Boyer NCARC testimony, March 18, 1998

Statement of Phil Boyer
President
AOPA Legislative Action
500 E St., SW, Suite 250
Washington, DC 20024
202/479-4050

before the

House Transportation and Infrastructure Committee
Subcommittee on Aviation
The Honorable John J. Duncan, Chairman

on

The Recommendations
of the National Civil Aviation Review Commission
and Meaningful FAA Reform

March 18, 1998

Mr. Chairman, my name is Phil Boyer, and I am President of AOPA Legislative Action.

AOPA Legislative Action enjoys the financial support of 340,000 dues paying members. Together with our affiliated organization, the Aircraft Owners and Pilots Association and the AOPA Air Safety Foundation, we promote the interests and educate on safety those who contribute to our economy by taking advantage of general aviation aircraft to fulfill their business and personal transportation needs. More than half of all pilots in the United States are members of AOPA, making it the world’s largest pilot organization.

Mr. Chairman, I am very pleased to be here today to discuss the recommendations of the National Civil Aviation Review Commission and offer a few thoughts about the upcoming reauthorization of the Federal Aviation Administration and the Airport Improvement Program.

The National Civil Aviation Review Commission

The FAA Reauthorization Act of 1996 (PL 104-264) was a thoughtful and reasonable bill, and I commend you and the members of this committee for producing it. The final version of the Act created the National Civil Aviation Review Commission (NCARC) to review FAA funding mechanisms and aviation safety, which was an excellent plan to study this vexing problem. Transportation Secretary Rodney Slater appointed 13 of the NCARC’s members, including Chairman Norm Mineta, and the majority and minority leaders of both houses of Congress appointed eight others.

The Act charged the Commission with analyzing the FAA’s budget requirements through 2002, alternative financing and funding means for meeting these requirements, and aviation safety. It did not require the Commission to develop a new financing system for the FAA, only to conduct an independent review of all the options—including the benefits of the current excise tax system. The law also clearly stated that Clinton administration appointees should “represent a balanced view of the issues important to all segments of the aviation industry, including general aviation.”

General aviation not represented

However, despite the specific mandate from Congress, not one of the 13 commissioners appointed by the administration solely represented general aviation users. (One congressional appointee was the owner of an aviation business that deals in the general aviation marketplace. While receptive to our point of view, her main role was successfully representing the views of air taxi operators.) The administration also chose to disregard the law creating the NCARC by failing to appoint representatives for airline passengers, regional airlines, or business aviation.

Mr. Chairman, I’m sure you and most members of this committee are as fond of Norm Mineta as I am. He once sat in your seat as chairman of this subcommittee, and then as full committee chairman. In fact, his two sons are pilots. Norm Mineta’s experience and wisdom in aviation matters is unquestioned. And despite the lack of general aviation representation, let me assure this committee that his door was always open to us throughout the entire NCARC proceedings. But there is simply no substitute for full representation.

The NCARC report does contain some positive aspects. The report correctly notes that the FAA faces challenges such as micromanagement by the Department of Transportation and the Office of Management and Budget. It endorses AOPA Legislative Action’s recommendation of a direct link between FAA spending and revenues. It acknowledges, at least for general aviation, the efficiency and safety of excise taxes over user fees. It calls for incentives to change the FAA’s culture to a more external focus on users and services and more businesslike and responsive management. It offers meaningful safety initiatives. And it endorses full funding for the Airport Improvement Program.

With all due respect to our friend Norm Mineta, however, we disagree with some of the conclusions of the NCARC. Despite the message of the Commission’s report, the sky is not falling.

On May 28 of last year, I testified before the NCARC and told the Commission about the approach to modernization that AOPA advocates. Our approach is based on the findings of The Mitre Corporation, an FAA consultant, and I will discuss them in detail shortly.

Figure 1: NCARC chart of projected delays if the National Airspace system (NAS) is not modernized (from American Airlines study).

The sky is not falling

As you may recall, the NCARC report includes a graph that demonstrates that, given no changes to the air traffic control system, a rapid increase in airline delays will occur (see Figure 1). The trend is startling when displayed alone, and it is the Commission’s principal reason for recommending radical, expensive changes.

Unfortunately, this graph does not tell the whole story.

The Mitre Corporation has identified ways in which currently available technology can dramatically reduce delays at relatively little cost and with little development or implementation time. Mitre’s presentation includes a chart that shows the projected delays using its inexpensive and rapid alternative. The airlines acknowledge the utility of these programs for reducing projected delays—a fact the NCARC left out of its report.

Figure 2: Mitre Corporation chart of projected delays, including range of possible delays after implementing enhancements to current NAS using existing technology at low cost.

If the NCARC had seriously considered the alternative I presented to the Commissioners last May—one that I believe the FAA will shortly adopt—it might have come to a very different conclusion (see Figure 2).

NCARC recommendations—a good deal for the commissioners

If Congress were to implement the NCARC recommendations—increased spending, coupled with a reduction in the general fund contribution and tax breaks—it would likely trigger a second tax increase on the flying public in two years and dispense special tax and funding favors to the interests represented on the Commission. We can’t help but observe that membership on the Commission seemed to confer sector-specific benefits (see Figure 3). And though some of the individual recommendations are good ideas, that contrasts with the Commission’s treatment of general aviation.

Figure 3. NCARC winners and losers.

Though general aviation uses relatively few of the FAA’s services, the report also claims that general aviation does not pay enough to cover the costs it imposes on the system. The report calls for consideration of a change in GA tax rates. In the words of the Commission: “...it is clear from existing aviation cost allocation studies that the current level of tax payments does not cover the costs general aviation imposes on the FAA. The Commission believes that fuel taxes imposed on general aviation should be re-evaluated based on an accurate analysis of the costs of providing ATC and related services to them.”

General aviation was the only segment of aviation singled out for such treatment. In fact, the NCARC staff developed a proposal to double general aviation taxes over a five year period.

The report would bifurcate FAA management by converting the FAA’s air traffic control system to a nebulous “Performance-Based Organization.” A board of directors—a new layer of bureaucracy—would run the “PBO” and fund it with user fees or other user charges as it saw fit. We do not oppose granting the FAA more flexibility—from the beginning, we supported this Committee’s action to provide personnel and procurement flexibility, and we support completing the job by making the FAA independent. But we disagree strongly with the Commission that a PBO is a necessary or appropriate structure for air traffic control.

The definition of a PBO is vague, but we can infer the intended nature of a PBO from the units of the federal government the administration has already recommended become PBOs. Nearly all these agencies provide clearly defined and easily measured services to the public, and none come close to the size and scope of the air traffic control system. They include units like the U.S. Mint, the National Technical Information Service of the Department of Commerce, Federal Housing Administration mortgage insurance services, and the Federal Retirement and Insurance Services branch of the Office of Personnel Management. None of these agencies are responsible for a multi-billion-dollar equipment modernization program involving some of the most advanced technology in existence.

The administration’s PBO candidates have easily measured goals and performance levels. They serve individual customers without involving a greater duty to the general welfare in each and every transaction. And they all measure their budgets in millions, not billions. Contrast that with the FAA, a $9 billion per year, 24 hours, 365 days a year agency with millions of lives in its hands at all times.

The report also calls for further consolidation of flight service stations used by GA and more reliance on the Direct User Access Terminal program for flight planning by personal computer. Such a cavalier reduction in one of the few services provided by the FAA for general aviation could actually lead to a decrease in flying safety as it would reduce the ability of pilots to receive timely and accurate weather forecasts.

Most important, I must again acknowledge that the Commission recognized the importance of general aviation by calling for GA to continue to pay the fuel tax instead of user charges. Nevertheless, when I testified to the Commission last May, I explained why exempting us from user fees was no blessing either. An exemption is a double-edged sword. It could create a two-tiered system of users—those who are perceived as paying for the services they use, through a direct user fee, and those who are perceived as not paying. The business decisions and desires of the upper tier, the airlines paying user fees, would affect the FAA’s bottom line immediately. FAA policy makers would have much less incentive to listen to a group in the lower tier.

The NCARC report’s core recommendation—user-based charges leading to greatly increased revenue—makes the report in whole a failure. The solution to the FAA’s problems is not to throw more money at the agency. Every government agency, no matter how essential, must live within its means. The FAA needs to better manage its existing resources, a fact Congress recognized when it adopted legislation in 1995 freeing the FAA from the burden of certain federal personnel and procurement rules. The NCARC makes a few management and cost-control suggestions, but they don’t go far enough.

The commission mostly ignored FAA’s largest cost driver

For example, labor costs, the most important area of potential cost savings for the FAA, were almost completely ignored by the Commission. Despite extensive discussion of labor cost savings in the congressionally ordered audit of the FAA by Coopers & Lybrand—the report the NCARC was statutorily required to consider closely—the NCARC makes only a passing mention of labor cost savings. Yet the Coopers & Lybrand report notes that labor costs are the largest component of the FAA’s current costs and future cost growth and identifies staffing and personnel, facility consolidation and closure, and productivity improvements as three of the FAA’s seven sources of cost savings.

Cost accounting may be difficult to achieve

The Coopers & Lybrand report flatly states that the FAA lacks a cost accounting system. A General Accounting Office report released last month (GAO/AIMD-98-62) shows that the FAA is currently incapable of tracking its major assets. Said the report: “The lack of accountability over physical assets means that FAA and the Congress may not have accurate financial management information to help make informed decisions about future funding. The lack of accountability is of particular concern in situations such as FAA’s where billions of dollars of assets are being acquired in connection with the ATC modernization program.”

Our discussions with Transport Canada, Canada’s department of transportation, also reveal how difficult it may be for the FAA to establish a credible cost accounting system. Transport Canada started developing their cost accounting system in 1984 as part of their methodology for calculating the number of employees (FTEs) needed for particular services. It has been a long and difficult process for them, and they are candid in admitting their system still needs refinements. But given their experience, Transport Canada officials were amused at the notion the FAA could develop and implement a credible system by November 1998.

User fees present Congress with oversight and constitutional challenges

We would also like to bring to the Committee’s attention a recent review of the entire user fee issue performed at the request of the House Budget Committee by the General Accounting Office (GAO). The report (GAO/AIMD-98-11) states: “Increased reliance on fee collections as an agency’s primary source of funding has implications for federal budgeting and management that may call for a reexamination of the basic principles as well as the actual practices underlying the treatment of fees. Offsetting can inhibit congressional tradeoffs based on the relative merits of programs and can obscure the amount of spending for fee reliant agencies.”

Further, the recent court decision invalidating the FAA’s foreign overflight fee schedule demonstrates that constitutionally it will be difficult, if not impossible, for the FAA to develop a user fee schedule that is based on anything but direct cost recovery. The courts have determined that fees based on ability to pay are akin to unauthorized taxes.

Mr. Chairman, given the FAA’s fundamental accounting shortcomings, how can the administration claim that the FAA needs drastically more funds or a fundamental change in its financing structure when it can’t account for its current funds? Even worse, how can anyone imagine that the FAA is capable of managing an enormously complex user fee system? The potential for breakdowns in the system are mind-boggling.

The administration FY99 proposal

Unfortunately, it appears the Clinton administration will far exceed the recommendations of the NCARC in the reauthorization proposal it will send to this committee.

In addition to asking for a transition to user fees to fund the FAA’s costs beginning in FY2000, the administration’s budget proposal calls for the aviation users to pay an additional $6 billion in additional “new” user fees between FY2000 and FY2003! There is no explanation for why this money is needed or how it would be spent, but it’s clear that these funds would replace the general fund contribution to the FAA’s budget. Despite the strong argument for a general fund contribution, the administration wants to simply throw it out to free the revenue for non-aviation uses—in effect, charging the traveling public for new non-aviation spending. Even the NCARC supports retaining the general fund contribution because “non-aviation users benefit economically and socially from a safe, efficient, and effective air transportation system.”

As I mentioned, the NCARC also calls for exempting general aviation from user fees, allowing GA pilots to continue to pay into the system through a fuel tax instead. The administration’s budget proposal doesn’t even hew to this small concession, which is why I have told AOPA members they might want to do all their flying before 1999, because if the administration’s budget proposals are enacted, they will be taxed right out of the sky.

Mr. Chairman, I would characterize the NCARC report as a solution looking for a problem. The President’s budget, on the other hand, is just a problem. AOPA Legislative Action supports a very different approach to FAA reform and air traffic control modernization—the approach taken by this Subcommittee.

The House aviation subcommittee’s approach: Meaningful FAA reform

Mr. Chairman, along with creating the NCARC, your committee enacted meaningful reforms of the FAA as part of the Reauthorization Act of 1996. The act gave the FAA the power to write its own personnel and procurement rules, to enjoy the support of a Management Advisory Council (MAC), and to have greater autonomy from the Department of Transportation. We should give these reforms time to work before we even consider major changes to FAA’s financing system.

In particular, the President should appoint the members of the MAC. The MAC holds tremendous promise as a tool for assuring the continued excellence of the FAA as it struggles to modernize, cope with increasing demands from the aviation industry and the flying public, and serve its customers better. The law required the establishment of the MAC within three months of the date of enactment, yet the MAC has yet to be assembled 18 months later.

At a time when the President has appointed a new FAA administrator with an excellent track record of management but little direct aviation experience, wouldn’t a council of 15 members with industry expertise be extremely beneficial to assist her in crafting and moving needed reform forward in an expeditious manner? Ms. Garvey shows great potential for leading the FAA into the twenty-first century. She deserves to have all the management tools available at her disposal. What better time is there for the FAA to draw upon the advice, experience, and knowledge the MAC would provide?

This Committee also passed legislation in 1996 that would have restored the FAA as an independent agency free from the DOT, which the House subsequently adopted by voice vote. AOPA recommends that Congress reject the recommendations of the NCARC and once again adopt this committee’s proposal to make the FAA an independent agency.

In its report, the NCARC writes “...the FAA, the DOT, the aviation industry, the Administration and the Congress want to make the system work. But there are too many people in charge.”

Exactly.

In addition to the management flexibility granted FAA by the 104th Congress when it approved personnel and procurement reform, Congress should restore the FAA as an independent agency free from the second-guessing of the DOT and the White House. Until the administration gives up on its quest to bypass Congress and secure an unlimited supply of funds for FAA, the benefits of management flexibility and legislation to expand it cannot materialize.

The President’s FY99 budget request is yet another example of the detrimental effect of political meddling with the technical and safety mandate of the FAA. With the user fee and tax increase proposals, the FAA has gotten wrapped up in the administration’s gimmicks to fund billions of dollars in new programs while claiming to balance the budget, leaving aviation with nothing to show for it but higher, and in our case prohibitive, taxes. It’s even more evidence of the need to free the FAA from politics.

An evolutionary, not revolutionary, approach to NAS modernization

Like you, Mr. Chairman, we eagerly await the administration’s reauthorization bill, which promises details on its plan to impose these user fees, tax increases, and NCARC proposals. This bill comes at a crucial time. The air traffic control system is on the verge of fundamental change that will carry it far into the future.

For years, AOPA has advocated a different vision for the future of aviation and the modernization of air traffic control. What is required from the FAA to implement our approach is a fundamental shift in attitude. Instead of pursuing revolution, modernization requires evolution.

As we told this Committee last October, the revolutionary approach was tested by the original NAS plan. It attempted to throw massive sums of money at the FAA to totally restructure the ATC system all at once. Operating under the “Big Bang” theory, the FAA sought as much money as it could, all up front, at the inception of the NAS plan in the early 1980s. The NAS plan ultimately failed when it couldn’t support its own weight. The cost overruns are legendary—the initial price tag of $11 billion, already a huge public works project, ballooned to over $40 billion. Technology was obsolete before it was ready to use. FAA employees and contractors built careers on single programs or systems. We all remember the Advanced Automation System (AAS) that Congress supported based on the assurances of the FAA the system could be developed, delivered, and make an impact on air traffic management. The microwave landing system is another well-known example of a system that enriched contractors and built FAA careers, despite its near-universal rejection by the industry, and ultimately, it took intervention by Congress to kill it. As expected, much better, cheaper, and more versatile technology is now coming online—the Global Positioning System, or GPS, which uses satellites for precision navigation.

The revolutionary approach requires that virtually every system be scrapped and replaced all at the same time, all while still providing a full level of service with zero tolerance for accidents, 24 hours a day, seven days a week. It amounts to remodeling a house by tearing it down to the foundation first before rebuilding it, while trying to live in it at the same time.

Not only are there other solutions to FAA’s funding needs, but these solutions are readily available to the FAA. The technology needed to modernize the air traffic control system to meet future capacity demands and budget constraints, while enhancing the level of aviation safety, exists today. Most of it has been developed and tested, and the FAA can bring it online in time to meet capacity needs with much less money than anyone might expect. This is where the scenario developed by The Mitre Corporation comes in. We think it holds tremendous promise.

Mitre has identified four areas where technology that exists today can produce incremental change sufficient to handle future capacity needs and increase ATC system cost-efficiency, as well as providing substantial savings to the airlines. A Mitre report to the FAA’s National Airspace System Modernization Task Force presented November 3-4, 1997, identified these four initial technical enhancements to the air traffic control system—Collaborative Decision Making, Conflict Probe, Data Link, and Center TRACON Automation System (see Figure 2). Mitre’s plan simply takes advantage of the useful parts of the current system instead of scrapping the entire system and starting from scratch. It would incur dramatically smaller costs than even the original price tag for the NAS plan, and complement the FAA’s urgent need to fund the replacement of the ATC host computer system by 2000. Most importantly, the Mitre approach allows the Congress and the users to understand the risks associated with these technological investments, a concept we never saw employed by the revolutionary approach to modernization.

We are pleased with the overall response that FAA Administrator Jane Garvey has given the recommendations of the Task Force on Modernization, which takes the “evolutionary, not revolutionary” approach to heart and relies on the Mitre proposal, which we have long advocated, for its guidance. I hope the FAA takes this path, and I urge Congress to lend its full support for it.

GPS/WAAS

Let me turn to the issue of the Global Positioning System (GPS) and the Wide Area Augmentation System (WAAS), a program that will have the largest impact on virtually every community in your respective states and our members. I testified to this committee last year and expressed AOPA’s strong support for the WAAS program, so I won’t repeat the details today. We believe GPS/WAAS will ultimately serve general aviation as a sole means system for en route through Category I precision approach capability (200 feet, 1/2-mile visibility minimums), and we urge the FAA not to delay this program.

On a related issue, we are very pleased that DOT is revisiting its plan to terminate loran-C service in 2000. AOPA has repeatedly urged the DOT to continue loran-C service until augmented GPS system proves itself ready serve as a sole-means navigation system for general aviation, and users are prepared to reap the benefits. Congress should encourage the FAA to retain loran-C as a backup system for GPS/WAAS as long as it is necessary.

Mr. Chairman, I would like to request that the Committee support full development of WAAS as part of its FAA reauthorization bill this year and carefully scrutinize any proposed cuts.

Flight 2000

Flight 2000 as it is currently named is a program that has experienced difficulties due mainly to a lack of focus on its purpose. The Mitre Corporation has called for redefining the objective of Flight 2000 to serve as a tool to mitigate risk in future communication, navigation, and surveillance programs. While we generally support that concept, the program must have stated specific objectives and a schedule. The program remains unfocused and undefined. The FAA needs to state the nature of the datalink with aircraft. Will it be voice only, data only, or both? What surveillance tactics do they envision?

The administration is requesting $90 million to fund the program for FY99, and $300 million over four fiscal years. This is a significant amount of money that should be justified with a solid program that enjoys a clear objective. Also, we understand that 40 percent of this request is for equipment acquisition. The Committee should closely scrutinize acquisition for Flight 2000 and whether it is appropriate for the government to purchase equipment from vendors who will reap the benefits of re-equipping the fleet. I should add that the status of Flight 2000 should not affect that decision to go forward with WAAS.

The FAA must assure that a consensus has developed in the aviation community before pursuing Flight 2000. Otherwise, it could balloon into another “big bang” program.

Airport Improvement Program: Protecting and enhancing our investment

Mr. Chairman, I’d now like to turn to one of the federal government’s most successful infrastructure investment programs: the Airport Improvement Program. AOPA believes that Congress should concentrate on protecting and enhancing the federal investment in our national airport system as an essential component in the economy.

We believe Congress can best achieve these goals in three steps.

First, AOPA has previously pointed out that a change in policy relating to the amount airports are allowed to collect for PFCs could open the door to a smaller and more effective Airport Improvement Program. However, we also understand the reality of the current situation and therefore support funding AIP at $2 billion for FY99. This will assure full funding for the nation’s growing airport needs. The NCARC and the rest of the aviation community is united in its support for full AIP funding.

Second, Congress should reauthorize AIP for a five-year period. As you know, Mr. Chairman, Congress reinstated the aviation excise taxes for 10 years as part of the Taxpayer Relief Act of 1997. A five-year reauthorization would put the final piece of the puzzle in place to enhance confidence in the federal government’s commitment to meeting airport infrastructure funding needs in the long term.

Third, Congress should consider programmatic improvements to AIP aimed at protecting our federal investment.

FAA is ignoring grant assurances

The FAA’s oversight of airports participating in the AIP must be improved and given teeth. The FAA’s enforcement efforts are plagued by badly written grant agreements and selective enforcement. While some of the problem is a lack of resources for enforcement, the FAA is also “release happy.” It can take years for an airport to get an AIP grant, but the FAA will often swiftly allow the release of properties purchased or improved with AIP funds for sale or non-aviation purposes.

For instance, one airport that received $14 million in AIP funds was recently granted a release to sell some of the land purchased with AIP funds, with absolutely no input from the users, following an unsuccessful attempt by the sponsor to close the airport outright. It is obvious that the sponsor is slowly but surely accomplishing its initial objective of closing the airport. This is an example of how the FAA will grant the sponsor’s requests through “normal procedures” without considering the long-term interests of the airport or its users.

Another example is a general aviation facility that has gained more and more air carrier traffic. As the airport sponsor concentrated on serving the air carriers, it neglected general aviation and other users. A small runway, used for general aviation and serving as a cross wind runway as well, was allowed to be closed by the FAA airports division despite the air traffic control division’s clear statement that the runway has a definitive aeronautical use. The runway was used to separate air carriers from other aircraft and reduce delays. Will the next step be for the sponsor to use resulting delays from reducing airport capacity to push general aviation out of the airport entirely?

Currently, no process for public comment or input on these cases exists. Some airports are alleged to divert revenue to off-airport use in violation of the law. This includes not only the well-known examples at major airports, but at general aviation airports as well. At one small airport, it has been alleged that the sponsor has diverted up to $2 million of airport revenue to its general fund. Airport property is used as an industrial park, and the revenues generated by the park are not being credited to the airport.

At another airport, the FAA found that the airport sponsor used airport facilities and land rent free, failing to ensure that the airport fund receives reasonable compensation for all leased property. Another example involves a different airport whose sponsor may be using revenue from the sale of airport property to maintain roads within the nearby industrial park.

Compliance must become a priority

The FAA must be as vigilant over taxpayer dollars as they are in enforcing certification and safety regulations. We believe the approach taken by the Committee to the reauthorization of AIP should be based on the principle that compliance should be as important to the FAA as the actual dispensing of grants and a meaningful deterrent capability will discourage future violations.

Specifically, we recommend this Committee give FAA the tools it needs to improve enforcement by directing the FAA to restructure the regional staff of the Office of Compliance (ARP-400) so that it reports directly to the headquarters level, ARP-1 (Airports) and authorize adequate resources for enforcement. This would remove regional influences and distance enforcement responsibilities from those approving and disbursing the grants—people who traditionally view airport sponsors as “customers.”

Congress should also give the FAA the ability to levy fines on airports violating grant assurances. Currently, the FAA can only refuse future grants, but that is often not a credible threat. Another solution is to require that a process be established for the release of airport properties and non-aviation uses of land purchased with AIP dollars. This process should include public comment and a final public FAA justification for the release. The process should take into account the interests of the public and users, but not interests of the sponsor not related to aviation or the interests of airport businesses at the expense of users. Releases granted, as well as significant changes to the airport layout, should take into consideration future airport needs and growth and airport capacity and delays, and should not facilitate unjust discrimination against specific aeronautical users or activities. The FAA should also require that sponsors accepting AIP grants have enabling state law and local zoning ordinances in place to prevent development around airports that contributes to the demise of the airport.

We hope the committee will also consider other programmatic improvements. The committee could expand and make permanent the demonstration program allowing the use of AIP funds for maintenance purposes. Another issue worthy of attention is the liability of airport sponsors for aviation accidents. When a sponsor has failed to secure navigation aid equipment funded by the FAA through the FAA’s facilities and equipment account, it often uses AIP funds instead. However, the sponsor is then liable for accidents instead of the FAA. The committee should explore ways to give sponsors relief in these situations.

Let me close by summarizing: Using an evolutionary, not revolutionary, approach, modernization of the air traffic control system can and ought to be achieved without expenditures on a titanic scale.

Mr. Chairman, this concludes our comments. Thank you again for the opportunity to present our views. I will be happy to respond to any questions.