AVmail: Sep. 13, 2004

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Reader mail this week about cell phones in airliners, spin training, and VFR over-the-top, and a LOT of comments on air traffic controller 'Jane Doe's' letter.


Cell Phones in Airplanes

After a recent AVweb article that recommended readers review the material on the NASA Aviation Safety Reporting System (ASRS), I followed the recommendation and read the report on Passenger Electronic Devices (PED). The prospect of cell phones on airplanes (now) scares me to death! I hope the PIC exercises his authority and overrides corporate policy by prohibiting use of these devices.

Ray Montagne


Airport Closures and Other Anti-Aviation Stuff

Why not create a No-Fly list of these folks who were happy to see Meigs Field go away, and all the other NIMBYs (Not in My Back Yard), and noise complainers? When they want to buy a ticket to go visit the kids or take a trip, the response they'll get from the reservationist would be, "Sorry, guess you'll have to drive. Because of your anti-aviation attitude -- bringing more rules, fewer airports and costlier flying -- there aren't enough pilots, so sorry, take the bus!"

Terri Lee Jones


Spin Training

After reading Mr. Megginson's letter (AVmail, Sept. 6), I tried to find some relevant information from Transport Canada. I found their published report on stall/spin accident evaluation. The author makes two main points about the value (or lack thereof) of spin recovery training:

(a) "... One feature that stands out in all except one of the 39 stall/spin accidents examined is that knowing how to recover from the stall or spin was of no benefit to the pilots in these circumstances. They stalled at altitudes so low that once the stall developed, a serious accident was in progress. Safety will be advanced therefore by preventing stalls and spins ..."

(b) "... In Canada, the stall/spin accident rate is not appreciably different from the American experience... Canada is not gaining an obvious safety dividend from the current approach to spin training and testing ..."

The report does not say that "... Canadian pilots were actually significantly more likely to die in stall/spin accident ..." as Mr. Megginson said in his letter. Maybe he had access to some other reports.

Dave Newcombe


Everyone Should Rebel

Reference the article, "Aussie Pilots Rebel (Really) Against Airspace Rules," (NewsWire, Sept. 9):

We should take heed here in the States. The Aussie's say a handful of union pilots drove the new airspace rules that effectively shuts down much of their airspace. If you think this could not happen here in the states, you are living in a dream world. Whether it is union influence (which is tremendous in itself) or pure politics, this is the direction we are heading. There are many powerful interests that want to close the sky down to GA aviation.

Their actions to protest the closing of airspace should be applauded by all pilots everywhere. Isn't it interesting that the reduction in freedom to fly in the name of safety forces a response that may impact safety ... no flight plans, no transponder use, no ATC use? I think that is where we are heading. Will we be forced into a similar flight situation?

Dale Carlson


Why Do You Fly?

You left out the most obvious response to the Question of the Week, "Why do you fly?" (QOTW, Sep. 9):

Because I can.

Steve Mann


Banner Towers Say "I Told You So"

I have a unique perspective to your article "Banner Towers Say 'I Told You So' " (NewsWire, Sep. 2).

I used to be a banner tower and was displaced because of the shutdown of airspace over sport and other events that has now affected the Cleveland National Air Show.

When I was 11 years old my father and older brother started a family business towing banners. My two brothers and I spent our teen years growing up on airports across the great lakes region of the United States. As we grew so did the family business and our love for aviation. Eventually my older brother (Jim) started his own banner towing business and carried on the family trade. I went to college while my younger brother (Matt) started his professional pilot career by towing banners. During college I obtained my commercial pilots rating, funded by my older brothers' business. I then began towing banners to pay for my commercial pilots rating and helped pay my way through an Aerospace Engineering degree at the University of Michigan. For several very enjoyable years I was able to fly banners across the great lakes region with my brothers and other pilots that would become very good friends.

After the terrorist attacks we all understood the closure of airspace across the country. But as airspace restrictions began to lift in the weeks and months following, we were horrified to see TFRs remain over events that are the very livelihood for banner towers. Hoping for strength in numbers, an organization was formed (U.S. Aerial Advertisers Association) by banner towers across the country. My brother was asked to act as president of their new organization and head the efforts to lift restrictions. Despite protests and pleas from the organization and other aviation related ventures that depend of the freedom of airspace around stadiums, eventually legislation was passed sealing the loss of their right to fly near stadiums during events. During our pleas to Congress, they presented numerous facts of the reality of the TFRs (their complete lack of effectiveness to stop any real attack) and the way the legislation was written. The TFRs did not stop blimps and helicopters for media coverage from flying in the airspace, and the legislation was written so it did not stop traffic patterns for certain airports affected. Essentially it only affected a certain group of aviators. Banner towers are well-known entities where the same pilots fly the same events for many many years. The aircraft are small and light, with what amounts to a drag chute connected to the back of the plane that limits its speed to 60 mph. Considering this with the TFR dimensions of three miles and 3000 feet, what portion of general aviation are the lawmakers protecting the public from? Considering that banner towing was started in 1926 and has never had a recorded instance of an event spectator being injured or killed by a banner tower makes it one of the safest inclusions to a sporting event. The legislation simply makes no sense whatsoever.

I have never again flown with my brothers like we did before 9/11 and have regrettably come to realize that I likely never will. I was lucky, in that I was near the end of college and could move on in a new direction in a different region of the country. Had things been different, I would have likely not have had to move. Many of the people I used to fly with have had to move on. My older brother has continued to soldier on with his business trying to keep some vestige of the old trade alive and still takes great pride in flying his billboard-size U.S. flag when possible. I have never seen someone work so hard to be able to work so hard with no rewards. After what has become years of going at it alone, though, he has little else to say other then what your article so plainly said: "We Told You So."

It's simply a shame to know that a way of life (our American way) has ended because of lawmakers that don't care and won't listen to reason. This whole experience has made me realize that the terrorist may have attacked us on September 11, 2001, but their work of destroying the American way of life is being conducted from Capital Hill. Because I grew up with this group of fine people who are as American as apple pie I can truly feel their frustration. There is a certain romance when numerous fabric-covered taildraggers comprised of Supper Cub's and Citabria's are parked in the grass in preparation of an afternoon's flying over your favorite college's football stadium. This way of life is simply no more and -- even if restored -- will never be the same.

Thomas R. Miller


VFR Over-The-Top

I must respectfully disagree with Mr. William Shumann of the FAA on the question of the legality of flying VFR over an undercast cloud layer (AVmail, Sep. 6).

The argument of an engine quitting (assuming it's a single-engine plane, I suppose; could be a twin or a glider or a balloon) is bogus. Having an IFR clearance is not necessary since the required visibility and cloud clearance criteria are met. Pilots frequently obtain an IFR clearance to climb through a cloud layer and then cancel IFR when above. What one person thinks is imprudent is not necessarily illegal. You can legally fly VFR at night over mountains or miles offshore over water without floatation devices. It's more risky, but it's not necessarily "consummately stupid" as another reader put it.

Some would consider that flying in a small airplane is stupid and crazy. Or riding a motorcycle, or rock climbing, or skydiving. Some people take more risks than others would because they enjoy a particular activity.

Not having a backup plan or disregarding the consequences of the increased risk is stupid, but partaking in risky but rewarding activities is not stupid in itself. It's about risk management, not risk avoidance.

Flying VFR over an undercast can be a lot less risky than flying at night, for instance. It depends on the circumstances; such as, say, flat farmland below with a reasonably high ceiling and plenty of fuel to return to known-clear weather. The law leaves it up to the pilot to decide when the risk is too much for him or her. It it not one of those simple circumstances that can be legislated ahead of time.

Besides, it is still legal to fly IFR in IMC in uncontrolled airspace without an ATC clearance. And how does an IFR clearance make an engine failure any safer? You'd still bust the minimum legal IFR altitude on your way down, anyhow.

Having that IFR clearance will not, in most cases, increase the level of safety while flying over an undercast. Having an instrument rating would. And getting VFR flight following and filing a VFR flight plan would as well. Those things are for each pilot to consider when confronted with the particular weather and terrain during his or her flight and is not dictated in the FARs.

Finally, the FARs specifically prohibit student pilots from flying without visual reference to the ground. The lack of this wording for other pilot certificate levels is essentially proof that it is allowed.

Peter Sturdza


Hmmm. I think you'd better check Mr. Shumann's answer, because it seems to disagree with both the FARs and the FAA Instrument Flying Handbook, which says:

VFR Over-The-Top must not be confused with VFR-On-Top. VFR-On-Top is an IFR clearance that allows the pilot to fly VFR altitudes. VFR Over-The-Top is strictly a VFR operation in which the pilot maintains VFR cloud clearance requirements while operating on top of an undercast layer. This situation might occur when the departure airport and the destination airport are reporting clear conditions, but a low overcast layer is present in between. The pilot could conduct a VFR departure, fly over the top of the undercast in VFR conditions, then complete a VFR descent and landing at the destination. VFR cloud clearance requirements would be maintained at all times, and an IFR clearance would not be required for any part of the flight.

I don't see anything in Part 91 prohibiting VFR over the top flight, although there are some limitations for large turbojets and additional limitations in part 135 and elsewhere for commercial operations.

Near as I can tell, as a non-commercial operator, you either meet VFR cloud clearance and visibility requirements or you don't, undercast or not. Mr. Shumann may be thinking that FAA could use one of their shotgun "careless and reckless" violations against someone who lost an engine atop an overcast and had to descend through it, but that's clearly an emergency and it would be an interesting argument for them to make.

In any event, the notion that flying VFR above an overcast automatically requires a VFR on top (i.e., IFR) clearance appears to be incorrect.

Scott Dunham


The assertion that VFR flight might be illegal above a broken or overcast layer that puts the aircraft beyond engine-out gliding distance from a VFR approach and landing is not logical. If the same rationale applied to IFR flight, then one could not file for a route above an overcast layer that did not provide a certain minimum ceiling and visibiliy and be within gliding distance of an airport with an IFR approach, as it would be equally, or more hazardous than the VFR pilot above a broken layer with good ceiling and visibility below.

Neither is a good idea, but in reality it occurs frequently.

Dick Lawrence


Controller Shortage

Editor's Note

We received almost two dozen letters about "The 'REAL' Story On The Controller Shortage" (NewsWire, Sep. 9). We couldn't print some really good ones because they weren't signed. We can withhold publication of your name on AVmail, but we cannot publish your letter if we don't have your full name on file.

Kevin Lane-Cummings
Columns & Features Editor


It would seem that "Jane Doe" has made a nice career of being a controller. She claims that she has been doing this for 20 years. Someone, or the Union, has obviously been protecting her for those 20 years. What kind of money is she making? Sounds to me that she has had her feet stepped on by the Union and this is her way of retaliating. As the old saying goes, if you ain't happy doing what you're doing, go find something better.

David E. Wackerling


I am a senior manager in Techical Operations, formerly known as Airway Facilities. I have over 31 years in the FAA. "Jane" was kind in her assertions. She only touched the tip of the iceberg. Her letter was right on target and I realize the political machine will never admit these things nor ever do the hard work to correct them. We all talk about these things privately but never publicly. Thanks to Hollywood and the union, the public has been duped for years on the nebulous "stress" and "high complexity" of the job. Bunk!

Jane is also correct in telling you that she would be in big trouble if she were identified. Union brothers/sisters can be very vindictive and work life would be impossible for her.

Good article and I like the way you handled the whole issue. Thank you for getting it out there.

Name Withheld By Request


I just finished reading the "Jane Doe" letter regarding air traffic controller productivity and the controller's union. Some interesting points, but a lot of puzzling irrelevancies, too. My knee-jerk reaction was to wonder why the writer continues to work as a controller in an environment that she obviously finds unpleasant; but if she's been doing it for 20-plus years, maybe she's got a pension-vesting ball-and-chain holding her there.

Not being an air traffic controller (and not having slept at a Holiday Inn Express last night), I can't comment on the controller-specific issues she raises, but it's obvious she hasn't kept tabs on how things are at other work environments. A lot of the things she's objecting to with regard to use of vacation time, sick leave policy, dress code, action taken against drug abusers, and so forth, are actually pretty standard in many work environments, and it puzzles me that she objects to them. Does she really not want to be allowed to use all the vacation she accrues? She wants to have to provide a doctor's note for every single sick day she uses? She would like to work for an employer who reveals private medical information about employees, such as substance abuse, to everyone? She wants a business-attire dress code imposed? And this would improve ATC services how?

Jane Doe's most puzzling comment was, "The controllers' union is staffed with very smart individuals. But these individuals do not have the best interest of the FAA in mind when they negotiate work rules."

Maybe I'm missing something here, but I sorta thought that a labor union is supposed to represent the best interests of the workers, not the employer. Does she really want to be represented at the bargaining table by a labor union that advocates for the employer, not the employees?

One of the most interesting things about her letter is that -- while she takes pot-shots at the union and complains about a lot of different things -- not once does she state explicitly what she really does want. Since she touches on issues of safety and waste of taxpayer dollars, and says she "will respond to any e-mail request from you or your organization," perhaps AVweb can find out from her what proposals she has for improving ATC safety or efficiency, rather than just what she's unhappy about?

Karin Cozzolino


First, my professional background:

FAA 1959-1981 (Reagan)
DOD 1987-89 (Earned retirement)
Contract tower 1996-2003
Rehired FAA 2004, resigned 2005

Retirements are going to hurt all the facilities in the next five years because everyone was hired at the same time. The staffing at this point is just crazy. No one works over half the shift. Time-off awards for doing your job. The contract tower I worked at had about three times the traffic of my last FAA facility: The contract tower had eight people, the FAA tower had 19. You should hear the controllers complain if they don't get every other hour off. The centers are more overstaffed than the towers. Friends at the center tell me two to three hours a day is normal, and if you want a no hitter (work no positions all day), it is pretty easy.

The FAA gave away the store under the last administrator ... pay, benefits and staffing. Now the union runs the show, a true example of the tail wagging the dog.

Name Witheld By Request


Glenn,

You may recall meeting me at ###. I was an Air Traffic Controller and first-line ATC supervisor at several high density FAA facilities including 12 years at LAX. I retired with 36.5 years of Govt. service as a Controller. I went through the 1980's PATCO strike. This was a difficult time for those who stayed on the job, but a total disaster for most of the strikers.

The extensive (anonymous) letter from the lady controller is an accurate portrayal of many (certainly not all) FAA ATC facilities since the inception of a Controller's Union. Weak, poorly-qualified management and overly zealous union Reps have allowed such abuses to fester. She has my admiration for comin forth at great risk.

The lady describes a situation where the inmates are running the asylum and that is the unfortunate truth at too many FAA facilities. Controller pay scales have reached a level the public would not believe and in many cases not justified by the workload. There are a lot of luxury level cars parked at an FAA facility.

Enroute (Center) facilities in the less desirable living areas (NY Center is always a classic example) have typically had trouble keeping a full staff of Journeyman level controllers. It's a miserable place to work and the resulting ATC on-air attitude is palpable. At LAX and SAN (now SOCAL) Approach there was/is always a list of cold weather controllers trying to get out.

The Big City types earn their money. But for every Chicago or Atlanta TRACON there are two dozen lesser facilities where they make serious bucks and gripe if they have to put in over 4 hrs per shift actually working traffic. Leaving work 30-45 minutes early is considered a right. They won't bid on a high density facility because they no longer need the extra money.

Bearing in mind that the average controller is just a high school graduate with a few years of military ATC experience or a low time GA pilot who qualified for the test. So the $100K+ they make is beyond anything dreamed of 20 years ago. And the workload has NOT significantly increased no matter what anyone says. You can only handle so many airplanes before you put a hold on things. Working a Friday night arrival rush with the old non-computerized radar was a challenge today's controllers wouldn't believe. Three to four hours on position was normal. But the day sure went fast and we seemed to thrive on it. Flow Control; What’s that..? The "Give em a third (or more) chance" philosophy in training has allowed some less-than-adequate people into the ranks. But..they're union members and NATCA will protect them.

The fault lies NOT with the controllers. They are simply greedy like everyone else. FAA management from a series of politically appointed INEPT Administrators to the lower level Regional managers have allowed the ATC personnel situation to deteriorate while they were dumping billions on "Star Wars" stuff the controllers told them wouldn't work as advertised by the contractors.

Because so many "Civilians" look on Air Traffic Control as some kind of mystic science, most legislators just stay away from this subject. It's sort of like the aura that surrounds the medical profession. Retirement at age 50 with 20 years of ATC service is like having a money tree in your back yard. 50% (or more) of your base pay for life.

Following the PATCO strike, many fired controllers could only qualify as supermarket baggers. I saw our facility union rep handing out cheese samples at a local mall. I took no joy in that. Prior to the strike, many borrowed the max amount from the FAA Credit Union and then left them holding the bag. Our Western Region Credit Union almost went under. I doubt they'll ever make that mistake again.

What's the answer..? I don’t have any special wisdom but it’s got to start at the top. ** I picture a Chuck Yeager or Curt LeMay type running the show from the BIG OFFICE in DC; "Play by the rules or you're outta here.." .. "Sell me some junk and you'll never get another FAA contract and you won't get paid for this one.." ** Separate the FAA from DOT. It's cumbersome and adds a another level of political stupidity by clueless bureaucrats. ** Good controllers do not necessarily make good supervisors..

Some controllers are over paid and under worked. At the BIG and busy places..they earn every dime. But they are still Govt. employees and subject to a code of conduct. NATCA is NOT going to strike a la PATCO. They will lose. Cell phones while working a position..? Unthinkable! If the Facility Chief wants a dress code that is something above beach wear.. that's his privilege. Set it and enforce it.

For $100K+ a year you should expect to work hard. If you don't like it: get out and find something else. Abuse Sick Leave frequently ..for example.. get a few days off without pay. It's time to put some bright, motivated and qualified people at the top and shake things up a bit. The day-to-day controller will take every "freebie" he can get.. as will any other group of workers. It’s human nature. There is little old fashioned "loyalty" to the profession. Neither management nor The Union has fostered such an environment.

When Pres. Reagan fired about two-thirds of the controllers, nobody believed it would last. After a few months without pay most of them were begging (pleading) to come back and all the "job stresses" they complained about didn't seem so bad after all.

Name Witheld By Request


I am an Air Traffic Controller now working at Mesa's Falcon Field. Currently, Falcon is the nation's 43rd busiest facility (total traffic). I have been a controller for over 23 years, having been hired less than a week after the strike in 1981. In that time I have worked at a tower/TRACON, a top 5 tower and now at Falcon.

This morning, I read with great interest the account of "Jane." She raised several issues to which I take great exception! I will not elaborate on all her points, but on the following:

1. Staffing verses retirement. I am glad that Jane's facility is overstaffed. It is nice to know that someplace in the system there is a facility that is ready for the looming retirement boom. Such is not the case at my facility. We currently have 10 controllers. While we are authorized 12, getting new controllers in the building has been very difficult (last year the FAA hired 1 new controller, or half of my needs). Of the 10 of us, 20% can retire today. By this time next year 40% of the workforce can walk out the door. If Jane is dissatisfied with working one hour on position and one hour on break we urge her to come to Falcon Field. Several mornings we work four hours without a break, while the evening crew work the final three hours "break free." And our staffing is not the exception, but the rule. Recently the FAA instituted reduction of operations in and out of the nation's busiest airport. The reason ... staffing (or lack thereof). The same is true at all centers and most major approach control facilities.

2. Jane mentions CRU-X by name. The purpose of CRU-X is to track and report the movements of FAA personnel. This tracking program has cost the FAA (and you the taxpayers) millions while having serious bugs. Jane says this would expose controller's work habits. Well, Jane, here are our habits: If I am not on position then I am on a break (when we get one), attending mandatory briefings, or doing collateral duties (updating training manuals, inputting traffic information, attending pilot/controller briefings and the like). This tracking program has thousands of options and is geared towards technicians, staff specialists and management. Having received basic training on CRU-X, I can say that the program is very cumbersome, and inputting information is laborious to say the least.

3. The high use of annual leave is true. However, it is not restricted solely to controllers. As federal civilian employees, our accruing of annual leave is based on our federal service. When the employee has reached 15 years of service, they receive 8 hours of annual leave per two week pay period. That equates to 204 hours of leave per year (this is the amount that Jane makes). We are allowed to carry over 240 hours of leave per year. Any amount over 240 is lost. So, yes, we do take leave. We have earned it -- we should be able to use it. Chances are good that Jane uses as much of her annual leave as her co-workers.

4. Sick leave is a problem. But not in the way Jane explains it. The majority of the work force are in their mid- to late-40s. As we grow older, the more likely it is that we will become sick. Fact of life. Anyone with a legitimate medical condition should use sick leave. But there is more than just being sick. The FAA is fanatical when it comes to medications. Makes sense. User safety cannot/will not/shall not be compromised because a controller had an adverse reaction to a medication. (As an example: Having Novocain at the dentist requires 18 hours before a controller can return to work.) If the FAA had its way, we would not be allowed to take aspirin Then too, I certainly do not want to work with someone who has a cold, the flu or whose child has Chicken Pox (I have not had that). Stay home, get well, then come back to work. We work in very close proximity in our tower; contagions are swift and sure. Agreed, controllers who take sick leave because it is guaranteed are wrong. The FAA, however, is responsible to track those who use sick leave when annual is denied, or in conjunction with a day off. Instead of reprimanding those employees, the FAA chastises all of us (recently sick leave reprimands were sent to anyone who used a certain amount of sick leave, including those who donated leave to others). As is the norm, the FAA uses a broad brush (more on this later). Once again, it is understandable when a controller has worked several six-day/10-hour shifts to want an extra day off. Unfortunately, using sick leave is the only way this may be accomplished.

5. It is sad that illegal drugs are pervasive in our society. I wish I could say that controllers are immune, but we are not. With very few exceptions (like police), every agency and private entity has a drug treatment program. So does the FAA, much to their credit. A controller must enroll into a treatment program, then receive numerous random tests (for what I believe is the rest of their career), as well as other accountability items before they can return to work. But two strikes and you're out ... period.

6. The main issue is the relationship between management and controllers. While the main point in the 1981 strike was money, the underlying theme was the lack of respect and contempt management had for controllers. In the ensuing 23 years, nothing has changed. I'm lucky that I now work for a great manager, one who puts the needs of the controllers above his ambitions. This has not always been the case. At my previous facility, management (supervisors on up) didn't trust controllers to flush the toilets correctly, let alone handle aircraft. To get respect, one must show respect. Yes, we are arrogant! Our job demands perfection with each and every radio transmission and operation. Millions of lives rely on our doing our job ... perfectly. Such perfection commands some type of conceit. Every controller I know believes they are the best in the agency (ask me, I'll tell you), and as a group we are -- Jane included. Putting 11 of us in a 10-foot by 10-foot room is bound to create some friction. It would be safe to say that controllers want to work that busy traffic. We live for it, we thrive on it; anything less ... well I want the busy traffic. All a controller wants is to be left alone to practice their craft. Working traffic is an art form, and as artists we resent management standing over the shoulder questioning our every move. A good manager knows how to delegate the work. If Jane's manager allows too few controllers to work, while the rest are on break, that isn't the responsibility of the controllers. It is the easy way out to let the CIC (controller-in-charge) make the decision, then the manager saying, "What's the problem? I didn't do anything. You controllers did this to yourselves." The CIC has limited supervisory responsibility, and ultimately it falls to management to assign work. Each facility has a "minimum" staffing number per shift. Fall below that number and either a certified staff specialist, supervisor or overtime controller must be used.

7. And finally there is NATCA, the controllers union. Every officer in the National Air Traffic Controllers Association is a controller. They have first-hand knowledge of the problems we in the tower/radar room encounter daily. Be it an overbearing supervisor, bad equipment, or other workplace hazards, our union has seen and worked with it. Our union is strong because management is weak. It is the job of the union to protect its members. Errors by management, as cited by Jane, were the reasons controllers were re-cycled through training. The union ensures that agreements are adhered to so that all controllers are dealt with in a fair and impartial manner. Break the rules (even if it means that a comma was omitted) and the employee must be given a second chance. The issue is that our union is better trained than management. Again, not our fault.

8. From top to bottom, we (controllers and the union) see waste and abuse: Countless billions of our taxes were spent on a radar system that didn't perform (during the late 80s), new systems that are ordered only to be cut (STARS), the acquisition of technology that is at least five years old (more likely 10), or inadequate maintenance of current equipment. Upper-level facility managers/regional managers/Washington managers going to Hawaii for "meetings," or the countless hours management seem to spend hours vilifying workers when other, more-pressing issues face each facility. This is what we face ... day in and day out.

In the final analysis, it is the ineptitude of the FAA that has caused Jane's problems, not NATCA.

James "Beamer" Bermant


Please do not confuse NATCA terminal and en route controllers with those in the Flight Service option. Flight Service controllers average six hours and 57 minutes "on-the-position" time out of their eight-hour day. One 30-minute lunch and two 15-minute breaks, traffic permitting.

Mark Chanter
FTW AFSS


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