its proposed rule in July 2010 and 
the final rule by January 2012. However, until the notice of proposed 
rulemaking is published and the close of the comment period is known, 
it will be unclear as to when the final rule will be issued.[Footnote 
29] The Department of Transportation, in its monthly report on the 
department's significant rulemakings, has classified this rulemaking 
effort as "behind schedule" since March 2010. Much of the time on this 
rulemaking effort has been devoted to research and analysis aimed at 
quantifying the atmospheric conditions that lead to supercooled large 
droplet icing, as well as developing tools that would allow industry 
to comply with the forthcoming rule. 

In 2009, FAA completed an internal review of its rulemaking process 
and concluded that several of the concerns from 1998 that led to the 
agency's major reform effort remain, including: 

* inadequate early involvement of key stakeholders; 

* inadequate early resolution of issues; 

* inefficient review process; 

* inadequate selection and training of personnel involved in 
rulemaking; and: 

* inefficient quality guidance. 

According to FAA's manager for aircraft and airport rules, the agency 
is taking steps to implement recommendations made by the internal 
review, such as revising the rulemaking project record form and 
enhancing training for staff involved in rulemaking. In addition, in 
October 2009, FAA tasked ARAC with reviewing its processes and making 
recommendations for improvement within a year. According to an FAA 
rulemaking manager, ARAC is finalizing its recommendations and writing 
its report, which FAA expects to receive in December 2010. We believe 
these efforts have the potential to improve the efficiency of FAA's 
rulemaking process. Progress in rulemaking will be critical for FAA 
because, as we have reported in our recent reviews of the transition 
to the Next Generation Air Transportation System (NextGen), many of 
the proposals for safely enhancing the efficiency and capacity of the 
national airspace system will depend on timely development of rules 
and procedures.[Footnote 30] 

Ensuring the availability of adequate resources for icing-related R&D. 
NASA is a key source of R&D related to icing. The agency performs 
fundamental research related to icing in-house and sponsors such 
research at universities and other organizations. According to NASA 
officials, possible areas for increased support for R&D that could be 
helpful include pilot training, supercooled large droplet simulation 
(both experimental and computational), engine icing, and the effects 
of icing on future aircraft wing designs. However, the amount of NASA 
resources (including combined amounts from NASA's budget and from FAA 
for aircraft icing R&D at NASA facilities) and staffing for icing 
research have declined significantly since fiscal year 2005, as shown 
in figure 6. According to NASA officials, there were several 
contributing factors to the decline in available resources, including 
the fiscal constraints on the overall federal budget, a shift in the 
administration's priorities for NASA, as well as a restructuring 
within NASA's aeronautical programs to reflect the available resources 
and priorities. Because the outcomes of R&D are often a required 
precursor to the development of rules and standards, as well as 
technological innovation, a decline in R&D resources can delay actions 
that would promote safe operation in icing conditions. For example, 
FAA's chief scientist for icing told us the decline in NASA's icing 
research budget has adversely affected NASA's research to understand 
how icing affects various makes and models of aircraft in real time--
research that would ultimately help pilots determine how to respond to 
specific icing encounters. He said that without NASA's research 
efforts, it would be uncertain who would conduct this and other 
potentially important icing research. In commenting on a draft of this 
report, the National Science Foundation agreed that this is a major 
concern and noted that icing-related research conducted by NASA has 
been extremely valuable. 

Figure 6: NASA Funding and Staffing for Icing-Related R&D, Fiscal 
Years 2005 to 2013, as of February 2010: 

[Refer to PDF for image: multiple line graph] 

Fiscal year: 2005; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $6,383,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 42. 

Fiscal year: 2006; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $6,086,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 36. 

Fiscal year: 2007; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $1,532,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 28. 

Fiscal year: 2008; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $1,959,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 21. 

Fiscal year: 2009; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $2,183,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 22. 

Fiscal year: 2010; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $1,043,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 21. 

Fiscal year: 2011; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $1,966,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 21. 

Fiscal year: 2012; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $930,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 21. 

Fiscal year: 2013; 
Funding for icing-related R&D at NASA facilities, provided by NASA and 
FAA: $930,000; 
Staffing for icing-related R&D at NASA facilities, in full time 
equivalents (FTEs): 21. 

Sources: GAO presentation of NASA data. 

Notes: Amounts for fiscal years 2005 through 2009 represent actual 
allocations, while amounts for fiscal years 2010 through 2013 
represent projected allocations. Funding data represent three sources 
of funding for icing research at NASA. According to NASA, complete 
data are available for one source, while data for another source are 
only available for fiscal years 2005 to 2010, and data for the third 
source are only available for fiscal years 2005 to 2009. Amounts do 
not reflect icing-related funds received or could be received through 
other government programs or external partnership (e.g., Boeing) 
agreements. The funding costs do not include amounts for staffing. 

[End of figure] 

Ensuring that pilot training is thorough, relevant, and realistic. 
Another icing-related challenge to aviation safety is pilot training. 
Aviation experts told us that pilots are likely to encounter icing 
conditions beyond their aircraft's capabilities at least once in their 
career. Currently, icing must be covered in a commercial pilot's 
initial training and, while recurrent training may not always 
emphasize icing, it is covered on a rotational basis. Different 
weather conditions affect aircraft performance in a variety of ways, 
making it critical that pilots receive training relevant to the 
conditions they are likely to encounter. For example, it is important 
that regional airline operators provide region-specific training to 
their pilots as regional airline consolidations may cause pilots to 
fly a geographically wider variety of routes with more variation in 
weather conditions. Further, in February 2010, the Executive Air 
Safety Chairman of the Airline Pilots Association International 
testified on the importance of pilots knowing the effects icing has on 
the controllability of the specific airplane they are flying. He 
stressed that, currently, the pilot community has inconsistent 
information and guidance when having to decide how to react after 
encountering in-flight icing conditions or whether to take off or 
proceed into reported freezing rain or drizzle. Furthermore, in 
commenting on a draft of this report, NASA said the current FAA 
written tests for pilot certification have little relevance to the 
competence required in icing and winter weather operations. For 
example, NASA said one issue is that the pilot-applicant can pass the 
test without answering weather-related questions correctly, but that 
even correct answers provide very little operational information 
compared with what a pilot needs to know when faced with icing. NASA 
said it has participated in developing materials to help fill this 
information gap and while the materials have been adopted by a number 
of users, they have not been endorsed by FAA. NASA believes that these 
or other expanded materials should be utilized and included as part of 
the formal pilot training requirement. 

Regarding pilot training, in January 2010, the FAA Administrator said, 
"The flying public needs to have confidence that no matter what size 
airplane they board, the pilots have the right qualifications, are 
trained for the mission, are fit for duty. . . . We know we need to 
reexamine pilot qualifications to make sure commercial pilots who 
carry passengers have the appropriate operational experience--they 
need to be trained for the mission they are flying."[Footnote 31] FAA 
has begun to take steps to address shortcomings in pilot training. For 
example, in January 2009, FAA issued a notice of proposed rulemaking 
to establish new training requirements, such as requiring the use of 
flight simulators for training flight crewmembers and requiring 
training on special hazards such as loss of control and controlled 
flight into terrain.[Footnote 32] However, as of June 2010, FAA did 
not have a target date for issuing a final rule. In June 2009, FAA 
took the additional step of issuing an action plan to improve airline 
safety and pilot training. The plan called for specially focused 
inspections of carriers' flight crew training and qualifications 
programs. In February 2010, the IG reported that these inspections 
were generally completed on time, but inspectors lacked guidance from 
FAA headquarters and surveillance questions were inadequate.[Footnote 
33] As a result, the IG reported that the consistency and quality of 
the inspections may not have been comprehensive enough to detect flaws 
in the carriers' training and qualifications programs. 

Ensuring the collection and distribution of timely and accurate 
weather information. Improving the quality of weather information 
could reduce the safety risks associated with winter weather 
operations. Pilots and operators use weather forecasts to decide 
whether it is safe to start a flight or, once aloft, whether it is 
preferable to continue on to the destination or divert to an alternate 
airport. Weather experts explained that weather forecasters are still 
far from being able to precisely predict icing conditions in the 
atmosphere and the impact of such conditions on individual aircraft. 
For this reason, FAA said icing forecasters generally provide overly 
cautious forecasts that cover a broad area. While this serves to warn 
pilots that icing could occur, representatives of the Air Line Pilots 
Association said that too many false alarms result in pilots ignoring 
subsequent forecasts of icing. These representatives also said that 
pilots do not know when they are entering severe conditions, as they 
are only given generalized statements about icing conditions. 

Providing pilots with accurate weather information has been a long- 
standing concern: FAA's 1997 Inflight Aircraft Icing Plan recommended 
improving the quality and dissemination of icing weather information 
to dispatchers and flight crews. Since 1997, FAA, in conjunction with 
NOAA and NCAR, has developed improved icing forecasting products. As 
previously mentioned, these icing forecasting products are now fully 
operational, yet FAA and others told us that further improvements to 
weather forecasts are still needed. Currently, NextGen weather 
researchers are focused on creating technology and procedures that 
enable forecasters to provide pilots with more precise and accurate 
predictions of icing conditions, which they believe will address the 
problem of pilots ignoring traditionally unreliable icing forecasts 
and better communicate the existence of dangerous weather conditions 
to pilots. 

Addressing the environmental impacts of deicing fluids. While critical 
to safe, efficient winter operations, continuing to keep aircraft and 
airport pavement free of ice and snow while complying with EPA's 
proposed rule on the use of deicing fluids could be challenging for 
affected airports.[Footnote 34] These programs involve treating 
aircraft and airport pavement with millions of pounds of deicing and 
anti-icing compounds annually. These compounds contain chemicals that 
can harm the environment. Some airports can control deicing pollution 
by capturing the fluids used to deice aircraft using technologies such 
as AIP-funded deicing pads, where aircraft are sprayed with deicing 
fluids before takeoff and the fluids are captured and treated; 
drainage collection systems; or vacuum-equipped vehicles. Third-party 
contractors, rather than individual air carriers, are increasingly 
performing deicing operations at commercial airports. FAA does not 
currently have a process to directly oversee these third-party 
contractors but indicates that it has one under development. 

In its official comments on EPA's proposed rule, an association of 
airports expressed several concerns, including that (1) complying with 
the proposed rule would require additional vehicles around terminals, 
taxiways, and runways to recover deicing fluid, potentially slowing or 
halting operations and posing a safety hazard; (2) the proposed rule 
offers no alternative means of compliance to airports which do not 
have enough space to construct deicing pads; and (3) EPA's estimate of 
the costs of complying with the proposed rule did not include several 
necessary expenditures, including certain infrastructure and 
maintenance costs and the cost of consultants or other staff needed to 
help comply with the rule. According to EPA, the agency worked closely 
with FAA in developing the proposed rule, which FAA determined would 
have no impact on the safety of operations. Several state 
environmental agencies supported the need for this type of rule, but 
some of the agencies believed that the proposal could be improved by, 
for example, including stricter requirements for the treatment of 
deicing fluid or by giving airports more time to comply with new 
requirements. 

Developing a more integrated approach to effectively manage winter 
operations. FAA indicated that developing an integrated approach to 
effectively manage winter operations is among its top challenges 
related to aviation icing. FAA said that, in conjunction with the 
aviation industry, it needs to begin focusing on winter operations 
holistically because there are many vital elements to safe operations 
in winter weather conditions, including airport surface conditions, 
aircraft ground deicing, aircraft in-flight icing and icing 
certification, dissemination of airport condition information, air 
traffic handling of aircraft in icing conditions, and air traffic 
arrival and departure sequencing. An academic expert on icing agreed 
with this view when he told us an integrated approach is critical 
because there are so many different players involved. Other industry 
stakeholders we contacted cited specific examples that demonstrated a 
lack of an integrated approach to winter operations. For example, 
representatives from a pilots' association told us air traffic control 
procedures at large airports cause aircraft to spend more time than 
necessary in icing conditions, which is a safety hazard for small 
aircraft. Representatives from the National Air Transportation 
Association told us consistent language does not exist across all 
stakeholders, with subjective terminology used to report runway 
conditions and in-flight icing encounters that could be interpreted in 
various ways by pilots. FAA stressed that it is important for FAA and 
the aviation industry to focus on how components of the aviation 
system interact and affect one another during winter operations and 
not view the components in isolation. 

Conclusions: 

FAA and other aviation stakeholders have taken many steps to improve 
aviation safety in icing and winter weather conditions. These steps 
have likely contributed to the fact that large commercial airplanes 
have experienced few icing-related accidents since 1998. Nevertheless, 
the many reported icing incidents suggest that icing is an ongoing 
risk to aviation safety, including the safety of large commercial 
airplanes. Further, aviation stakeholders have identified challenges 
that if addressed, could improve safety. Among others, these 
challenges include improving the timeliness of FAA's winter weather 
rulemaking efforts, ensuring the availability of adequate resources 
for icing-related R&D, and developing a more integrated approach to 
effectively manage winter operations. Although FAA and other 
stakeholders are continuing their efforts to reduce safety risks 
associated with icing and winter weather operating conditions, these 
efforts could benefit from more formal and holistic planning. FAA has 
not formally updated its 1997 Inflight Aircraft Icing Plan, meaning 
the stakeholders do not have a consolidated and readily accessible 
source of information on the key in-flight icing actions FAA has under 
way or planned. Furthermore, the scope of the 1997 plan did not 
include icing issues occurring on the ground, yet contaminated runways 
resulting from icing and winter weather pose hazards to planes during 
takeoff and landing, and removing ice or preventing ice from forming 
on aircraft occurs not only during flight, but also on the ground 
prior to takeoff. A plan that addresses both in-flight and ground 
icing issues, as well as the challenges stakeholders identified for 
this report, would help FAA measure its ongoing and planned efforts 
against its goals for improving safety. Furthermore, a comprehensive 
plan could help identify gaps or other areas for improvement and 
assist FAA in developing an integrated approach to winter operations. 
Although stakeholders identified multiple challenges for this report, 
we believe several of them could be addressed in the plan. 

Recommendation for Executive Action: 

To help facilitate FAA's and other stakeholders' efforts to address 
challenges to improving safety in icing and winter weather conditions, 
we recommend that the Secretary of Transportation direct the 
Administrator, FAA, to develop a comprehensive plan, in consultation 
with public and private stakeholders, to guide these efforts. The plan 
should focus on winter operations holistically, be clearly 
communicated to all affected parties, and include detailed goals, 
milestones, and time frames that can be used to gauge performance and 
progress, identify gaps, and determine areas for improvement. FAA 
should also periodically report to affected parties on its progress in 
implementing the plan, as well as any updates to the plan. 

Agency Comments: 

We provided a draft of this report to the Department of Transportation 
(which contains FAA), the Department of Commerce (which contains 
NOAA), NTSB, NASA, and the National Science Foundation (which contains 
NCAR) for their review and comment. In response, the Department of 
Transportation agreed to consider our recommendation and provided 
technical comments which we incorporated as appropriate. The 
Department of Commerce and NTSB also provided technical comments which 
we incorporated as appropriate. 

In commenting on a draft of this report, NASA emphasized the 
importance of updated and timely aircraft certification requirements 
and the need for research to develop computer models and simulations 
to provide the understanding needed to support new certification 
requirements. With respect to our recommendation, NASA said that while 
FAA's development of a comprehensive plan for winter operations is a 
good first step, NASA suggested that greater emphasis be placed on 
FAA's implementation activities once the plan is in place. NASA also 
provided technical comments which we incorporated as appropriate. 

In its comments, the National Science Foundation (NSF) said our report 
adequately addresses the state of aircraft operations during winter. 
Of the challenges we identified, NSF said developing a more integrated 
approach to effectively manage winter operations is the most critical 
and will result in the most improvements to aviation safety and icing. 
NSF said that a number of universities, under funding from NSF, 
conduct research into the physics of icing and also had provided in 
situ measurements (using a storm penetration aircraft) of icing and 
other conditions associated with large convective storms. NSF 
indicated that our discussion of CIP and FIP as fully operational 
products illustrates that advances are being made, but that constant 
updates are needed as a result of additional research. 

We are sending copies of this report to interested congressional 
committees, the Secretary of Transportation, the Secretary of 
Commerce, the Chairman of NTSB, the Administrator of NASA, and the 
Acting Director of the NSF. In addition, the report will be available 
at no charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you have any questions concerning this report, please contact me at 
(202) 512-2834 or dillinghamg@gao.gov. Contact points for our Offices 
of Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in appendix III. 

Signed by: 

Gerald L. Dillingham, Ph.D. 
Director, Physical Infrastructure Issues: 

List of Requesters: 

The Honorable John D. Rockefeller IV: 
Chairman: 
The Honorable Kay Bailey Hutchison: 
Ranking Member: 
Committee on Commerce, Science, and Transportation: 
United States Senate: 

The Honorable James L. Oberstar: 
Chairman: 
The Honorable John L. Mica: 
Ranking Member: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The Honorable Byron L. Dorgan: 
Chairman: 
The Honorable Jim DeMint: 
Ranking Member: 
Subcommittee on Aviation Operations, Safety, and Security: 
Committee on Commerce, Science, and Transportation: 
United States Senate: 

The Honorable Jerry F. Costello: 
Chairman: 
The Honorable Thomas E. Petri: 
Ranking Member: 
Subcommittee on Aviation: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The Honorable Charles E. Schumer: 
United States Senate: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

We reviewed (1) the extent to which large commercial airplanes have 
experienced accidents and incidents related to icing and contaminated 
runways, (2) the Federal Aviation Administration's (FAA) inspection 
and enforcement activities related to icing, (3) the efforts of FAA 
and other aviation stakeholders to improve safety in icing and winter 
weather operating conditions, and (4) the challenges that continue to 
affect aviation safety in icing and winter weather operating 
conditions. 

To review the extent to which large commercial airplanes have 
experienced accidents and incidents related to icing and contaminated 
runways, we analyzed data obtained from FAA, the National 
Transportation Safety Board (NTSB), and the National Aeronautics and 
Space Administration (NASA). More specifically, NTSB provided us both 
raw and summary data from its aviation accident database on accidents 
involving large commercial carriers, small commercial carriers, or 
private operators in which any of the following were cited as a cause 
of the accident, a contributing factor, or a finding: icing of the 
airframe and associated equipment and structures, engines and engine 
intakes, fuel lines, or carburetors; contamination of airport surfaces 
by snow or ice; and snow removal.[Footnote 35] We analyzed this data 
to identify and remove several duplicate accident records. FAA and 
NASA provided us data from their aviation incident databases on 
incidents related to the same types of factors as the accidents we 
analyzed. We tabulated the incident data to determine the numbers of 
incidents by type of factor and by type of operator. 

To review FAA's inspection and enforcement activities related to icing 
we obtained FAA's inspection and enforcement policies and analyzed 
data from FAA's inspection and enforcement databases. More 
specifically, to assess the timeliness of FAA's inspection-based 
assessments of large commercial carriers ground deicing programs under 
the Air Transportation Oversight System (ATOS), we obtained and 
analyzed data from the system to determine how many assessments were 
completed within FAA's required time frames. To determine the extent 
to which FAA's inspections found that large commercial carriers were 
in compliance with FAA's safety requirements, we analyzed inspection 
data from ATOS on inspectors' responses to compliance-related 
questions. We also analyzed data from ATOS on the results of 
inspectors' overall assessments of each large commercial carrier's 
compliance with ground deicing regulations. To determine the extent to 
which FAA had completed all required and planned inspections of large 
and small commercial carriers' ground deicing programs that were 
covered by the National Work Program Guidelines (NPG), we obtained and 
analyzed data from FAA's Program Tracking and Reporting Subsystem 
(PTRS) on the numbers of required and planned inspections that FAA 
completed, as well as those that it terminated or canceled. To 
determine the enforcement actions that FAA initiated against carriers 
that violated icing-related regulations, we obtained and analyzed data 
on these actions from FAA's Enforcement Information System, including 
whether the actions were administrative, fines, or suspensions or 
revocations of carriers' operating certificates. For the cases that 
are closed, we analyzed data to determine the minimum, median, and 
maximum dollar amounts of fines and durations of suspensions. 

To determine the efforts FAA and other stakeholders have undertaken to 
improve safety in icing and winter weather operating conditions and 
the challenges that remain, we interviewed government officials from 
FAA, NTSB, NASA, the National Oceanic and Atmospheric Administration 
(NOAA), and the National Center for Atmospheric Research (NCAR), as 
well as the Flight Safety Foundation and an academic expert from the 
University of Illinois. We also contacted a variety of industry 
representatives, as shown in table 6. 

Table 6: Industry Groups We Contacted: 

Industry group name: Aerospace Industries Association; 
Representation: Represents manufacturers and suppliers of civil, 
military, and business aircraft. 

Industry group name: Air Line Pilots Association, International; 
Representation: Represents the collective interests of pilots in 
commercial aviation in the United States and Canada. 

Industry group name: Air Transport Association; 
Representation: Represents the nation's leading airlines. 

Industry group name: Aircraft Owners and Pilots Association; 
Representation: Represents general aviation. 

Industry group name: Airports Council International of North America; 
Representation: Represents local, regional, and state governing bodies 
that own and operate commercial airports in the United States and 
Canada. 

Industry group name: General Aviation Manufacturers Association; 
Representation: Represents manufacturers of fixed-wing general 
aviation airplanes, engines, avionics, and components. 

Industry group name: National Air Traffic Controllers Association; 
Representation: Represents air traffic controllers, engineers, and 
other safety-related professionals. 

Industry group name: National Air Transportation Association; 
Representation: Represents the legislative, regulatory, and business 
interests of general aviation service companies. 

Industry group name: National Business Aviation Association; 
Representation: Represents companies that rely on general aviation 
aircraft for business purposes. 

Industry group name: Regional Airline Association; 
Representation: Represents North American regional airlines and the 
manufacturers of products and services supporting the regional airline 
industry. 

Source: GAO, based on industry information. 

[End of table] 

We also reviewed key documents on the efforts undertaken by these 
entities, including FAA's 1997 Inflight Aircraft Icing Plan and a 
status update on the plan and FAA's other winter-weather initiatives 
that FAA developed at our request; FAA's 2009 report on its review of 
its rulemaking process; FAA's Answering the Call to Action on Airline 
Safety and Pilot Training; and the Environmental Protection Agency's 
proposed rule on the use of deicing fluids and related effluents, as 
well as public comments on the proposed rule submitted to the docket 
by Airports Council International of North America and several state 
environmental agencies. We also obtained and reviewed data related to 
several key stakeholder efforts, such as data on Airport Improvement 
Program (AIP) funding FAA has provided to airports to construct 
deicing facilities and to acquire aircraft deicing equipment; data 
from NTSB's recommendation database on the status of its 
recommendations related to aviation icing and winter weather; and data 
on NASA funding and staffing for icing research. 

We conducted this review from August 2009 to July 2010 in accordance 
with generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient and 
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 assess the reliability 
of the inspection and enforcement data that we received from FAA, we 
performed electronic testing of the data elements that we used, 
obtained and reviewed documentation about the data and the systems 
that produced them, and interviewed knowledgeable FAA officials. To 
assess the reliability of the accident data we received from NTSB and 
the incident data we received from FAA and NASA, we obtained and 
reviewed documentation about the data and the systems that produced 
them. 

[End of section] 

Appendix II: FAA's Funding to the Airport Improvement Program for 1999 
to 2009, by State and City: 

State/City: Alaska; Fairbanks; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $2,069,333. 

State/City: Colorado; Denver; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $299,974. 

State/City: Colorado; Denver; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $6,200,000. 

State/City: Colorado; Denver; 
Year: 2004; 
Construct deicing containment facility: 
Total amount: $7,700,000. 

State/City: Colorado; Denver; 
Year: 2005; 
Construct deicing containment facility: 
Total amount: $13,120,975. 

State/City: Colorado; Denver; 
Year: 2006; 
Construct deicing containment facility: 
Total amount: $2,634,739. 

State/City: Connecticut; New Haven; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $67,092. 

State/City: Iowa; Dubuque; 
Year: 2006; 
Acquire aircraft deicing equipment: 
Total amount: $221,417. 

State/City: Illinois; Belleville; 
Year: 2005; 
Construct deicing containment facility: 
Total amount: $202,572. 

State/City: Illinois; Belleville; 
Year: 2009; 
Acquire aircraft deicing equipment: 
Total amount: $507,900. 

State/City: Indiana; Indianapolis; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $5,654,999. 

State/City: Kansas; Wichita; 
Year: 1999; 
Acquire aircraft deicing equipment: 
Total amount: $128,350. 

State/City: Kansas; Manhattan; 
Year: 2001; 
Acquire aircraft deicing equipment: 
Total amount: $37,438. 

State/City: Kansas; Manhattan; 
Year: 2002; 
Acquire aircraft deicing equipment: 
Total amount: $123,971. 

State/City: Kentucky; Covington; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $1,210,000. 

State/City: Kentucky; Covington; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $269,057. 

State/City: Kentucky; Lexington; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $198,000. 

State/City: Kentucky; Lexington; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $2,399,244. 

State/City: Kentucky; Paducah; 
Year: 2007; 
Construct deicing containment facility: 
Total amount: $91,037. 

State/City: Maryland; Baltimore; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $3,403,519. 

State/City: Maine; Bangor; 
Year: 2004; 
Construct deicing containment facility: 
Total amount: $399,599. 

State/City: Maine; Bangor; 
Year: 2005; 
Construct deicing containment facility: 
Total amount: $1,384,222. 

State/City: Michigan; Detroit; 
Year: 2005; 
Construct deicing containment facility: 
Total amount: $2,950,000. 

State/City: Michigan; Detroit; 
Year: 2008; 
Construct deicing containment facility: 
Total amount: $3,800,000. 

State/City: Michigan; Detroit; 
Year: 2009; 
Construct deicing containment facility: 
Total amount: $1,889,237. 

State/City: Michigan; Kalamazoo; 
Year: 2004; 
Acquire aircraft deicing equipment: 
Total amount: $203,468. 

State/City: Minnesota; Bemidji; 
Year: 2005; 
Acquire aircraft deicing equipment: 
Total amount: $12,065. 

State/City: Minnesota; Bemidji; 
Year: 2005; 
Acquire aircraft deicing equipment: 
Total amount: $161,478. 

State/City: Minnesota; Brainerd; 
Year: 2008; 
Acquire aircraft deicing equipment: 
Total amount: $204,250. 

State/City: Minnesota; Hibbing; 
Year: 2005; 
Acquire aircraft deicing equipment: 
Total amount: $280,690. 

State/City: Minnesota; International Falls; 
Year: 2007; 
Acquire aircraft deicing equipment: 
Total amount: $205,899. 

State/City: Minnesota; Minneapolis; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $7,660,984. 

State/City: Minnesota; Minneapolis; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $10,204,941. 

State/City: Minnesota; St. Cloud; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $58,500. 

State/City: Minnesota; St. Cloud; 
Year: 2007; 
Acquire aircraft deicing equipment: 
Total amount: $204,250. 

State/City: Missouri; Kansas City; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $150,000. 

State/City: Missouri; Kansas City; 
Year: 2005; 
Construct deicing containment facility: 
Total amount: $5,589,005. 

State/City: Missouri; Kansas City; 
Year: 2006; 
Construct deicing containment facility: 
Total amount: $4,463,462. 

State/City: Montana; Bozeman; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $91,328. 

State/City: Montana; Missoula; 
Year: 2008; 
Construct deicing containment facility: 
Total amount: $4,363,460. 

State/City: North Carolina; Charlotte; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $145,051. 

State/City: North Carolina; Kinston; 
Year: 2001; 
Acquire aircraft deicing equipment: 
Total amount: $167,943. 

State/City: New Jersey; Morristown; 
Year: 2004; 
Construct deicing containment facility: 
Total amount: $1,579,259. 

State/City: New Mexico; Roswell; 
Year: 2008; 
Acquire aircraft deicing equipment: 
Total amount: $116,051. 

State/City: New York; Buffalo; 
Year: 2006; 
Construct deicing containment facility: 
Total amount: $816,891. 

State/City: New York; Buffalo; 
Year: 2008; 
Construct deicing containment facility: 
Total amount: $500,000. 

State/City: New York; Islip; 
Year: 2007; 
Construct deicing containment facility: 
Total amount: $46,550. 

State/City: New York; Islip; 
Year: 2009; 
Acquire aircraft deicing equipment: 
Total amount: $288,591. 

State/City: New York; Ithaca; 
Year: 2009; 
Acquire aircraft deicing equipment: 
Total amount: $113,735. 

State/City: New York; New York; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $6,856,488. 

State/City: New York; Newburgh; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $1,400,000. 

State/City: New York; Rochester; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $1,858,022. 

State/City: New York; Rochester; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $973,860. 

State/City: New York; White Plains; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $369,855. 

State/City: New York; White Plains; 
Year: 2003; 
Acquire aircraft deicing equipment: 
Total amount: $262,678. 

State/City: New York; White Plains; 
Year: 2007; 
Acquire aircraft deicing equipment: 
Total amount: $581,613. 

State/City: New York; White Plains; 
Year: 2008; 
Acquire aircraft deicing equipment: 
Total amount: $296,283. 

State/City: New York; White Plains; 
Year: 2009; 
Acquire aircraft deicing equipment: 
Total amount: $473,991. 

State/City: Ohio; Akron; 
Year: 2005; 
Construct deicing containment facility: 
Total amount: $4,993,313. 

State/City: Ohio; Akron; 
Year: 2006; 
Construct deicing containment facility: 
Total amount: $5,000,000. 

State/City: Ohio; Columbus; 
Year: 2002; 
Construct deicing containment facility: 
Total amount: $5,173,023. 

State/City: Ohio; Toledo; 
Year: 2005; 
Construct deicing containment facility: 
Total amount: $746,756. 

State/City: Ohio; Toledo; 
Year: 2006; 
Construct deicing containment facility: 
Total amount: $861,735. 

State/City: Ohio; Toledo; 
Year: 2007; 
Construct deicing containment facility: 
Total amount: $77,524. 

State/City: Ohio; Youngstown/Warren; 
Year: 2007; 
Construct deicing containment facility: 
Total amount: $22,609. 

State/City: Ohio; Youngstown/Warren; 
Year: 2008; 
Acquire aircraft deicing equipment: 
Total amount: $246,687. 

State/City: Oklahoma; Tulsa; 
Year: 2004; 
Construct deicing containment facility: 
Total amount: $381,239. 

State/City: Oregon; Portland; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $6,173,126. 

State/City: Oregon; Portland; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $9,645,738. 

State/City: Oregon; Portland; 
Year: 2002; 
Construct deicing containment facility: 
Total amount: $488,743. 

State/City: Pennsylvania; Bradford; 
Year: 2003; 
Acquire aircraft deicing equipment: 
Total amount: $144,425. 

State/City: Pennsylvania; Harrisburg; 
Year: 2000; 
Acquire aircraft deicing equipment: 
Total amount: $86,920. 

State/City: Pennsylvania; Latrobe; 
Year: 2006; 
Acquire aircraft deicing equipment: 
Total amount: $118,883. 

State/City: Pennsylvania; Philadelphia; 
Year: 2000; 
Acquire aircraft deicing equipment: 
Total amount: $17,915,168. 

State/City: Pennsylvania; Pittsburgh; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $1,000,000. 

State/City: Pennsylvania; Pittsburgh; 
Year: 2002; 
Construct deicing containment facility: 
Total amount: $2,430,965. 

State/City: Pennsylvania; Pittsburgh; 
Year: 2007; 
Construct deicing containment facility: 
Total amount: $6,115,219. 

State/City: Pennsylvania; Pittsburgh; 
Year: 2008; 
Construct deicing containment facility: 
Total amount: $6,775,000. 

State/City: Pennsylvania; State College; 
Year: 2002; 
Construct deicing containment facility: 
Total amount: $89,092. 

State/City: Pennsylvania; State College; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $221,883. 

State/City: Pennsylvania; State College; 
Year: 2004; 
Construct deicing containment facility: 
Total amount: $3,919,476. 

State/City: Tennessee; Memphis; 
Year: 2007; 
Construct deicing containment facility: 
Total amount: $1,440,412. 

State/City: Tennessee; Memphis; 
Year: 2008; 
Construct deicing containment facility: 
Total amount: $286,591. 

State/City: Tennessee; Nashville; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $1,356,970. 

State/City: Tennessee; Nashville; 
Year: 1999; 
Acquire aircraft deicing equipment: 
Total amount: $214,294. 

State/City: Tennessee; Nashville; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $832,306. 

State/City: Tennessee; Nashville; 
Year: 2000; 
Acquire aircraft deicing equipment: 
Total amount: $131,416. 

State/City: Tennessee; Nashville; 
Year: 2007; 
Construct deicing containment facility: 
Total amount: $44,491. 

State/City: Texas; Beaumont/Port Arthur; 
Year: 2006; 
Acquire aircraft deicing equipment: 
Total amount: $88,825. 

State/City: Texas; Dallas-Fort Worth; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $7,878,022. 

State/City: Texas; Dallas-Fort Worth; 
Year: 2000; 
Construct deicing containment facility: 
Total amount: $1,223,254. 

State/City: Texas; Dallas-Fort Worth; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $750,000. 

State/City: Texas; Fort Worth; 
Year: 2003; 
Construct deicing containment facility: 
Total amount: $13,075. 

State/City: Virginia; Roanoke; 
Year: 2002; 
Acquire aircraft deicing equipment: 
Total amount: $387,827. 

State/City: Washington; Bellingham; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $75,000. 

State/City: Wisconsin; Eau Claire; 
Year: 2005; 
Acquire aircraft deicing equipment: 
Total amount: $220,000. 

State/City: Wisconsin; Green Bay; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $605,700. 

State/City: West Virginia; Clarksburg; 
Year: 2001; 
Construct deicing containment facility: 
Total amount: $66,825. 

State/City: West Virginia; Clarksburg; 
Year: 2002; 
Construct deicing containment facility: 
Total amount: $230,683. 

State/City: West Virginia; Clarksburg; 
Year: 2004; 
Acquire aircraft deicing equipment: 
Total amount: $220,139. 

State/City: West Virginia; Huntington; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $577,789. 

State/City: Wyoming; Sheridan; 
Year: 1999; 
Construct deicing containment facility: 
Total amount: $58,850. 

Source: GAO analysis of FAA data. 

[End of table] 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO contact: 

Gerald L. Dillingham, Ph.D., (202) 512-2834 or dillinghamg@gao.gov: 

Staff Acknowledgments: 

In addition to the contact above, other key contributors to this 
report were Sally Moino, Assistant Director; Laurel Ball; Richard 
Brown; Shareea Butler; Colin Fallon; David Goldstein; Brandon Haller; 
David Hooper; and Joshua Ormond. 

[End of section] 

Footnotes: 

[1] In this report we use the term "icing" to refer to icing of 
airplane surfaces. We use the term "contaminated runway" to refer to 
ice, snow, slush, frost, or standing water on the runway. 
Precipitation or the presence of fog at low temperatures may be 
defined as icing conditions for the airplane, which may require 
certain ground deicing procedures (e.g., checks or deicing of the 
critical surfaces). Runways that are contaminated with snow, slush, or 
ice are generally associated with operations in winter conditions. 

[2] The Flight Safety Foundation is an independent, nonprofit, 
international organization engaged in research, auditing, education, 
advocacy, and publishing to improve aviation safety. 

[3] APA describes two types of rulemaking, formal and informal. Formal 
rulemaking includes a trial-type on-the record proceeding. Most 
federal agencies use the informal rulemaking procedures outlined in 5 
U.S.C. §553. 

[4] 14 C.F.R. part 39. 

[5] 74 Fed. Reg. 44676, Aug. 28, 2009. 

[6] Urea is a chemical compound commonly used to deice runways and 
other airfield surfaces at commercial airports in the United States. 

[7] We did not analyze trends because, according to incident data 
experts, not all incidents are reported and therefore trends are not 
meaningful. 

[8] FAA implemented ATOS in 1998, and currently uses the system to 
oversee all 98 large commercial carriers. ATOS emphasizes a system 
safety approach that extends beyond periodically checking airlines for 
compliance with regulations to using technical and managerial skills 
to identify, analyze, and control hazards and risks. For example, 
under ATOS, inspectors develop surveillance plans for each airline, 
based on data analysis and risk assessment, and adjust the plans 
periodically based on inspection results. FAA also conducts 
inspections that partially address icing related requirements, such as 
inspections of carriers' flight crew training. We did not look at 
these inspections because of resource constraints. 

[9] FAA bases assessments of design on a single inspection because, 
unlike performance assessments, assessing the design of a program does 
not involve inspecting activities at multiple locations. 

[10] U.S. Department of Transportation Inspector General, FAA's 
Process for Reviewing Air Transportation Oversight System (ATOS) 
Inspection Data (Washington, D.C., Mar. 2010). 

[11] 49 U.S.C. §46301 (civil penalties) and 49 U.S.C. §44709 (license 
revocation). 

[12] FAA's 1997 Inflight Aircraft Icing Plan describes various 
activities planned to improve safety for aircraft flying in icing 
conditions. 

[13] 72 Fed. Reg. 44656, Aug. 8, 2007. In general, a transport 
category airplane is an airplane with maximum takeoff weight (MTOW) 
greater than 12,500 pounds or with 10 or more passenger seats, except 
for propeller-driven, multiengine airplanes and recently certified 
commuter category aircraft with an exemption to 14 C.F.R. § 23.3(d), 
in which case the transport category airplanes are those with MTOW 
greater than 19,000 pounds or with 20 or more passenger seats. FAA 
certifies the design of transport category airplanes under 14 C.F.R. 
part 25. 

[14] 74 Fed. Reg. 1280, Jan. 12, 2009. 

[15] 74 Fed. Reg. 38328, Aug. 3, 2009. 

[16] 74 Fed. Reg. 61055, Nov. 23, 2009. This proposed rule only 
applies to airplanes with an MTOW of less than 60,000 pounds being 
operated under 14 C.F.R. part 121. 

[17] 75 Fed. Reg. 37311, June 29, 2010. Supercooled large droplets 
have a diameter greater than 50 microns and include freezing drizzle 
and freezing rain. These droplets can result in ice accretion beyond 
the normally protected areas of the aircraft. Mixed-phase icing 
conditions are a mixture of supercooled water droplets and ice 
crystals. Exposing engines and externally mounted probes to ice 
crystal or mixed-phase conditions, especially high ice water content 
conditions, could result in hazardous ice accumulations within the 
engine that may cause engine damage, power loss, and loss of or 
misleading airspeed indications. 

[18] 74 Fed. Reg. 62691, Dec. 1, 2009. 14 C.F.R. §135.227 and 14 
C.F.R. §91.527. Frost-polishing is accomplished by scraping or buffing 
frost accumulations so as to obtain a smooth surface. Previous FAA 
guidance recommended removal of all wing frost prior to takeoff, but 
allowed frost to be polished smooth if the operator followed the 
manufacturer's procedures. The polished frost requirement does not 
apply to large commercial aircraft (part 121) because part 121 already 
did not permit operations with polished frost. 

[19] A runway safety area is a 1,000-foot safety zone at the end of a 
runway. 

[20] The Transportation [and other] Agencies Appropriations Act, 2006. 
Pub.L.No. 109-115, Div. A, Title I, 119 Stat. 2396, 2401 adopted FAA's 
2015 goal for owners or operators of airports to improve the airport's 
runway safety areas to comply with FAA's design standards required by 
14 C.F.R. part 39. FAA considers runway safety areas that meet 90 
percent of the standards to be substantially compliant. 

[21] EMAS uses materials of closely controlled strength and density 
placed at the end of the runway to stop or greatly slow an aircraft 
that overruns the runway. According to FAA, the best material found to 
date is a lightweight crushable concrete. 

[22] Airports that are scheduled for 2010 installation of EMAS beds 
are Arcata, California; Winston-Salem, North Carolina; Wilmington, 
Delaware; Key West, Florida; Teterboro, New Jersey; Telluride, 
Colorado; and Stuart, Florida. 

[23] This list, which NTSB has maintained since 1990 and revises 
annually, includes important safety recommendations identified for 
special attention and intensive follow-up. 

[24] In addition, NTSB has closed eight of these recommendations as 
"unacceptable response" by FAA; has classified seven of the open 
recommendations as "unacceptable response" by FAA; has closed three of 
these recommendations after concurring with FAA's rationales for 
disagreeing with the recommendations; and is awaiting FAA's response 
on one of these recommendations. 

[25] ARAC is an advisory committee consisting of representatives from 
the aviation community. Established by the FAA Administrator in 1991, 
ARAC provides industry information, advice, and recommendations to be 
considered during FAA's rulemaking activities. ARAC affords FAA 
additional opportunities to obtain firsthand information and insight 
from those parties that are most affected by existing and proposed 
regulations. 

[26] The APA includes exceptions to notice and comment procedures for 
categories of rules such as those dealing with military or foreign 
affairs and agency management or personnel. 5 U.S.C. § 553(a). APA 
requirements to publish a proposed rule generally do not apply when an 
agency finds, for "good cause," that those procedures are 
"impracticable, unnecessary, or contrary to the public interest." 5 
U.S.C. § 553(b). 

[27] GAO, Aviation Rulemaking: Further Reform Is Needed to Address 
Long-standing Problems, [hyperlink, 
http://www.gao.gov/products/GAO-01-821](Washington, D.C.: July 9, 
2001). 

[28] Additional information about the status of these recommendations 
is available at [hyperlink, http://www.gao.gov/products/GAO-01-821] 

[29] FAA is required by statute to issue a final regulation, or take 
other final action, within 16 months of the last day of the comment 
period; or if an Advance Notice of Proposed Rulemaking is issued, FAA 
has not more than 24 months after the date of publication in the 
Federal Register of the proposed rule to issue a final regulation. 49 
U.S.C. § 106(f)(3)(A). 

[30] GAO, Responses to Questions for the Record; Hearing on the Future 
of Air Traffic Control Modernization, GAO-07-928R (Washington, D.C.: 
May 30, 2007) and Next Generation Air Transportation System: Status of 
Transformation and Issues Associated with Midterm Implementation of 
Capabilities, [hyperlink, 
http://www.gao.gov/products/GAO-09-479T](Washington, D.C.: Mar. 18, 
2009). 

[31] J. Randolph Babbitt, Focus and Vision: Moving Forward, remarks as 
prepared for a speech before the Aero Club (Washington, D.C., January 
26, 2010). 

[32] 74 Fed. Reg. 1280, Jan. 12, 2009. Currently, simulators are used 
to train pilots of large commercial airplanes for in-flight icing 
because it is not feasible to train in actual icing conditions, as 
they are difficult to predict and hazardous. However, reliance on 
simulators for training means that pilots may not be sufficiently 
prepared for a variety of real-world icing conditions. According to 
representatives of the Aerospace Industries Association, some 
characteristics of icing cannot currently be replicated, and to 
improve simulators, researchers need to develop engineering tools to 
characterize ice shapes such as those resulting from supercooled large 
droplets. 

[33] Department of Transportation Inspector General, Progress and 
Challenges With FAA's Call to Action for Airline Safety (Washington, 
D.C., Feb. 4, 2010). 

[34] 74 Fed. Reg. 44676, Aug. 28, 2009. 

[35] In determining the probable causes of an accident, NTSB seeks to 
consider all facts, conditions, and circumstances. Any information 
that contributes to the explanation of an accident is identified as a 
"finding" and may be further designated as either a "cause" or 
"factor." The term "factor" is used to describe situations or 
circumstances that contributed to the accident cause. Just as 
accidents often include a series of occurrences, the reasons why these 
occurrences lead to an accident may be the combination of multiple 
causes and factors. For this reason, a single accident record may 
include multiple causes and factors. 

[End of section] 

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