- The FAA's "delicate balance" in regulating the airlines
- 'Coziness' between inspectors and airlines isn't an issue
- Changing pilot fatigue regulations -- why has it taken so long?
- His reaction to the tape of Flight 3407's cockpit voice recorder
A former Eastern Airlines pilot, he is the administrator of the Federal Aviation Administration (FAA). This is the edited transcript of an interview conducted on Oct. 23, 2009.
... I heard yesterday [the FAA is] the largest regulatory body in the world. Is that true?
Yeah. Forty-nine thousand employees. ...
We cover more than just a regulatory agency. We actually have a number of operational units. We actually control air traffic. We have more than 15,000 air traffic controllers. We inspect airplanes. We have more than 6,000 inspectors looking at maintenance, looking at flight operations, avionics, the mechanics of the airplanes.
These are operational tasks, so we actually have people doing things, which is different than a regulatory body that just says, "Well, we're going to look at this and set the rules." We have that. Then we have to go enforce the rules, too, and observe people to make sure they're carrying them out. So it's complex. It's not easy.
Who would you say is the customer?
... When you talk about air traffic, and you're providing air traffic control service, I think the people on the other end of the microphone are, in fact, the customers. We have a service to provide.
Now, in that airplane are passengers, and so I think the broadest answer to that is the passenger is the ultimate customer. And the purchaser is the taxpayer. They're buying the service for us to deliver to somebody, and it's the taxpayer on one end and the passenger on the other. We're obliged to produce the safest, most efficient air travel system we can, and that's our job.
Over the years, though, I think there was the perception, and maybe it was even more overt than that, that the customers were the airlines. Is that a mistake?
I don't know that it's a mistake. I think it would cause a rise in some people. ... You have to have some sort of a relationship, because -- a lot of people are unaware of this -- but there are no two airlines [that are] the same. Every one of them has different operational needs, and therefore we have to meet with them and understand that. We have to understand why Alaska Airlines might need something different than Southwest Airlines. Well, they operate in a different environment. They land on gravel fields. Their equipment they need in the airplane is different. So it has different rules, and we have to understand that. So that absolutely implies and requires that we meet with them periodically.
So I think that's where they overlap. People say, "Well, you're meeting with them like customers." Well, we have to understand what they do.
I guess people take that term "customer" and can get it confused at times, though, because, you know, "The customer's always right." That isn't always the case.
It's absolutely not the case here, and I have any number of CEOs that will attest to that fact, where we've had to deal with them as a regulator, and they're not happy. ...
It's a very delicate balance. I'm a big advocate for self-reporting. There was a day when, if a carrier made a mistake, a mechanic made a mistake, a pilot made a mistake, and they knew that it was a violation of the federal regulations, the answer was, "Hide it."
Well, that's not the answer today. That's not the answer I want. That's not the answer that's going to get us safer. I want people to come forward and say, "Look, I made a mistake. I misread the rule. This procedure misled me, but I'll tell you about it," and in return, you get immunity.
The only way we're going to get safer is to find those things out -- find out why that switch is in the wrong location; find out why that procedure leads to some failure downstream in the system. ... We've got to give people the latitude. If we ever lose that trust, if it's all a punitive relationship, people go silent, we don't learn anything. Then you get safer by investigating accidents. I want to get safer by investigating data.
But how do you know when to be punitive, though, in that environment? It gets difficult, doesn't it, in the real world?
Not really. I mean, we've had cases where someone says, "OK, I disclosed that I wasn't doing this maintenance procedure right." That's great. Thank you very much. And by the way, it was so important, we're going to tell the other carriers, because we don't want them to do it either.
But if I find out two months later you're still doing the same thing and didn't fix it, now we're going to be punitive. You knew it. You told us you were going to fix it, and you didn't. ...
And there are certainly cases to be made in the appeals sense, where someone says: "Look, you wanted me to do this. I have an alternative means of complying. Can I put that before you?" And of course, we'll listen to those. ... But that again entails a discussion, understanding and absolute confirmation that there's no degradation of safety.
So allowing airplanes to fly outside an airworthiness directive [AD], that would be being too lenient, right?
Oh, absolutely. Yeah, that would be.
The thing that came out in the Southwest [investigation], which speaks to this issue of culture, was that the people who kind of raised their hand and said, "This is not right," ultimately they became vilified through the whole process. That's not a good thing. Why did that happen inside the FAA, and what are you going to do about it to try to fix that?
We have taken a big step. What we want is everyone to be very comfortable that they can raise these safety issues. And to that end, we've restructured. We have a Department, now, of Audit and Evaluation that will handle any of the public safety concerns, any of our internal concerns. And we're going to try and handle this a little bit different.
The answer to someone who says, "Look, I have raised something three or four times," the answer to that is not, "Oh, golly, another whistleblower." The answer is: "Thank you very much. Thank you for bringing this to our attention. We want to get to the root of this and make sure that everybody's doing that."
I don't expect carriers to sweep things under the rug. I don't expect us to sweep things under the rug, either, so everybody should have a free voice. A squeaky wheel is making some noise. We all know that. And they're squeaking for a reason. And we need to understand that reason. ...
No. People say, well, this longtime relationship, but the reality is there's so much change in this industry, whether it be on the management side, the carrier side or on the FAA side, there hardly are any cases where anybody is there more than two or three years anyway.
So, while people think about it that way, a review of the facts says that's not the case. You don't have people that are in place to develop that kind of a relationship anyway.
I'm curious, when you started out in your flying career, what your perception of the FAA was.
Something to be avoided at all costs -- (chuckles) -- quite honestly. When I started here, I jokingly said, "When I started my career as a professional pilot, there were two people I really had little interest in meeting: my chief pilot, and I certainly never wanted to meet the FAA administrator."
Now I have the job. But I think anybody who's being regulated -- you know, whenever you look in the rearview mirror and you see a police car, you right away think, jeez, am I doing something wrong? I think that's just a natural instinct.
Is that the way it should be, in a sense?
... Utopia for us would be for everybody to have the same incentive for safety as we do. That makes our job very easy. And I think that the good-news story here is that that is the case. ... [Carriers] go and spend enormous amounts of money in their safety programs. They're developing programs now before we even ask them to, some of the safety initiative things that we found.
We've done a Call to Action to promote things people are implementing already. We don't even have the reports out, and they're already implementing some of the best practices that we found in this Call to Action.
So I think it speaks pretty highly that this is an industry -- and let's face it: A bad safety record is bad for business, too. It's not without some motivation that you should be safe, but the good news is they are.
It's also an incredibly tough business, as you well know, with a lot of pressure on it. There aren't economic incentives for safety, are there?
Well, what I just said. You look at the traffic falloff after somebody's had an accident, yeah, that's an economic incentive. If you have a bad enough safety record, people don't fly with you anymore. ...
So I think people really have a great incentive to be safe, and I think the majority of them do it for the right reason. They want to deliver their customers as safely and efficiently as they can.
Tell me about the business, how it's changed. I don't think most people at home would realize, maybe until they watch this show, that more than half the departures now are with regional carriers as opposed to the old mainline carriers. ...
I would say several things brought it about -- technology, number one. You introduced into service maybe 15 years ago the regional jet, maybe 20 years ago smaller airplanes that could efficiently go into small cities. Instead of running one flight a day at noon, you could now run a flight at 8:00, noon and 4:00 with the same number of seats, and fill all three of them up as opposed to filling one up. So what I just said tripled the flight operations ... and gave the passenger a range of choices. So we're seeing a lot more of that.
The hub-and-spoke network has certainly caught on. It's a way of doing business. Not the only way. You have several carriers who have what I call their "networks," but the network isn't linear. Southwest would be a good example. AirTran … [has] hubs, but they don't depend on them solely, like a lot of carriers do. So that's been a dramatic change. Serving those smaller cities, in some cases, mines people that otherwise wouldn't fly.
The other trend that we've been watching is the outsourcing of flying, the fact that the mainline carriers are taking a lot of these routes you were talking about, the smaller planes and the shorter distances, and contracting their flying out. Does that trend have any inherent problems that you see in it?
It certainly distances the relationship of quality control and any other number of issues, but I think as these have matured, the carriers are now saying: "Wait a minute. We want more of that control, so you are going to have to comply with our standards for uniforms, for safety, for programs. We want you to have some of these voluntary safety programs that all the major carriers have. If you're going to code-share us, if we're going to buy capacity from you, then you're going to have these programs."
It's interesting you should mention that, because [we've] been focusing a little bit on Continental. They're very specific in saying: "We don't get into the safety business with our contract operations. That's up to the FAA." And the reason they say that is because they're doing multiple deals with multiple players, and it gets confusing and all that sort of thing. But doesn't Continental or Delta or whatever the airline, don't they have a responsibility to get into the safety business with these people who are doing flying on their behalf, under their paint job?
... We have one set of rules, and they all comply. They do that. But you have a number of carriers who insist on more, and I think what you're seeing is a trend. ... The pilots, for example, have professional standards boards where they police themselves on professionalism. I'm very encouraged to see that expanded. ...
With that in mind, some of the carriers are saying: "You know what? We should encourage that, too. We should have joint safety council meetings with everybody who code-shares with us. When we put forward a safety initiative with our carrier, everybody ought to know about it, and everybody ought to do it." So I think you're seeing that.
Why hasn't it happened until now, though? Why has it been so slow?
I could be selfish and say I did a Call to Action and inspired them all to do it, but I have been pounding on professionalism. The technology we have today has taken us an enormous distance, and the procedures and our ability to train people. And we always look at it. We continue to look at it. ...
We're changing the regulations, which started back in January of '09, to change some of the things. We know more about high-fidelity simulation. We can expose pilots to things that they'd never otherwise see, or you wouldn't put them into harm's way to demonstrate it. You wouldn't put a real airplane in that position simply because it's dangerous, but it doesn't mean you don't want the pilot to know about it if it happened.
So we're seeing those kind of training scenarios, and all of that improves, and I think our knowledge of how people learn and so forth improves with it. And therefore the carriers are saying, "We need to expand this kind of thing."
A lot of this, it seems to me, relies on voluntary action -- basically good intentions. They might have bottom-line reasons as well, but the bottom line is you're relying on voluntary action. You're the guys that make the rules. Why not change the rules and raise the bar in such a way that there's just no question that you're getting one level of safety?
To that point, we are, in fact. The training is a good example. As I said, we are changing the training regulations. We had a lot of people voluntarily doing it.
We have to keep up with technology, too. We don't invent it; we watch it and then regulate to it. So we have seen new technologies. We saw carriers adopt it, and quite honestly, this is where that feedback loop with the people that we regulate -- a carrier will say to us: "We want to improve our own training. We're going to buy these new simulators that do more than you've ever asked for." We look at it and say: "You know what? Everybody ought to be doing that." We changed the reg. But the technology and the adoption -- again, we don't invent the stuff. That's not our task, but we certainly can, when we observe it, make sure that it gets adopted.
A lot of government agencies have a hard time keeping up with advancements in technology and whatever is going on in the world. Do you feel like you're a little bit behind where the industry is right now?
No, I don't. I think we've done a good job. We have a lot of people that track where the industry is. We have research scientists that work here, and their job is to stay abeam of this technology and brief us internally [about] where technology is going. When we begin to write a regulation, I don't want to write a regulation for yesterday's technology. I want to write a regulation so that we inspire people to go to tomorrow's technology.
It's a challenge. Can I say that every department and every corner is ahead? No, but I'm pretty proud of the record. I think we're as abeam as anybody in this kind of business.
Let's take pilot fatigue, for example, in the news at the moment. Pilot fatigue is an issue that has been [around] as long as I can recall, ... and it certainly has been an issue for a long time in the commuter/regional world, where it's more acute. And we're only now, post-Buffalo, getting to the point where we're talking about changing these rules. Why has it taken so long?
That's a great question, because I was actually involved in the '90s myself in trying to bring these changes about. The aviation rulemaking committees, [which] will argue both sides of this question, really struggled. The FAA struggled in working with them to adopt a rule that was both capable of being monitored, regulated and made sense. You know, cost-benefit -- all those issues get into play.
What we did here was to pull together a group -- and yes, it was post-Buffalo. ... The accident was a tragedy. This was a time to say: "Look, enough is enough. We're going to call this together." And I have to say -- and I testified to this statement -- in the regulatory Olympics, this was a 3-minute mile. This committee came together in 45 days and gave us a quality product.
From that product, we're going to develop a rule. We're going to write a rule that will be out by the end of this year. That is a phenomenal speed. But it is going to address fatigue. It is going to look at risk management. It is going to look at the duty times. It's going to recognize for the first time that there's a difference between being what pilots in the trade call being on the "front of the clock" and the "back of the clock." You go to work at midnight and work for 12 hours, that's completely different than going to work at 8:00 in the morning and working for 12 hours. And we never recognized that difference before in the regulations. Now we'll recognize it.
So we're making great strides there, and I look forward to getting these implemented. The good news here -- I think everybody's going to be slightly disappointed -- "Is it going to be enough for the pilots?" "It's too much for the carriers." I think that means we struck the right balance in the rule. ...
Take me back to your days in the cockpit. What is pilot pushing really all about when you're in the driver's seat, literally?
"Pilot pushing" is a term that says the pilot feels some obligation, in order to keep his job, that if he doesn't go ahead and fly, if he or she says, "Look, I'm so tired I can't fly anymore," or, "The weather's so bad" -- in the old days, it was weather. You'd say: "Well, I'm looking at the weather. I'm not going to go to Denver. It's horrible. I'm not going to subject the passengers." And the chief pilot would say, "Well, you either go, or you're fired."
So you had a decision to make, and fortunately, enough of them finally stood up and said: "You know what? Fire all of us then, because we're not going. We get to make the decision. We're in the airplane. You put us in command for a reason. We get to make the decisions, and we get to do it without the pressure of whether or not I keep my job." ...
I have a good relationship with the pilot groups, and I know it's an issue. A lot of this should be issues resolved between the companies and the pilot groups there. It's finding a way. If I found a company that I thought was pushing pilots, and we had evidence, you'd want to take action on them. You can't do that. Pilots are entitled -- as a matter of fact, they're not only entitled; they're obliged. If they're not fit and ready to work, they have an obligation to say, "I can't fly this flight." And they should be able to do that without any fear of a punitive action.
Should the FAA get more involved in that, though, to ensure that even the recipe for that atmosphere isn't there?
That goes beyond our regulatory reach, really. They have an obligation; the company has an obligation. If either of them aren't living up to that obligation, then that's where we step in.
[The FAA was set up with a dual mandate: the safety and promotion of air travel. After the 1996 ValuJet crash] the promotion component was taken out of the mission. Are there lingering effects of that, though? Is this still an agency that's about promoting aviation?
No. We want the aviation industry to be safe; we want it to be efficient. And if we're doing those two things, it becomes promoted. If it's perceived as not an efficient way to travel, if it's not safe, nobody would do it. So I think we do fulfill the mission of safety and efficiency, which by definition then makes it promoted. ...
I was curious about this, because when they changed the official [mandate] in '96, Congress went through and struck it out there. And then there's this little footnote here, and it says here: "The managers have adopted provisions ... to clarify the FAA's highest priority is safety and security. Managers do not intend for enactment of this provision to require any changes in the FAA's current organization or functions. This provision is intended to address public perceptions that might exist." So I wonder, internally, if it's business as usual.
Remember, that was almost a decade ago. I haven't noticed anybody out actively trying to promote. We've got our hands full with making it safe and efficient. So we're not pursuing any promotion. If the perception is there, it's a lingering one.
When you talk about the promotion piece, the Customer Service Initiative, now called -- what is it called now?
Consistency [and Standardization Initiative] -- yeah.
Right. Does that confuse the troops? And does that put them in a position where they're not doing the job the way you'd like them to?
If it has confused them, I've gone to great lengths in my few short months that I've been here to clarify that. We've had a town hall meeting. We've done correspondence internally. We've done a lot of updates. We have Web pages. We have management briefings. All of those things, I have emphasized what our mission is, what our goal is, so people aren't confused. We went to great lengths on road shows to describe the Standardization Initiative, and so I hope there's no lingering -- if it is, we didn't do a good job communicating what the focus is.
But we have taken a very proactive stand and aggressive move to make sure everybody understands what the mission is.
I want to ask you a little bit about [Continental Flight] 3407 specifically. Obviously we're waiting for the final report, but as I look at the things that seem to be funneling into that cockpit on that night, it seems that there's a lot of issues there that have been out there which suddenly come into focus. Is this one of those watershed accidents?
Remember, we went 29 months without an accident. Everybody in the country was so unused to having a tragic airline accident, and it was a tragedy. If we had one every 10 years, that's one every 10 years too often. So they're always tragedies.
It did put a focus on a couple of areas that came to light, and again, you correctly have noted it's an ongoing investigation, so I'm not going to weigh in on that. But the things we did learn in the preliminary inspired me to have a Call to Action to talk about some of the professionalism components of this. We had the flight-training rules already under way, and we're going to be working with Congress to make sure that we get these things enacted.
We have an advance notice of proposed rulemaking [NPRM] on standards for pilots, so all of these things, I think it puts some focus from Congress, and therefore we're working jointly with them to make sure that any of the issues that arose from this accident are going to be addressed, and addressed as quickly as we can.
As a pilot, when you read that cockpit voice recorder transcript, how did that strike you?
I'll tell you what I have said in public speeches and in many public forums. That was a very disappointing tape. I don't know of a professional pilot who listened to that tape and wasn't disappointed. ... The NTSB [National Transportation Safety Board] is going to ... make the final decision as to the pilot activities there -- but as a professional pilot, there certainly was a lack of coordination in the cockpit. They certainly didn't follow some of the procedures that should have been instinctively followed. It was very disappointing, very disappointing.
As you look at those trends that led to it, though, there were a lot of red flags, weren't there? Was this an accident waiting to happen?
Look, when you look back, you can certainly identify what went wrong. Were there things that were very visible to the outside? No. But in retrospect, looking at them, should we find ways to find those things out -- the fatigue, for example? Absolutely.
... In recent years, because of the explosive growth, the regionals have been thrust into the big leagues, and that's been a very difficult transition for a lot of them. How do you manage that, as a regulator? Are you on top of it?
Yeah. All of the regulations involved, that airline was in compliance. What went wrong there was a failure to follow the procedures. The essence of that accident was the airplane stalled. Again, I don't want to prejudge what the NTSB has to say, but the casual observer would say they failed to recognize the stall and execute the proper stall recovery, period. Being in total regulatory compliance can't stop that.
But, as we talked about earlier, being in total regulatory compliance, meeting the minimum, probably isn't enough, is it?
Some of the things that are out there -- both of those pilots had a fair amount of flight time. The captain had more than five years of experience at that carrier. All the regs were met.
Again, I can't regulate professionalism. ... Looking forward, we want to make sure that professionalism -- when we talk about "sterile cockpit," for example. The two people in the cockpit, when one of them starts talking, the professional has the obligation to say: "Excuse me. We're in a sterile environment right now." But when two people engage in it, now we've got two people that aren't professional.
All I have to do is make sure that one of them is more professional, and that breaks the chain. Safety is all about breaking the chain, and that's what our mission is.
These airplanes are incredible machines of technology. The dependability of a jet engine is phenomenal, when you think about how many people we carry and so forth. But again, you know, one is one too many.
So what's left in the chain? Professionalism -- making sure that the human interfaces with the machine correctly. That's our challenge going forward.
Of course, the way this system used to work when you were brand new is you sat with a Sully, [Capt. Chesley Sullenberger], right? You had the seasoned veteran. It was an apprenticeship-type thing. The way that the regionals have grown, the way they pay, the way the pilots are produced these days -- all these things have stacked up. We lose that whole mentor. The senior pilots are working for another organization altogether, walled off there. It might be the same logo, but they're not there, helping you learn how to fly. How do you create that mentoring, which allows inexperienced pilots to fly, learn their job, and safely do it with passengers sitting behind them?
You've hit on a great point. That's one of the key areas we're working on right now. How do you have that experience transfer? ...
We're looking at the feedback from these programs that we have in the Call to Action. Every carrier there -- and, by the way, I've got to applaud all the carriers -- regionals, majors, everybody -- they all participated. They had great ideas, and one of the common themes was we need to have forums where we get together and openly talk about safety improvement areas, what we're doing at this carrier and you ought to be doing it at that carrier.
They were receptive only in the sense that everybody does it, right? They don't want to be at a competitive disadvantage. In other words, they'll be safe as long as everybody's safe, right?
Right. That's right.
Well, maybe that's where the FAA should be stepping in.
That's what we plan to do. We have told them we're going to take these practices and look at how we make sure everybody does them. Now, I'm not numb or immune to the thought that, golly, if we just make it voluntary, everybody will join together, and we'll all do it. That would be my hope in transition, but at some point we've got to say, "These are programs you have to do." Recurrent training is, you know, it's qualified, requalified and mandatory. And so we look at things like that. ...
... Everybody has a miserable first job, but the difference in the flying business is that, you know, my grandma is sitting behind [you], and so what you have is very challenging flying at very low pay, very difficult work situations. You could call these aviation sweatshops in some cases. Is that right? ...
I think that that's a little bit overplayed. We have good regulations. These carriers have terrific safety records. And you're right: Everybody starts somewhere. Everybody says, "This pilot only has five years."
Well, a surgeon operates on somebody, in real life, for the first time. A lawyer tries his first case. You don't start at the Supreme Court. Everybody starts somewhere, and you build your time. And maybe it was flight instructing, but they have accrued a lot of time. There's nobody hiring carrier pilots at any carriers today with less than 750, 1,000 hours. These are pretty well-qualified pilots when they start.
The regional carriers, they've got a lot of very seasoned pilots. I've known them over the past. You've got 20-year veterans at some of these regional carriers. These are very well-qualified pilots. They like flying for the regional carrier. They're senior. They have good bids. They have good runs. The pay is good. By the way, the starting pay at a major carrier, take a look. It's not exactly stunning over there, either. It's where everybody starts, whether you start at US Airways or you start at Colgan. Now, there's probably a little bit of difference, but it's not dramatic.
That first year is always a tough year, as I understand it. But it goes up more rapidly, I think, at the majors than it does at the --
Well, the aircraft are bigger, and therefore the pay is, but the resident in a hospital, it's his first year, he's not exactly making what the heart surgeon is making, either. ...
That's where good training comes in. We have rules. The pilots call it "green on green," where you don't put two brand-new pilots on the same airplane. You've got to have one with at least 100 hours of operating experience in the airplane. That's in there today. We have addressed some of those rules.
You also limit what pilots can do with a new pilot. They can't fly to the same low minimums with a new captain. You don't put them in those situations, and we have regulations that take care of that today. I think it's one of the reasons we have the safety record we have.
The safety record is extraordinary, no question. A lot of people in the safety business say, "You know, sometimes the absence of accidents doesn't necessarily mean you have the safety you think you have." Is the system, in places, kind of stretched at the seams?
No, I don't think it's stretched at the seams at all. One of the things, though, to your point: We have changed internally at the FAA. We acknowledge that things that we've learned through, in the past, accident investigation, forensic investigation of accidents is what brought us the changes.
We don't have accidents anymore. I mean, we went 29 months without an accident, without one commercial fatality. We've just completed nine more months without one. If this was 1950, there would be three a month. So we go a long time.
So what we're going to solve, where are we going to stop accidents in the future is from data. So we've actually restructured here just recently. Since I've been here, we have done away with an Accident Investigation Department and created an Accident Prevention [Department], and we've melded a Department of Data Collection, sharing data better, analyzing the data. It's one thing to collect data; it's another thing to analyze it and understand what you're getting, and then applying it to good use. These are precursors, and we want to identify things before they happen. I don't want to investigate any more accidents; I want to investigate data.
I'm not diminishing this record. It is tremendous. But the last six fatal accidents have been regionals. Is there something going on there that we're missing?
Again, this is when you look at the volume of increase. The SST [supersonic transport] had a wonderful safety record, but they only flew them twice a day. We are flying regional aircraft at about five times the volume we flew them 10 years ago. These are very popular. They fly a lot of short routes now, a lot more takeoffs and landings. Look at the incidence of where accidents happen. So there's a lot more exposure there, and of course we're focused there as well. That's an area of focus for us, too.
So, why? What in the data -- is there any common trend across these accidents that we should be looking at? Right now, of course we still have one to be determined, but we haven't found that common thread. But it has inspired us to do a better job of data collection and ask these carriers to participate in these voluntary programs, which, I have to say, they're doing. ...
But what I'm saying is, is there a special focus that should be here on this regional flying that you don't have right now?
The special focus I think we're addressing with the change in training rules, which, as I mentioned, have been ongoing since January. Are we giving people enough exposure to things so that -- there's an old saying: "No pilot should ever be a surprised pilot." And if a pilot has been exposed to everything that could possibly happen in a simulated environment, a training atmosphere or something like that, they're a better pilot. That's why those training regs are changing.
And you should ask me, "Well, if they've been [in the works] since January, why aren't they in place?" The answer to that is they're very complicated. We, by federal procedures, have to put these out for comment with 3,000 pages of comments. So we have to digest those.
But what will come out is a very well-thought-out new rule that will, in fact, change training; will, in fact, change some of the training requirements. It will improve the quality of training and exposure to more things, more training elements. ...