Arbitration Awards of Employee Parking Accommodations

An advance decision was requested regarding the implementation of three arbitration awards requiring the Federal Aviation Administration (FAA) to expend appropriated funds for employee parking. FAA did not consider that it would be justified in making the determination, as required for the expenditure of funds by applicable regulations, that such leased parking accommodations were necessary to avoid impairment of its operational efficiency. Since FAA regulations incorporated by reference in the collective bargaining agreement had already made the required determination, the agency was not required to make a further determination. Therefore, FAA could expend appropriated funds to implement the awards.