Aviation Safety: FAA's Use of Emergency Orders to Revoke or Suspend
Operating Certificates (Testimony, 08/06/98, GAO/T-RCED-98-253).
Pursuant to a congressional request, GAO discussed the Federal Aviation
Administration's (FAA) use of emergency orders to suspend or revoke
aviation operating certificates, focusing on the: (1) extent to which
FAA used emergency orders; (2) ways in which changes in FAA's policies
might have affected the agency's use of emergency orders; and (3) time
needed for FAA to investigate alleged violations and issue emergency
orders.
GAO noted that: (1) of the 137,506 enforcement cases closed in fiscal
years (FY) 1990 through 1997, FAA initiated 3 percent using emergency
orders; (2) FAA's nine regions differed in how frequently they issued
emergency orders partly as a result of their different enforcement
practices; (3) most of the emergency orders were issued to pilots for
either their operating certificates or their certificates of their
medical fitness to fly; (4) seventy-seven percent of the enforcement
cases initiated as emergency actions resulted ultimately in the
suspension or revocation of the certificate holder's operating
certificate; (5) five percent resulted in FAA's dropping the case
because it determined that no violation was committed or that it had
insufficient evidence to prove a violation; (6) the outcomes were not
specified for six percent of the cases, and the remainder involved a
variety of other outcomes; (7) in 1990, FAA decided that, for those
cases in which revocation are based on a demonstrated lack of
qualification to hold the relevant certificate, the certificate
generally should be revoked immediately and not after the lengthy appeal
process that nonemergency certificate actions can be subject to; (8) FAA
informally implemented this policy change in 1990 and 1991 before
formally incorporating it into its compliance and enforcement guidance
in 1992; (9) this shift in policy is reflected in the increase in the
numbers of emergency actions GAO observed: FAA initiated 184 revocations
using emergency orders in FY 1990; (10) in subsequent years, over 320
emergency revocations were issued, on average, each year; (11) although
the use of emergency orders is intended to expedite the handling of
serious enforcement cases, the time needed for FAA to investigate
violations and issue emergency orders varied widely, frequently taking
several months or longer; (12) for half of the enforcement cases in FY
1990 through FY 1997, FAA issued the emergency order within about 4
months after learning of the violation; (13) for the remainder, the time
needed to investigate and issue the order ranged from just over 4 months
to over 2 years; (14) during this time, the certificate holder could
continue to operate, that is, to fly or repair aircraft and possibly
pose a safety risk; and (15) while it is necessary for FAA to act
swiftly in cases that present an immediate threat to safety or a
demonstrated lack of qualifications, some aviation attorneys in the
private-sector have questioned whether it is appropriate or necessary
for FAA to handle some cases as emergencies, especially if the
violations occurred years before.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-RCED-98-253
TITLE: Aviation Safety: FAA's Use of Emergency Orders to Revoke or
Suspend Operating Certificates
DATE: 08/06/98
SUBJECT: Air transportation operations
Airline industry
Airline regulation
Pilots
Administrative remedies
Safety regulation
Transportation safety
Commercial aviation
Licenses
Aircraft maintenance
IDENTIFIER: Valujet Flight 592
TWA Flight 800
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Cover
================================================================ COVER
Before the Subcommittee on Aviation, Committee on Transportation and
Infrastructure, House of Representatives
For Release
on Delivery
Expected at
9:30 a.m. EDT
Thursday
August 6, 1998
AVIATION SAFETY - FAA'S USE OF
EMERGENCY ORDERS TO REVOKE OR
SUSPEND OPERATING CERTIFICATES
Statement by Gerald L. Dillingham,
Associate Director, Transportation Issues,
Resources, Community, and Economic
Development Division
GAO/T-RCED-98-253
GAO/RCED-98-253T
(348122)
Abbreviations
=============================================================== ABBREV
FAA -
FAR -
NTSB -
============================================================ Chapter 0
Mr. Chairman and Members of the Subcommittee:
We appreciate the opportunity to testify about the Federal Aviation
Administration's (FAA) use of emergency orders to suspend or revoke
aviation operating certificates.\1 As you know, FAA is responsible
for examining and testing the qualifications of airmen, such as
pilots, mechanics, and flight engineers, as well as of aviation
entities, such as airlines, airports, and repair stations, that seek
a certificate to operate. FAA also periodically conducts inspections
of airmen and aviation entities to monitor their compliance with the
Federal Aviation Regulations (FAR). When FAA detects violations of
the FAR by such certificate holders, it has a range of actions it can
take to enforce compliance with the regulations. These options range
from administrative actions, such as warning letters, to "certificate
actions" to suspend or revoke an individual's or entity's operating
certificate.\2 FAA may take certificate actions on a nonemergency
basis, in which case the certificate holder may continue to operate
until the matter is adjudicated. However, if FAA determines that the
public interest and safety require the immediate suspension or
revocation of an operator's certificate, the agency can issue an
emergency order, a type of certificate action which takes effect
immediately on issuance.
Since the fatal crashes of ValuJet Flight 592 in May 1996 and TWA
Flight 800 in July 1996, FAA's oversight of the aviation community
and the agency's enforcement actions in response to violations have
come under increased scrutiny. While some have criticized FAA for
not responding swiftly or forcefully enough to safety violations,
others have questioned its haste in using emergency orders to suspend
or revoke the certificates that pilots, airlines, and others need to
operate.
At the request of Senator James M. Inhofe, we recently completed a
review of FAA's use of emergency orders during fiscal years 1990
through 1997.\3 Our report provided information on (1) the extent to
which FAA used emergency orders, (2) the ways in which changes in
FAA's policies might have affected the agency's use of emergency
orders, and (3) the time needed for FAA to investigate alleged
violations and issue emergency orders.
In summary,
-- Of the 137,506 enforcement cases closed in fiscal years 1990
through 1997, FAA initiated 3 percent (3,742) using emergency
orders.\4 (See fig. 1.) FAA's nine regions differed in how
frequently they issued emergency orders partly as a result of
their different enforcement practices. Most of the emergency
orders were issued to pilots for either their operating
certificates or their certificates of their medical fitness to
fly. Seventy-seven percent of the enforcement cases initiated
as emergency actions resulted ultimately in the suspension or
revocation of the certificate holder's operating certificate.
Five percent resulted in FAA's dropping the case because it
determined that no violation was committed or that it had
insufficient evidence to prove a violation. One percent were
overturned on appeal. The outcomes were not specified for six
percent of the cases, and the remainder involved a variety of
other outcomes.
Figure 1: FAA's Use of
Emergency Orders to Initiate
Enforcement Cases Closed in
Fiscal Years 1990-97
(See figure in printed
edition.)
Source: GAO's analysis of data from FAA's Enforcement Information
System.
-- In 1990, FAA decided that, for those cases in which revocations
are based on a demonstrated lack of qualification to hold the
relevant certificate, the certificate generally should be
revoked immediately and not after the lengthy appeal process
that nonemergency certificate actions can be subject to. FAA
informally implemented this policy change in 1990 and 1991
before formally incorporating it into its compliance and
enforcement guidance in 1992.\5 This shift in policy is
reflected in the increase in the numbers of emergency actions we
observed: FAA initiated 184 revocations using emergency orders
in fiscal year 1990. In subsequent years, over 320 emergency
revocations were issued, on average, each year.
-- Although the use of emergency orders is intended to expedite the
handling of serious enforcement cases, the time needed for FAA
to investigate violations and issue emergency orders varied
widely, frequently taking several months or longer. For half of
the enforcement cases in fiscal years 1990 through 1997, FAA
issued the emergency order within about 4 months after learning
of the violation. For the remainder, the time needed to
investigate and issue the order ranged from just over 4 months
to over 2 years. During this time, the certificate holder could
continue to operate, that is, to fly or repair aircraft and
possibly pose a safety risk. While it is necessary for FAA to
act swiftly in cases that present an immediate threat to safety
or a demonstrated lack of qualifications, some aviation
attorneys in the private sector have questioned whether it is
appropriate or necessary for FAA to handle some cases as
emergencies, especially if the violations occurred years before.
--------------------
\1 FAA's use of emergency revocation orders is the subject of
proposed legislation that would provide the certificate holder with
the right to appeal the emergency nature of a revocation order before
the National Transportation Safety Board (NTSB). This legislation
adds a requirement for FAA to show just cause for bringing an
emergency revocation action against a certificate holder. (See S.
842, introduced on June 5, 1997, and H.R. 1846, introduced on June
10, 1997.)
\2 A certificate suspension may be for a definite period (e.g., 30
days) or it may be indefinite (e.g., until the holder demonstrates
qualifications to hold the certificate). When a certificate has been
revoked, the former holder loses any right to use the certificate.
\3 Aviation Safety: FAA's Use of Emergency Orders to Revoke or
Suspend Operating Certificates (GAO/RCED-98-199, July 23, 1998).
\4 We restricted our analysis to enforcement cases that FAA closed in
fiscal years 1990 through 1997. The enforcement cases that FAA
initiates using an emergency order to revoke or suspend an operating
certificate may ultimately be resolved in a variety of ways,
including the revocation or suspension of a certificate, the
imposition of a civil penalty (fine), or the expiration of the
certificate. (See table II.3.)
\5 FAA Order 2150.3A.
BACKGROUND
---------------------------------------------------------- Chapter 0:1
FAA detects violations during safety and security inspections and
also from such outside sources as public complaints or police
reports. When FAA finds that certificate holders have violated
aviation regulations, it has the statutory authority to take
appropriate action. FAA's options for responding to violations range
from administrative actions to legal actions, such as fines or
certificate actions. The option chosen depends on such factors as
the seriousness of the violation and the violator's prior enforcement
history and willingness to comply with regulations. Both FAA's
inspections and the processing of its enforcement cases are generally
carried out by its regional offices.
An emergency order revoking an operating certificate is the most
severe enforcement action that FAA can take against a certificate
holder. An emergency order is generally used when a certificate
holder is not qualified and may make use of the certificate\6 or
demonstrates a lack of care, judgment, and responsibility by, for
example, operating an aircraft while under the influence of drugs or
alcohol. An emergency order takes effect immediately on issuance.
The certificate holder does not have an opportunity to contest the
order before it is issued, and, unlike nonemergency certificate
actions, the emergency order remains in effect while the certificate
holder appeals. Emergency orders can be appealed to the National
Transportation Safety Board (NTSB) and the U.S. Court of Appeals.
(See app. I for more information on the appeals process.)
--------------------
\6 If a pilot is in prison or in the hospital, for example, an
emergency order would not be needed because the pilot would be unable
to use the certificate.
FAA'S USE OF EMERGENCY ORDERS
---------------------------------------------------------- Chapter 0:2
FAA used emergency orders in a small percentage of its enforcement
cases. Of the 137,506 enforcement cases closed in fiscal years 1990
through 1997, FAA initiated 3 percent using emergency orders. The
actual number of emergency orders ranged from a low of 322 in fiscal
year 1990 to a high of 573 in fiscal year 1996. On average, FAA
closed 468 cases annually in which it had initiated enforcement
action using emergency orders. (See table II.1.)
REGIONAL USE OF CERTIFICATE
ACTIONS AND EMERGENCY ORDERS
VARIED
-------------------------------------------------------- Chapter 0:2.1
FAA regions varied in their use of emergency orders to initiate
certificate actions; these differences appear to result in part from
differences in enforcement practices. FAA used emergency orders to
initiate 18 percent of its certificate action cases, on average, for
fiscal years 1990 through 1997, but three regions initiated from 28
to 38 percent of their certificate actions using emergency orders.
(See table II.2.) These differences among the regions reflect, in
part, unusually high numbers of emergency orders to suspend or revoke
medical certificates in the Eastern, Western-Pacific, and Southwest
regions.
While most regions issued no more than a handful (one to five) of
emergency orders to revoke or suspend medical certificates annually
during this period, the Southwest region averaged nearly a dozen
annually, and the Eastern and Western-Pacific regions averaged almost
25. Officials at these offices and at FAA headquarters were unsure
why these regions initiated so many more emergency orders for medical
certificates than did the other regions. However, they speculated
that differences in enforcement practices in FAA's regional offices
apparently affect whether emergency orders are used to revoke or
suspend a medical certificate. One regional counsel suggested that
some regions may handle medical certificate cases as nonemergency
certificate actions. Another regional counsel suggested that the
staff in her region were simply efficient in processing these cases,
while in other regions, the certificates of pilots that do not meet
requirements may simply be allowed to expire. (Medical certificates
must be renewed every 6 months to 3 years, depending on the type of
pilot.)
EMERGENCY ORDERS MOST OFTEN
ISSUED TO PILOTS
-------------------------------------------------------- Chapter 0:2.2
Nearly 60 percent of the emergency orders issued in the period we
reviewed affected pilots: 1,563 pilot certificates and 625 medical
certificates were revoked or suspended. (See fig. 2.) Pilot
certificates represent the largest category of certificates FAA
issues.
Figure 2: Types of Certificate
Holders Affected by Emergency
Orders, Fiscal Years 1990-97
(See figure in printed
edition.)
\a Operators include, for example, airport operators, agricultural
operators, scheduled and on-demand air carriers, and scheduled cargo
carriers.
Source: GAO's analysis of data from FAA's Enforcement Information
System.
MOST CERTIFICATE ACTIONS
INITIATED USING EMERGENCY
ORDERS RESULTED IN
REVOCATIONS OR SUSPENSIONS
-------------------------------------------------------- Chapter 0:2.3
A high percentage of the certificate actions initiated using
emergency orders ultimately resulted in revocations or suspensions.
Of the 3,742 cases that were initiated using emergency orders and
that were closed in fiscal years 1990 through 1997, 77 percent of
these resulted in the individual's or entity's losing the
certificate. Five percent of the cases initiated as emergency
actions ultimately resulted in the case being dropped with no
enforcement action being taken, while 1 percent were overturned on
appeal. (See table II.3.) FAA's database did not specify an outcome
for six percent of the cases. The majority of the remaining cases
were resolved by allowing the certificate to expire, by having
operators successfully complete a reexamination of their
qualifications, or by the imposition of a fine.
According to FAA officials we interviewed, the high numbers of
emergency orders that were upheld for suspension and revocation
reflects the fact that the agency takes emergency orders,
particularly revocations, very seriously and is reluctant to initiate
them without clear and convincing evidence. They strongly agreed
that emergency revocations were used in cases in which individuals or
entities lacked the qualifications for the certificate or
demonstrated a lack of care, judgment, and responsibility by, for
example, falsifying material aviation records or operating aircraft
while under the influence of drugs or alcohol. We were told that
requests to initiate emergency revocations against individuals are
scrutinized at the local and division levels within Flight Standards
before being referred to legal staff for action, while cases against
air carriers and repair stations undergo additional review at FAA
headquarters.
REDEFINITION OF EMERGENCY HAS
AFFECTED FAA'S USE OF EMERGENCY
REVOCATIONS
---------------------------------------------------------- Chapter 0:3
A change to FAA's policy broadened the circumstances in which the
agency uses emergency orders. Although the policy change applied to
both emergency revocations and emergency suspensions, FAA officials
focused on the rule's impact on the agency's use of revocations.
According to FAA officials we interviewed, prior to 1990, many
revocation actions had been taken on a nonemergency basis. In 1990,
FAA concluded that an emergency order is appropriate when a
revocation is warranted in the interest of public safety because the
certificate holder lacks qualifications. Under these conditions, the
revocation should generally be taken immediately. If the revocation
is not taken immediately, the certificate holder could continue to
operate for months or even years until the appeal process is
completed. FAA informally implemented this policy change in 1990 and
1991 before formally incorporating it into FAA Order 2150.3A in
February 1992. As a result, FAA increased the use of emergency
orders to initiate revocations from 184 in fiscal year 1990 to 327 in
fiscal year 1992. In fiscal years 1993 through 1997, 303 emergency
revocations were issued, on average, each year. (See table II.4.)
FOR HALF OF THE CASES, MONTHS
ELAPSED BETWEEN FAA'S LEARNING
OF THE VIOLATION AND ISSUING
THE EMERGENCY ORDER
---------------------------------------------------------- Chapter 0:4
The use of emergency orders is intended to expedite the handling of
serious certificate actions. For half of the emergency actions we
analyzed, however, more than 4 months elapsed between the time FAA
learned of the violation and the time it issued the emergency
order.\7 During this period, FAA inspection staff investigated the
violation, reached a preliminary determination that an emergency
suspension or revocation was warranted, and then transferred the case
to legal staff for the review and preparation of the case and the
issuance of the emergency order. According to an FAA official, the
use of an emergency order is not necessarily envisioned when FAA
first learns of a violation and initiates its investigation.
Although FAA has established no specific time frames for completing
investigations and issuing emergency orders, these were completed
within 10 days for 4 percent of the cases and within a month for 11
percent of the cases. Half of the cases, however, required more than
4 months (132 days) from the date of violation until FAA issued the
emergency order. (See table II.5.) The majority of this time was
spent on investigation, rather than preparation of the emergency
order by FAA's legal staff.
We discussed these time frames and FAA's use of emergency orders with
officials from FAA and NTSB, as well as with a number of aviation
attorneys from the private sector. They provided a variety of
opinions that reflected the tension between FAA's responsibility to
act prudently in investigating thoroughly before revoking or
suspending a certificate and its responsibility to act swiftly in
cases that present an immediate threat to safety or a demonstrated
lack of qualifications. The scope of our review of FAA's use of
emergency orders did not permit the kind of case analysis that would
determine how much time FAA expended on each investigation,
particularly in more complex cases, or whether FAA had struck the
appropriate balance between these competing responsibilities.
FAA officials offered several reasons why some cases can take months
to investigate and prepare. For example, both inspectors and legal
staff have many other responsibilities besides investigations and the
preparation of emergency orders, such as accident investigations. In
addition, certain types of cases may take longer because they are
complex, involve the falsification of maintenance or training
records, or require extensive checking of these records. The fact
remains, however, that months often elapse between the occurrence of
a violation, the time FAA learns of that violation, and the date the
agency issues an emergency order of suspension or revocation. During
this time, a certificate holder who could lack qualifications or who
could represent a threat to safety could continue to operate.
In contrast, the private sector attorneys we interviewed questioned
whether it is appropriate for FAA to use emergency orders for some
violations that are years old or for cases that have required months
to investigate and issue. While they acknowledged the need for an
enforcement tool that allows FAA to act swiftly when aviation safety
is a concern, they raised questions about whether some violations
represented an immediate safety threat.
--------------------
\7 Our analysis focused on the time between when FAA learned of the
violation and the time of issuance of the emergency order, rather
than on the length of time between the actual occurrence of the
violation and the last legal action taken to close out the case. We
chose this time frame because the agency has a fair amount of control
over the time needed for investigation, case preparation, and the
issuance of the emergency order. In contrast, FAA has less control
over the time between when a violation occurs and when it learns of
the violation, or the amount of time that it must wait before all
appeals are completed so that the case is resolved and can be closed
out.
-------------------------------------------------------- Chapter 0:4.1
Mr. Chairman, this concludes our statement. We would be pleased to
respond to any questions at this time.
FAA'S PROCESS FOR APPEALING
EMERGENCY CERTIFICATE ACTIONS
=========================================================== Appendix I
When faced with an emergency order, a certificate holder has several
appeal options. First, the certificate holder can appeal the
emergency nature of the order. The certificate holder may seek a
direct review of FAA's emergency determination by a federal court of
appeals.\1 In such cases, the certificate holder petitions the court
for a review of the emergency order and seeks a stay of the order.
According to the Assistant Chief Counsel in FAA's Enforcement
Division, such cases are generally decided by the federal court of
appeals within 5 to 7 working days.
The certificate holder may also appeal the underlying merits of the
emergency order to the National Transportation Safety Board (NTSB),
where the case is adjudicated by an administrative law judge. The
certificate holder must appeal within 10 days after receiving the
emergency order from FAA. The presiding administrative law judge's
initial decision is made orally at the end of the hearing and is
final unless appealed. Any appeal by the certificate holder or FAA
of the initial decision must be filed with NTSB within 2 days of the
hearing, and the entire matter must be resolved within 60 days of the
date on which the FAA Administrator advised NTSB of the emergency
nature of the order. Further appeals are available to both FAA and
the certificate holder in the federal courts of appeals. Figure I.1
shows the steps in initiating and appealing an emergency order.
Figure I.1: Steps for
Initiating and Appealing
Emergency Orders
(See figure in printed
edition.)
Source: FAA Order 2150.3A.
--------------------
\1 49 U.S.C. section 46110.
TABLES RELATED TO FAA'S USE OF
EMERGENCY ORDERS
========================================================== Appendix II
Table II.1
Enforcement Cases Closed, Fiscal Years
1990-97
Certific
ate Emergenc
actions Number y orders
as a of as a
Number Number percenta closed percenta
of of ge of cases ge of
enforcem certific enforcem initiate certific
ent ate ent d using ate
cases actions cases emergenc actions
Fiscal year closed closed closed y orders closed
-------------------- -------- -------- -------- -------- --------
1990 13,218 3,126 24 322 10
1991 15,341 2,598 17 482 19
1992 16,462 2,873 17 532 19
1993 23,535 3,136 13 487 16
1994 19,034 2,543 13 383 15
1995 17,987 2,185 12 503 23
1996 16,180 2,200 14 573 26
1997 15,749 2,209 14 460 21
======================================================================
Total 137,506 20,870 15 3,742 18
----------------------------------------------------------------------
Source: GAO's analysis of data from FAA's Enforcement Information
System.
Table II.2
Regional Use of Emergency Orders, Fiscal
Years 1990-97
Number of
Number of emergency
closed cases orders as a
initiated percentage
Number of using of
certificate emergency certificate
Region actions orders actions
---------------------------- ------------ ------------ ------------
Southwest 2,175 820 38
Eastern 2,000 596 30
Western-Pacific 2,477 703 28
New England 587 147 25
Alaskan 633 142 22
Great Lakes 1,656 326 20
Southern 3,986 560 14
Central 1,303 182 14
Northwest 1,501 221 15
Other\a 4,552 45 1
======================================================================
Total 20,870 3,742 18
----------------------------------------------------------------------
\a Includes enforcement actions opened by FAA's Aeronautical Center,
European region, and headquarters, as well as those enforcement
actions based on violations voluntarily self-disclosed to FAA by
aviation entities.
Source: GAO's analysis of data from FAA's Enforcement Information
System.
Table II.3
Recommended Type of Emergency Action
Compared With Final Action Taken, Fiscal
Years 1990-97
Emergency action initially recommended
----------------------------------------
Final action taken Revocation Suspension Total
---------------------------- ------------ ------------ ------------
Certificate revoked 1,656 35 1,691
Certificate suspended 322 887 1,209
No action 83 87 170
FAA action reversed 43 9 52
Other\
----------------------------------------------------------------------
Certificate expired 29 103 132
Successful reexamination 25 163 188
Civil penalty (fine) 21 6 27
Unable to locate certificate 11 11 22
holder
Consent order\a 6 0 6
Waiver of penalty under the
Aviation Safety Reporting
Program\b 2 0 2
U.S. attorney declines to 2 0 2
prosecute
Referred to U.S. attorney 1 0 1
Cease-and-desist order\c 1 0 1
Unspecified 109 131 240
Administrative 0 1 1
======================================================================
Total 2,311 1,433 3,742
----------------------------------------------------------------------
\a A consent order ordinarily includes an agreement that the violator
will take corrective and remedial action as a condition for the
suspension or forgiveness of a portion of the sanction or, in some
cases, a modification of the proposed sanction.
\b The Aviation Safety Reporting Program is a voluntary
self-disclosure program for pilots established in April 1975. In
exchange for self-disclosure of information on pilot errors, which
are reported in a database administered by the National Aeronautics
and Space Administration, FAA generally agrees not to take legal
action in response to reported unintentional violations.
\c A cease-and-desist order is an order of an administrative agency
or court prohibiting a person or business from continuing a
particular course of conduct.
Source: GAO's analysis of data from FAA's Enforcement Information
System.
Table II.4
FAA's Use of Emergency Revocations,
Fiscal Years 1990-97
Total emergency
Fiscal year Revocations orders\a
------------------------------ ------------------ ------------------
1990 184 322
1991 284 482
1992 327 532
1993 291 487
1994 281 383
1995 264 503
1996 382 573
1997 298 460
======================================================================
Total 2,311 3,742
----------------------------------------------------------------------
\a Includes emergency suspensions and emergency revocations.
Source: GAO's analysis of data from FAA's Enforcement Information
System.
Table II.5
Number of Days Between the Date FAA
Learned About the Violation and the Date
It Issued the Emergency Order, by
Percent of Cases, Fiscal Years 1990-97
Amount of time elapsed\a Percent of cases
---------------------------------------- ----------------------------
10 days or less 4
30 days or less 11
180 days or less 65
365 days or less 86
----------------------------------------------------------------------
\a The median time elapsed was 132 days. (The median is the number
representing the point dividing the upper half of the cases from the
lower half of the cases in terms of elapsed days.)
Source: GAO's analysis of data from FAA's Enforcement Information
System.
*** End of document. ***