Final Blog 

April  20, 2018

By - Kalan Foster 

Flight & Duty Regulations 

In my original blog, I sided with cargo air carriers. I said that cargo carriers are exempt from part 117 due to the catastrophic financial toll these rules and regulations can take on the aviation industry in general. These rules and regulations could cripple the cargo industry and the consequences could potentially bleed over into other industries, collapsing the market and reducing the amount resources available in the United States. I understand the backlash from both cargo operators and pilots. The pilots feel as though they deserve more rest because of the increased stress and difficulty of flying at night. The cargo operators don't want to adapt the new rules because it would cost the industry about 300 million dollars. If the new regulations were adopted cargo pilots would fly less and make less money (cargo rest/duty periods). 

I believe all of those things were true but I have decided to take it a step further and provide more information regarding how these changes are necessary for cargo pilots.

Cargo Pilots 

I have decided to side with the cargo pilots regarding the most recent changes to Part 117. The FAA and the NTSB have stated the most significant issue associated with early morning and overnight flights is pilot fatigue. Throughout history the FAA has avoided making changes to policies until major accidents occur, cargo pilots have decided to take a stand and fight for changes regarding policies that are flawed. Two years after the FAA decided they were not going to include cargo operators to Part 117 a UPS pilot clipped a tree crashing just before the runway (“UPS Boeing 757 cargo plane crash,” n.d. p.1). Pilot fatigue appeared to be one of the contributing factors in this crash and it led to the death of two cargo pilots. The NTSB analyzed the cockpit recorder and both pilots mentioned tiredness before the crash, UPS also did not provide the pilots with a weather briefing prior to departure. UPS also failed to perform a software update of the plane's Enhanced Ground Proximity Warning System, which tells pilots when they are flying too low to the ground.

 This accident could have been avoided if the FAA would have included cargo operators into Part 117, but they believe the cost of including cargo operators outweighs the lives involved with future accidents when they made that decision. It took the Independent Pilot Association (IPA) four years to sit in court to argue their case regarding pilot fatigue within the cargo industry and even after that fatal accident the FAA was silent on this issue (“UPS Pilots Make Oral Argument,” n.d. p.1). This issue is real, and hundreds of pilots fly in unsafe conditions every day and those circumstances need to change. The increased workload has also contributed to the pilot shortage, and the pilot shortage has taken a great toll on the industry in general. 

Pilot Shortage 

The increased cost of training caused the pilot shortage. New pilots can’t afford to invest thousands of dollars into flying in the beginning of their careers and as a result, the aviation industry is suffering. This change did more harm than good because its creating unsafe work environments for cargo pilots, the cargo industry is overworking its current pilots due to the shortage causing an increase in fatigue. The 1500-hour rule was created because airlines could not give their pilots the proper resting period which led to the shortage of pilots. Pilots find it difficult to consult with members of management regarding the rest and duty periods if a pilot is unsafe to fly there are consequences. 

Closing 

Pilots should feel comfortable to admit when they are tired, and they should be able to speak with members of management without the fear of losing their position. Operating an aircraft under unsafe conditions can lead to a pilot losing their certificate and I believe that is unfair considering the current state of the industry. Part 117 needs to be updated immediately to include cargo pilots to reduce the unnecessary amount of risk for cargo operators. If the FAA won’t include cargo operators into part 117 they have to reduce the 1500-hour rule allowing more growth within the industry.

References 

www.faa.gov/documentLibrary/media/Advisory_Circular/AC%20117-3.pdf.

“Cargo Rest/Duty Periods .” Flight Time/Duty Time for Air Cargo,

UPS Boeing 757 cargo plane crash last year resulted from pilot errors and fatigue. (2014, September 11). AirGuide Business. Retrieved from http://link.galegroup.com.ezproxy.emich.edu/apps/doc/A384022300/ITOF?u=lom_emichu&sid=ITOF&xid=dfcb7672

UPS pilots suing to join new U.S. fatigue policy. (2011, December 22). Retrieved from https://www.reuters.com/article/us-usa-airlines-fatigue/ups-pilots-suing-to-join-new-u-s-fatigue-policy-idUSTRE7BL1BX20111222

March 31, 2018 

By - Kalan Foster 

Aviation Organizations 

There several aviation groups that are beneficial depending on the pilot's field of study. After the Colgan accident, the rest and duty regulations were changed but they didn't include cargo pilots. The FAA was challenged by The Independent Pilot Association (IPA) regarding the rulemaking decision in the U.S. Court of Appeals, the FAA asked the court to suspend the lawsuit to perform a cost-benefit analysis(“UPS Pilots Make Oral Argument,” n.d. p.1). The IPA never stopped fighting for the rights of cargo pilots, it took the Independent Pilot Association (IPA) four years to sit in court to argue their case regarding pilot fatigue within the cargo industry and even after that fatal accident the FAA was silent on this issue. The Black Pilots of America (BPA) have done a great job providing job opportunities to African American and provide information lower-income communities to young aspiring pilots. The BPA has also provided funding for workplace discrimination cases against African American Pilots.  is also a great group to belong to, they provide free seminars across the united states, they provide scholarships to college student and they also find ways to give back to the community. All of these values align with my professional and academic future, one day I would love to give back to the community through these organizations. In the future, I want to become a cargo pilot and I believe it important to be involved with groups like the IPA in the future to unite and stand together. 

Career Development Opportunities 

All of the organizations listed have multiple opportunities for growth within their respective communities. IPA hires pilots to provide research and data for lawyers to fight cases for cargo pilots. The BPA hires Pilots to perform discovery flight for different communities, they also have a teaching program for younger pilots ages 16-18. The Organization of Black Aerospace Professionals has partnered with a local flight school to branch off and help grow the industry in this way. 



References 

UPS Pilots Make Oral Argument Before the D.C. Circuit to Challenge Cargo Exclusion from Rest Rule. (n.d.).Travel & Leisure Close-Up.

Home. (n.d.). Retrieved from http://www.obap.org/

Global Airlines: Is It a Fair Playing Field?

March 17, 2018 

By - Kalan Foster 

Global Airlines: Is It a Fair Playing Field?

Implementing the US-UAE open skies agreement was a way to reduce the amount of responsibility and the involvement of the US government. The international air transportation sector is a very lucrative part of our industry and to avoid and political corruption it's best if they stay out of this part of the industry. The agreement, signed by the U.S. Department of State, permits the other country’s airlines to establish offices in the territory of the other Party for the promotion and sale of air transportation  (US Department of State. 2002, March 11). 

These are the rules listed under the open skies agreement (US Department of State. 2002, March 11):

• The right to fly across its territory without landing.
• the right to make stops in its territory for non-traffic purposes. 
• Each Party shall have the right to designate as many airlines as it wishes to conduct international air transportation in accordance with this Agreement and to withdraw or alter such designations.
• On receipt of such a designation, and of applications from the designated airline, in the form and manner prescribed for operating authorizations and technical permissions, the other Party shall grant appropriate authorizations and permissions with minimum procedural delay.
• While entering, within, or leaving the territory of one Party, its laws and regulations relating to the operation and navigation of aircraft shall be complied with by the other Party's airlines. 
• Either Party may request consultations concerning the safety standards maintained by the other Party relating to aeronautical facilities, aircrews, aircraft, and operation of the designated airlines.
• The airlines of each Party shall have the right to establish offices in the territory of the other Party for the promotion and sale of air transportation.
• The airlines of each Party shall be permitted to pay for local expenses, including purchases of fuel, in the territory of the other Party in local currency.

The dispute between the US's three largest airlines and their overseas counterparts has been ongoing for years. The government has decided not to intervene and revoke the open skies agreement because of the dispute. There are no provisions anywhere in the open skies agreement regarding subsidies, the goal for US air carriers seems to be to create and issues to create reform for the open skies agreement. The case they have brought to the UAE Ambassador is that these air carriers should be considered unfair competition and removed from the agreement (Townsend, S. 2017, December 04). Fly Emirates and Qatar Airways do in fact receive subsidies from their government, but because there aren't any provisions in place to negate the increase in competition US air carrier have been lobbying the UAE Ambassador stating that these practices are unfair. 

There are several US Air carriers that receive subsidies from our government. Delta, JetBlue, and American airlines all receive subsidies, but it's not as nearly as much as their middle eastern counterparts (Flows, C. 2016, November 17). Delta has decided to target these airlines specifically because they are funded by their government, but they also partner with Chinese competitor that provide unfair rates. Unfortunately, our government can't pay these airlines huge subsidies because we have plenty of other issues outside of the aviation sector.

The Export-Import bank allows air carriers to take out loans and finance projects and these rates are guaranteed to be below market values to foreign buyers. Foreign companies buy their aircraft from here and export them back overseas because its cheaper and they receive a lower export tax (Export-Import Bank of the United States. n.d). Buying these aircraft at a cheaper rate allows them to sell cheaper faires making it more difficult for US Carriers to compete.  This option is unavailable to US air carriers become they pay US taxes anyways and its suppose to increase the profit of these manufacturers. 

Norwegian Air Internation (NAI) has gone years without being approved by the US to participate in the open skies agreement. They want to provide direct flights from Cork and Shannon to Boston for more affordable rates, the average cost of a round-trip ticket is about $400, NAI has projected around trip flight would cost around $140 (Posaner, J. 2016, September 02). Emirates and Qatar are a huge threat to the industry and they have the potential to ruin international trade between the US and the middle east and that's another reason why Delta has been trying to create more pressure. 

These issues are like walking on a tightrope, I want to say that they aren't playing fair but they aren't breaking any laws. I think its safe to say that these international air carriers don't have a business code of ethics and they aren't professional on that level of thinking but they are within their rights. I think the US Government should do what they can to ensure that our industry continues to thrive if these impacts are industry enough to cause job shortages or the loss of businesses I believe at that point they should intervene. Its very important to put America first in that regard but until it gets to that point I believe the answer to this question lies in the future. 

References

US Department of State. (2002, March 11). Air transport agreement: U.S. UAE air transport agreement of March 11, 2002. Retrieved March 17, 2018, from https://www.state.gov/e/eb/rls/othr/ata/u/ 

Townsend, S. (2017, December 04). US-UAE Business Council optimistic Open Skies Agreement will remain. Retrieved March 17, 2018, from https://www.thenational.ae/business/us-uae-business-council-optimistic-open-skies-agreement-will-remain-1.68099

Flows, C. (2016, November 17). Government Airline Subsidies... So What? Retrieved March 18, 2018, from https://www.forbes.com/sites/realspin/2016/11/17/government-airline-subsidies-so-what/#5dc514671f5f

Export-Import Bank of the United States. (n.d.). Export Finance Solutions to Increase Sales for U.S. Businesses [PDF file]. Retrieved march 17, 2018, from https://www.exim.gov/learning-resources/publications

Posaner, J. (2016, September 02). Norwegian airline clouds open skies. Retrieved March 17, 2018, from https://www.politico.eu/article/norwegian-airline-nai-ireland-us-open-skie

March 4th, 2018 

By - Kalan Foster 

FAA Administrator 

Donald Trump has nominated his private pilot to be the next FAA administrator, and his credentials are based on an article published in news week: “He’s managed airline and corporate flight departments, certified airlines from start-up under FAA regulations,” they said, pointing out Dunkin “oversaw the Trump presidential campaign’s air fleet, which included managing all aviation transportation for travel to 203 cities in 43 states over the course of 21 months. (News Week)”. This article was released on multiple platforms, once he’s seriously considered I believe his credentials will be officially questioned. Based on the evidence provided online there's no evidence indicating that he isn't fit for the position, I don't believe fair to introduce a biased opinion this early. 

Daniel K. Elwell is the Acting Administrator of the Federal Aviation Administration (FAA). Mr. Elwell was the Deputy Administrator of the FAA prior to his temporary promotion. He was also the assistant administrator for policy, planning, and environment for two years. Most recently he was also the Senior Advisor on Aviation to the secretary of transportation (FAA).

The previous FAA Administrator was Michael Huerta. He was the Associate Deputy for the U.S. Transportation Secretary, he was the Chief of Staff for the U.S. Transportation Secretary, and he was also the deputy administrator of the FAA prior to being the FAA administrator.

Randy Babbit was the FAA administrator prior to Michael Huerta. He had flown with Eastern Airlines for 25 years, and he also was acting president of ALPA for 8 years.

Bobby Sturgill is also in the running to become the next FAA Administrator. Sturgill has been a pilot in both civil and military positions, Sturgill is now in charge of a company Rockwell Collins in which he’s the Vice President of operations. Sturgill created a bad rep earlier in his career introducing legislation that left ATC exhausted and overworked while he was acting as the FAA administrator.

The FAA Administrator is responsible for the safety and efficiency of the United States airspace system. He’s in charge of managing the budget which is $16.4 billion dollars, approximately 47,000 employees, and is responsible for ensuring that the airline industry is complying with all the federal laws.

NextGen is a very delicate project, I believe this next milestone within the Aviation industry should be led by someone who already has experience within the FAA or the NTSB. The FAA Deputy seems like the position that prepares candidates to accept this role, I believe they should hire someone within the industry to ensure these projects receive the much-needed attention they require.


Sources
Lanktree, G. (2018, February 26). Who is John Dunkin? Trump wants his personal pilot to head America's aviation regulator. Retrieved March 04, 2018, from http://www.newsweek.com/who-john-dunkin-trump-wants-his-personal-pilot-head-faa-819300

Daniel K. Elwell. (2018, January 10). Retrieved March 04, 2018, from https://www.faa.gov/about/key_officials/elwell/

Space Tourism

February 21, 2018 

By - Kalan Foster 

Space Tourism 

Space tourism is slowly becoming a reality for space enthusiasts and explorers all over the world. In the 1960’s, the idea was explored by several different companies. During the development of the Saturn V, NASA was exploring the future possibilities of space transportation and tourism. NASA was developing the first space shuttle for an expedition to the moon. The development of space tourism has been slow due to the lack of funding and the risks associated with space travel. In 1969, the first moon expeditions were successful, and Neil Armstrong was the first man to land on the moon.

NASA was making great progress until tragedy struck in 1986, the booster engine failed which lead to the death of seven team members (“Remembering the Challenger Crew”, 2015, March 09. The tragedy was so great that they decided to step away from space tourism temporarily out of the respect they had for the crew and their family members. Two years prior Congress established the Commercial Space Launch Act in 1984, which addressed many concerns the public had with these types of programs. The government wanted these programs heavily regulated; this law addressed the basic requirement for licensing and insurance, to a type of facilities that were required, and all programs required governmental authorization. After the accident, they changed this policy and limited the role of Commercial flight operations carried out by NASA. Flight exploration is very dangerous, I believe that the technology needs to be mastered prior to space exploration to reduce the amount casualties. The other laws that went into effect were the Commercial Space Act of 1998 and Commercial Space Transportation Competitiveness Act in 2000. These two rules increased government control and regulations, space exploration is very dangerous and it should be taken very seriously.

 - The Challenger Crew

After the 1960’s, there has been a total of 550 people who have traveled in space. Most of those people were trained for two years, but between the years of 2001-2009, some of the expeditions were tourism flights (“how many people,” 2016, March 02).  Jeff Benzo, Blue origins founder, was one of the first to develop a space tourism program. The program is still in development and Jeff has stated that they plan on launching tourists into space as soon as 2019 (“Blue Origin CEO”, n.d.). Tesla is also working with SpaceX, they’re projecting that they will start launching passengers in the fourth quarter of 2018 (“Blue Origin CEO”, n.d.). I believe space exploration will be possible very soon and the initial trips will be very expensive. I believe if there aren’t any major accidents that these space tourism programs will be very accessible and affordable to the public in the next decade. I would compare space exploration to skydiving, people who are brave enough will experience it and if its something they love they will invest money and time. I think that maybe in the next century space exploration as a means of transportation will be very possible, technology is always advancing.

The qualification to work in the space tourism is very minimal, you are only required to have and private pilot certification, and sub-orbital training.

Sub-orbital training consists of the following:

• Hypobaric altitude chamber testing
• Hands-on training on Star City's many simulators.
• Orlan space suit training.
• Centrifuge training
• Vestibular training
• Personal zero-gravity flight

It takes approximately two years of flight training to become certified. I spoke with a representative from the Yankee Air Museum, I know him personally. He told me that It very difficult to enter this field because it's so specialized, he also told me a degree in physics makes it easier to be recognized by potential employers.   

Refrences 

Good Question: How Many People Have Gone To Space? (2016, March 02). Retrieved February 22, 2018, from http://minnesota.cbslocal.com/2016/03/02/good-question-astronauts/

Smith, B. (n.d.). Blue Origin CEO: We're taking tourists to space within 18 months. Retrieved February 22, 2018, from http://money.cnn.com/2017/10/05/technology/future/blue-origin-launch-human-space-tourism/index.html

Administrator, N. C. (2015, March 09). Remembering the Challenger Crew. Retrieved February 22, 2018, from https://www.nasa.gov/multimedia/imagegallery/image_gallery_2437.html

UAVs

February 09, 2018 

By - Kalan Foster 

The Future is UAV's 

UAVs have become very popular in the 21st century and in 2014 they became a mainstream sensation over the holidays. The drones were much more affordable, durable, and they were less sophisticated than ever before. Drones are currently being used for recreational purposes, they’re being used sports, photography, videography, and tourism. Recreational drones must be registered with the FAA, they must weigh less than 55 pounds, they must be labeled with a registration number, and the owner must be 13 years or older. 

Source - Becoming a pilot 

Part 107 consists of the following: 

Unmanned aircraft must weigh less than 55 pounds, including payload, at takeoff

Fly in Class G airspace*

Keep the unmanned aircraft within visual line-of-sight*

Fly at or below 400 feet*

Fly during daylight or civil twilight*

Fly at or under 100 mph*

Yield right of way to manned aircraft*

Do not fly directly over people*

Do not fly from a moving vehicle, unless in a sparsely populated area*

The commercial use of UAV’s falls under part 107. However, the pilot must be certificated through the FAA; which consists of passing the aeronautical written exam, completing the RPC application, and a TSA background check. 

Commercial use of UAV

UAV’s are commercially operating in several different countries and the United States is lagging in the development of commercial operations. In a recent report UAV’s are being used for search and rescues in Australia, they are working on UAV’s that can operate in harsher climates. According to the verge “Lifeguards are testing out new drone technology in Australia have saved two people stranded off the coast of New South Wales state, as spotted by Quartz. The drone footage shows a birds-eye view of the ocean before the drone ejects the yellow floatation device, which inflates when it hits the water. The two teenage boys were caught about 700 meters (0.4 miles) offshore at Lennox Head in a swell of around three meters (9.8 feet). They were able to grab onto the floatation device and swim to shore”(PBS). 

- Little Ripper Life Saver 

In Canada UAV’s were used in an emergency. There was a fatal car accident that rolled off the road in Ontario, emergency responders were unsure that there were any victims. The terrain was difficult to navigate for responders, heavy forest coverage, and very steep. There has been a big demand from the health and administration to remove BFOV for emergency responders. In Canada it was approved, the received permission to fly UAV’s four nautical miles for search and rescues. So far, the government has been able to recognize how beneficial removing the BFOV from government entities and first responders (Theglobalandmail). 

NAS & UAVs

The integration of UAV’s into the national airspace system is imminent, they have already started testing the possibilities of integrating UAVs in simulations. NASA has a project in which they are trying to find safe and efficient was to integrates UAVs into the airspace. They are working on a system called Detect and Avoid or DAA for short. This feature will be used to program UAV’s to avoid incoming aircraft by deviating from its original course. This program will cost more money for both airport and airlines. Airports would have to restructure its operations and increase its workforce (NASA). 

Military Warfare

The military application of UAV’s has changed warfare greatly. The biggest change in drone warfare happened in 2002, the predator was used in Afghanistan to monitor al-Qaida. The predator was used as a targeting system for bombs, it was also used for search and rescues. Drones were the greatest threat to any military operation, they’re quiet, covert, and lethal. Drones are extremely efficient, and they are great for military operations. The predator is approximately $10,000 and its successor the reaper is approximately $13,000. These drones have reduced the cost of operations for the military because how efficient they are. Ethically the pilots have made great mistakes and the training required to operate these drones has increased significantly. 

Job Outlook

The association for unmanned vehicle systems international has projected that the job outlook for drones will increase by 100,000 jobs in the next decade.

 Here’s a list jobs available currently: https://momentumsolar.com/careers/ | https://www.goarmy.com/careers-and-jobs/browse-career-and-job-categories/transportation-and-aviation/unmanned-aerial-vehicle-operator.html | https://www.indeed.com/cmp/Minnesota-Department-of-Transportation/jobs/Unmanned-Aircraft-System-27018cac3fe8a522?q=Drone+operator&vjs=3 

References 

Becoming a Pilot. (2017, February 10). Retrieved February 09, 2018, from https://www.faa.gov/uas/getting_started/part_107/remote_pilot_cert/

Unmanned Aircraft Systems (UAS) Frequently Asked Questions. (2018, February 01). Retrieved February 09, 2018, from https://www.faa.gov/uas/faqs/\

Press, J. L. (2014, December 10). Other countries are surpassing the US in commercial drone flights. Retrieved February 09, 2018, from https://www.pbs.org/newshour/nation/countries-surpassing-us-commercial-drone-flights

Drones offer Ontario paramedics unprecedented and game-changing perspectives. (2018, January 17). Retrieved February 09, 2018, from https://www.theglobeandmail.com/news/national/drones-offer-ontario-paramedics-unprecedented-and-game-changing-perspective/article37631225/

Dunbar, B. (2015, April 02). Unmanned Aircraft Systems Integration in the National Airspace System. Retrieved February 09, 2018, from https://www.nasa.gov/centers/armstrong/news/FactSheets/FS-075-DFRC.html

Flight & Duty Regulations 

Febuary 2, 2018

By - Kalan Foster 

Part 117

The Colgan accident raised many questions and concerns regarding the current state of the airline industry and its approach to safety. The FAA oversaw enforcing and promoting safety, but they failed the aviation community and the public in this regard. If safety was their top priority this accident and the new unnecessary legislation could have been avoided. 

According to AC No: 117-3:

Regulatory Obligation - "Each flightcrew member must report for any FDP fit for duty, which includes being properly rested and prepared to perform his or her assigned duties. Fitness for duty is a joint responsibility between the air carrier and the flightcrew member. Part 117 imposes regulatory obligations on both air carriers and flightcrew members regarding fitness for duty. The joint responsibility is established in § 117.5(b), which requires that no certificate holder may assign and no flightcrew member may accept an assignment to a FDP if the flightcrew member has reported for a FDP too fatigued to safely perform his or her assigned duties". (AC 117)

Hours of Rest and Sleep -  "Managing rest and sleep opportunities are essential for reducing the risk of being unfit for duty due to fatigue. A joint responsibility is again placed on the air carrier and the flightcrew member in § 117.25(e)(f), which prescribes that no flightcrew member may accept an assignment for any reserve or FDP unless that flightcrew member is given a rest period of at least 10 consecutive hours immediately before beginning the reserve or FDP measured from the time the flightcrew member is released from duty. The 10-hour rest period must provide the flightcrew member with an opportunity of a minimum of 8 hours of uninterrupted sleep. If the flightcrew member determines that the rest period will not provide an opportunity of 8 uninterrupted hours of sleep, that flightcrew member must notify the certificate holder. The flightcrew member cannot report for the assigned FDP until he or she receives a minimum of 8 hours of uninterrupted sleep opportunity". (AC 117)

- The maximum flight per day shift is 9 hours and 8 hours per night shift. 

*Note - Previously the legislation required 9 hours of rest, which has the potential to be equal o or less than 8 hours depending on the needs of the business. 

Part 117 does not apply to 14 CFR Part 291. Cargo carriers are encouraged to comply with part 117 standards and procedures, but they are not required. The standard for cargo operations have not changed post the Colgan accident. 

Cargo carriers are exempt from part 117 due to the catastrophic financial toll these rules and regulations can take on the aviation industry in general. These rules and regulations could cripple the cargo industry and the consequences could potentially bleed over into other industries, collapsing the market and reducing the amount resources available in the United States. I understand the backlash from both cargo operators and pilots. The pilots feel as though they deserve more rest because of the increased stress and difficulty of flying at night. The cargo operators don't want to adapt the new rules because it would cost the industry about 300 million dollars. If the new regulations were adopted cargo pilots would fly less and make less money (cargo rest/duty periods).

For the reasons previously stated, I believe cargo operators should remain exempt from the new rules. As an airport manager the regulations would increase the stress and workload of everyone, and it could ruin startup companies and decrease growth industry wide. If pilots continue to pressure the FAA to force the industry to adopt these standards, this would cause the pilot shortage to increase, and it collapse new businesses. 

Refrences 

“117-3.” Advisory Circular Part 117, www.faa.gov/documentLibrary/media/Advisory_Circular/AC%20117-3.pdf.

“Cargo Rest/Duty Periods .” Flight Time/Duty Time for Air Cargo, www.alpa.org/alpa/DesktopModules/ViewAnnDocument.aspx?DocumentID=5524.