Skip Ribbon Commands
Skip to main content
Safety Recommendation Details

Safety Recommendation A-03-063
Details
Synopsis: Since January 2000, the National Transportation Safety Board has investigated numerous accidents involving turbine-powered aircraft not required to operate with either a cockpit voice recorder (CVR) or a flight data recorder (FDR). These accidents involved aircraft operating under 14 Code of Federal Regulations (CFR) Parts 91 and 135. Included among these accidents was the October 25, 2002, accident involving a Raytheon (Beech) King Air that crashed on approach to Eveleth-Virginia Municipal Airport, Eveleth, Minnesota, killing all eight persons on board, including Senator Paul Wellstone. The airplane was not equipped with either a CVR or an FDR at the time of the accident, nor did Federal regulations require it to be so equipped.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Amend the current regulations for 14 Code of Federal Regulations Parts 91, 135, and 121 operations to require all turbine-powered, nonexperimental, nonrestrictedcategory aircraft that have the capability of seating six or more passengers to be equipped with an approved 2-hour cockpit voice recorder that is operated continuously from the start of the use of the checklist (before starting engines for the purpose of flight), to completion of the final checklist at the termination of the flight.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable Action
Mode: Aviation
Location: Eveleth, MN, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA03MA008
Accident Reports: Loss of Control and Impact With Terrain Aviation Charter, Inc., Raytheon (Beechcraft) King Air A100, N41BE
Report #: AAR-03-03
Accident Date: 10/25/2002
Issue Date: 12/22/2003
Date Closed: 10/27/2009
Addressee(s) and Addressee Status: FAA (Closed - Unacceptable Action)
Keyword(s): Part 135,

Safety Recommendation History
From: NTSB
To: FAA
Date: 12/8/2015
Response: CC# 201501092: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration’s (FAA) draft Advisory Circular (AC) 20-CVR, “Airworthiness and Operational Approval of Cockpit Voice Recorder Systems,” which was posted for comment on the FAA’s website on November 10, 2015. The draft AC provides guidance to airframe manufacturers, cockpit voice recorder (CVR) systems manufacturers, aircraft operators, and Supplemental Type Certificate applicants to comply with regulations for the airworthiness and operational approval of CVR systems. Appendix A to the draft AC contains flowcharts that operators may use to determine the applicability of various regulations, similar to what is done in AC 20-141B, “Airworthiness and Operational Approval of Digital Flight Data Recorder Systems.” The NTSB has found some technical errors and confusion in the presentation of the flowcharts that should be remedied. NTSB findings include the following: • The notes at the bottom of appendix pages A-2 and A-4 through A-7 referencing “activation of erasure feature” (14 CFR 91.609(f), 121.359(f), 125.227(d), and 135.151(e), respectively) correctly reference existing regulations; however, these regulations are an artifact of older recording technology and are an over specification of other requirements (that is, 30-minute or 2-hour recordings). In the interest of clarity, the NTSB suggests deleting these notes. • On December 22, 2003, the NTSB issued the following safety recommendation to the FAA: Amend the current regulations for 14 Code of Federal Regulations Parts 91, 135, and 121 operations to require all turbine-powered, nonexperimental, nonrestricted category aircraft that have the capability of seating six or more passengers to be equipped with an approved 2-hour cockpit voice recorder that is operated continuously from the start of the use of the checklist (before starting engines for the purpose of flight), to completion of the final checklist at the termination of the flight. (A-03-63) On October 27, 2009, the NTSB classified Safety Recommendation A-03-63 “Closed?Unacceptable Action” in part because the FAA did not clarify that conversion to cargo operation does not remove the requirement to equip, maintain, and use a CVR. The flowcharts do not clarify or dispel this widely held belief; instead, they appear to support the misinterpretation. The flowcharts should be modified to indicate that passenger carrying aircraft originally required to have a CVR continue to have this requirement even if passenger seats are removed. • Figure 1 does not provide a reference to 14 CFR 91.1045 (and/or Part 91K). • Figure 2 does not clearly direct the user to 14 CFR Part 91K as the decision block; the direct reference to “91.1045” and “91.609” in the chart lacks parallel form with all other flowcharts in the appendix. • Figure 2 states “IC of A after 4/5/2012”; this date should be “4/6/2012.” This problem also exists in the bottom of figure 3 with the 12/5/2010 date. • Figure 3, top, uses a square block as a decision block; however, this should be a diamond block to represent a decision. Also at this block, the logic is incorrect; if the answer to “large turbine powered or pressurized with 4 reciprocating engines” is “No,” a CVR is not required; however, a CVR may be required for 10-19 seats (14 CFR 121.359(d)) or 20 30 seats (14 CFR 121.359(e))). • In figures 3 through 6, there are decision blocks containing options of “Yes,” “No,” as well as “and,” and “and/or.” The NTSB finds the use of non-standard flowchart logic (for example, “and” and “and/or”) confusing. • The square block at the top of figure 5 does not contain any text. • Figure 6, the IC of A after 10/11/1991 should also include the phrase “or a CVR installed after 10/11/1991.”

From: NTSB
To: FAA
Date: 10/27/2009
Response: The opening of the December 22, 2003, letter that transmitted this recommendation to the FAA stated that the NTSB has investigated numerous accidents involving turbine-powered aircraft not required to operate with either a CVR or an FDR. Significantly, these accidents involved aircraft operating under 14 CFR Parts 91 and 135. In its November 20, 2008, letter, the FAA stated that it had decided not to mandate the recommended requirement for existing aircraft operating under Part 91 or 135 in the March 7, 2008, final rule. The FAA stated further that it was not able to quantify or justify the potential burden of the CVR retrofit requirements. The NTSB’s December 22, 2003, letter explained that this recommendation had been prompted in part by the need for turbine-powered, nonexperimental, nonrestricted-category aircraft with the capability of seating six or more passengers but certificated for single pilot operation to be required to carry, maintain, and use a CVR. This recommendation was also prompted by the widely held but incorrect belief that a CVR is no longer required if an operator converts a passenger-carrying aircraft to one carrying cargo. The same letter stated that the recommended action was intended for turbine powered aircraft including the Beech King Air, Cessna Citation, Cessna Caravan, and Piper Cheyenne airplanes, as well as Bell 407 and Bell 206L helicopters. These single-pilot-certificated aircraft are heavily used in Part 135 passenger charter and other commercial operations. Under Parts 91 and 135 operations, a CVR is required only if the aircraft are certificated for operation by two pilots. Although CVR data from single-pilot operations may not provide the same level of operational information as would be expected when two or more crewmembers are present, the recorder can capture events that are important to accident investigators. Significantly, despite their single-pilot certification, aircraft in this category are often operated with two pilots to meet insurance requirements or for other reasons, such as safety-of-flight, making the presence of a CVR even more valuable to NTSB investigations. Aircraft covered by this recommendation were involved in more than 100 accidents investigated by the NTSB in the period January 2000 through December 2003. Most of these aircraft were not equipped with CVRs, and in only one case was the CVR operating at the time of the accident. In particular, the Beech King Air was involved in 45 of these investigations. Of those accidents, three of the aircraft were equipped with CVRs, although they were not required by federal regulation to be so equipped, but only one of the CVRs was operational and provided data that aided in the investigation. NTSB statistics also show that the Piper Cheyenne and the Cessna Citation were involved in 18 accidents during the same period, but CVRs had not been installed on any of the Piper Cheyennes. Although one Cessna Citation was equipped with a CVR, the recorder did not contain any useful audio information. The NTSB investigated a significant number of rotorcraft accidents during this period. The Bell 407- and Bell 206L-series helicopters are certificated to operate with one pilot and to carry at least six passengers. From January 2000 to December 2003, these helicopters were involved in more than 50 accidents investigated by the NTSB; none of these helicopters was equipped with a CVR. Finally, from September 1985 through December 2003, Cessna Caravans were involved in over 100 accidents. Without fully operational data recorders, the NTSB is disadvantaged in its ability to thoroughly investigate the large number of accidents involving these aircraft. On May 8, 2006, the NTSB sent a letter to the FAA referencing this recommendation and its relationship to the October 24, 2004, crash into mountainous terrain in Stuart, Virginia, of a Beech King Air 200, operated by Hendrick Motorsports. The flight was operating under Part 91, and both pilots were qualified and experienced, with the captain’s having accumulated 10,733 hours of total flying time. The airplane was not equipped with a CVR, an FDR, or a video image recorder. The probable cause of this accident, as stated in the NTSB’s report, was “the flight crew’s failure to properly execute the published instrument approach procedure, including the published missed approach procedure, which resulted in controlled flight into terrain. However, the lack of recorders prevented the NTSB from more fully developing the scenario that led to the crew’s failure to properly execute the approach. Issues that were discussed in the accident report, but not fully developed due to lack of recorder data, include crew resource management, possible misuse of the global positioning system rather than use of the instruments available for a nonprecision approach, and possible reasons why an experienced crew had not properly flown the missed approach. In the May 8, 2006, letter the NTSB stated that the absence of any recorders on this airplane reemphasized the need for Safety Recommendation A-03-63. In the same letter, the NTSB stated that between December 22, 2003 (when this recommendation was issued), and February 6, 2006 (the day before the NTSB’s meeting concerning the Hendrick Motorsports accident), we investigated 22 accidents involving Beech King Air aircraft in which no recorder of any type was available. Of these 22 accidents, 9 were fatal; a total of 43 people died. These numbers involved only the model of aircraft involved in the Hendrick Motorsports accident and not all accidents involving the turbine powered, nonexperimental, nonrestricted-category aircraft that this recommendation addresses. The NTSB’s recommendation letter also documented that aircraft converted from passenger service to cargo operation constitute another category of aircraft that has been a problem. Although these aircraft had 10 or more seats when in passenger service and were required to have a CVR when certificated, the owner mistakenly believed that when the passenger seats were removed for conversion to cargo service, the requirement to carry and/or maintain and use a CVR no longer applied. On October 14, 2008, the NTSB classified a number of other recommendations based on the FAA’s March 7, 2008, final rule on recorders. Among the recommendations closed in that letter was Safety Recommendation A-99-16, which asked for a 2-hour CVR for new and existing aircraft. At that time, the NTSB indicated that the recommended action would have led to the elimination of recorders that rely on magnetic tape instead of a solid-state recording medium. The NTSB continues to investigate accidents involving aircraft that use this outdated recording mechanism. Tape-based recordings are very unreliable; investigators consistently find it difficult or impossible to extract from them the data needed for accident investigations. The FAA’s decision to exclude from the requirements the retrofits recommended for aircraft operated under Part 135 or Part 91 will leave this problem unaddressed. In its current letter, the FAA states that the March 7, 2008, final rule requires new CVRs to have a 2-hour recording capacity but does not require a retrofit for Parts 91 or 135 aircraft. The FAA also stated that for Part 91 aircraft required to carry a CVR, the requirement has been effective since October 11, 1991, and the March 7, 2008, final rule mandated this same requirement for Part 135 newly manufactured aircraft that are required to carry a CVR. However, the FAA does not appear to have addressed (as intended in Safety Recommendation A-03-63) the need for CVRs to be required for aircraft certificated for single pilot operation, nor is there any clarification that conversion to cargo operation does not remove the requirement to equip, maintain, and use the CVR. The failures of the final rule to address the NTSB’s concerns and the FAA’s decision not to clarify that cargo operations are also required to carry and use operational CVRs do not satisfy Safety Recommendation A-03-63. Consequently, the recommendation is classified CLOSED—UNACCEPTABLE ACTION.

From: FAA
To: NTSB
Date: 11/20/2008
Response: Letter Mail Controlled 12/9/2008 3:08:58 PM MC# 2080716: Robert A. Sturgell, Acting Administrator, FAA, 11/20/08 After reviewing and analyzing the comments to the February 2005 notice of proposed rulemaking (NPRM), the FAA published a final rule, Revisions to Cockpit Voice Recorder and Digital Flight Data Recorder Regulations (73 FR 12542), on March 7, 2008. The final rule includes a retrofit requirement for existing turbine-engine powered airplanes operated under parts 121 and 125. By April 7, 2012, these airplanes are required to have an approved CVR that can record at least the last two hours of information and operate continuously from the use of the checklist before the flight to completion of the final checklist at the end of the flight. These same requirements apply to newly manufactured airplanes operated under parts 121 and 125 after April 6, 2010. For part 91 aircraft required to carry a CVR, the requirement for the CVR to be operated continuously from the use of the checklist before the flight to completion of the final checklist at the end of the flight has been effective since October 11, 1991. The final rule has mandated this same requirement for part 135 newly manufactured aircraft that are required to carry a CVR after April 6, 2010. The final rule also has a requirement for the CVR to record at least the last two hours of information for aircraft that are required to have a CVR and operated under parts 91 and 135. This requirement will affect newly manufactured aircraft after April 6, 2010. We have decided not to mandate the CVR retrofit requirements of recording at least the last two hours of information and operating continuously from the use of the checklist before the flight to completion of the final checklist at the end of the flight for aircraft required to carry a CVR operating under parts 91 and 135. In responding to comments received to the NPRM, we were not able to quantify or justify the potential burden of the CVR retrofit requirements on these operators and the requirement for retrofit was removed from the final version of the rule.

From: NTSB
To: FAA
Date: 5/8/2006
Response: Between December 22, 2003, when these recommendations were issued, and February 6, 2006, the day before the Safety Board's meeting concerning the Hendrick Motorsports accident, the Board investigated 22 accidents involving Beech King Air aircraft in which no recorder of any type was available to investigators. Of these 22 accidents, 9 were fatal; a total of 43 people died. The Board emphasizes that these numbers only involve the model of aircraft involved in the Hendrick Motorsports accident, and do not include all accidents involving the turbine powered, nonexperimental, nonrestricted-category aircraft that these recommendations address. The Board also emphasizes that Safety Recommendation A-03-63 does not ask for the installation of video image recorders; rather, it recommends that already-available CVR technology be required in this type of aircraft. The FAA should be able to move quickly to implement this recommendation without waiting for development of image recording technology and products. To date, Safety Recommendations A-03-62 thru -65 are classified OPEN—UNACCEPTABLE RESPONSE; the FAA has taken no specific action in response to Safety Recommendation A-03-63. The Safety Board asks the FAA to re-evaluate the importance of these recommendations and to initiate action as soon as possible.

From: NTSB
To: FAA
Date: 4/26/2006
Response: The Safety Board notes that this recommendation does not concern video image recorders; rather, it recommends a requirement for installation and use of 2-hour CVRs. The FAA's October 11, 2005, letter does not discuss any action that the FAA is taking in response to this recommendation. Pending the FAA's taking recommended action, Safety Recommendation A-03-63 remains classified "Open-Unacceptable Response." The FAA indicated that it believes that the intent of these recommendations is primarily to collect parametric data from images of the cockpit instrumentation. The FAA also indicated that current CVR and FDR regulations are performance-based rules and, as a result, must specify what parameters or actions must be recorded and the minimum accuracy of the recorded information. Because of these beliefs and concerns, the FAA initiated a project to identify what should be recorded and whether an image recorder is sufficient for recording parameter data. What should be recorded? The FAA notes that while the European Organization for Civil Aviation Equipment's (EUROCAE's) Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems (ED-112) has detailed resolution and accuracy requirements, the FAA believes that there has never been an image recorder system manufactured or installed for the purpose of obtaining parametric data from cockpit instrumentation. To address these issues, the FAA is developing a "proof-of-concept" test that will install an image recorder system in a simulator and on an FAA airplane. The simulator and the aircraft will be flown, and images of the flight deck instrumentation will be recorded at the resolution and rates defined by ED-112. These images will be analyzed to derive parametric data, which will be compared to actual data recorded on the airplane to determine the accuracy of the derived data. Other factors affecting image recording will also be reviewed, including lighting condition changes, instrument glare, and blockage resulting from normal crew actions. Safety Board personnel are working with FAA staff on these evaluations. The FAA indicated that the tests had been concluded in June 2005, that the evaluations are currently in progress, and that they should be completed soon. Although one of the primary benefits of an image recording system is the potential to obtain parametric data from images of the cockpit instrumentation, the Board does not agree with the FAA that the intent of these recommendations is primarily to collect parametric data. In the letter that transmitted these recommendations to the FAA, the Board stated the following: Such [video image] recorders obtain not only audio information like that from CVRs and event data like that from FDRs, but also information about the environment outside the cockpit window. The parametric data study the FAA is conducting concerns issues related to "event data like that from FDRs," but even if a video recorder cannot capture this data, it will still provide valuable audio information and can provide information on pilot actions and on the environment outside the aircraft. This is particularly relevant in aircraft where no other information is recorded or available. While recognizing the value of the FAA's study, the Board does not believe it is a valid basis for delaying the recommended actions. Even if the study determines that parametric data cannot be obtained, there will be great value to the Board's investigations in obtaining audio information and information on pilot actions and on the outside environment. In order for the FAA's actions in response to these recommendations to be acceptable, the FAA must prepare and issue the recommended regulations. Pending the FAA's taking the recommended actions, Safety OPEN—UNACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 10/11/2005
Response: Letter Mail Controlled 10/24/2005 2:37:14 PM MC# 2050494 Marion C. Blakey, Administrator, FAA, 10/11/05 The FAA has been actively working to address these safety recommendations, and is collecting data to establish an FAA position on aircraft image recorders. In order to develop an FAA position on this issue, some questions must be addressed: What would we record? By design, the current CVR and FDR regulations are performance-based rules. As such, the regulations specify what parameters or actions must be recorded and how accurate the information must be. The Board recommendations do not specify what data the image recorder should capture. The FAA believes that the intent of these recommendations is primarily to collect parametric data from the images of the cockpit instrumentation. Would an image recorder be sufficient for recording parametric data? While EUROCAE's Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems (ED-112) has detailed resolution and accuracy requirements, to the best of our knowledge there has never been an image recorder system manufactured or installed for this specific purpose. Since this has never been done, the vendor claims for producing a low-cost camera and recorder system that can be installed on the subject aircraft that will meet the resolution necessary to derive parametric data from recorded images are unsubstantiated. To address these issues, the FAA is working with the Board to develop a "proof-of-concept'' test that will install an image recorder system in a simulator and on an FAA Beechcraft King Air airplane. The simulator and the aircraft will be flown and images of the flight deck instrumentation will be recorded at the resolution and rates defined by ED-112. These images will then be analyzed and Board and FAA accident investigators will derive parametric data from these flights. The derived data will be compared to actual data recorded on the airplane to determine the accuracy of the derived data. Other factors affecting image recording will also be reviewed. These include things such as lighting condition changes, instrument glare, and blockage due to normal crew actions. Tests were concluded during the month of June 2005 at the FAA's Technical Center. The final report, including the findings from this testing, should be completed by December 2005. I hope that this helps explain ongoing FAA activities and illustrates the amount of time and work that is required to evaluate fully and properly respond to these safety recommendations.

From: NTSB
To: FAA
Date: 12/15/2004
Response: The FAA's March 29, 2004, letter indicates that safety recommendations concerned with recorders of all kinds are uniquely difficult for the FAA to respond to in a manner that the Safety Board finds acceptable. On June 3, 2004, staff from the FAA and the Board met to discuss the FAA's responses to recommendations in this area. The discussion focused on general difficulties in applying conventional cost-benefit analyses to regulations regarding recorders. The discussion also focused on the differential feasibility of recommendations that affect both newly manufactured aircraft and aircraft in the existing fleet, and it was observed that although the Board has addressed its recorder recommendations separately to these two populations of aircraft, the FAA has seldom made a distinction between them in its responses. Although the June 3 meeting was constructive, the substance of Safety Recommendations A-03-62 through A-03-65 and A-99-59 was not discussed. A discussion of the implementation issues related to these and other image-recorder recommendations was accomplished during the Safety Board's Public Hearing on Aviation Image Recording on July 27 and 28, 2004. Witnesses from recorder and camera system manufacturers testified that image-recording systems compliant with EUROCAE's Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems (ED-112, issued in March 2003) could be commercially available within a year of the FAA's issuance of a TSO based on ED-112. One witness estimated that a single-camera image recorder for smaller aircraft would cost between $3,000 and $5,000. Two other recorder manufacturers estimated that the equipment cost for a single camera installation in large aircraft would be about $10,000. These witnesses also noted that installation costs would vary widely but that they would be substantially less for installations in newly manufactured aircraft than as retrofits to existing aircraft. Witnesses who had participated in the EUROCAE Working Group that developed ED-112, as well as the manager of the FAA's Aircraft Engineering Division, testified that ED-112 provided a solid basis for the development of a TSO on an expedited schedule. The Safety Board notes that concerns have been expressed about privacy issues that could arise if cockpit image recorders were installed. At the recent hearing on image recorders, attention was focused on the effectiveness of privacy protections currently established for CVRs and their extension to cockpit image recorders. Testimony indicated that, since the 1990 Congressional passage of legislation protecting CVRs, no CVR recordings have been disclosed to the public in the United States. In that same period, witnesses could cite only one international instance of the public disclosure of a CVR recording. Counsel representing both plaintiff and defendant positions in civil litigation stemming from aircraft accidents testified that the statutory protections and judicial procedures regarding the use of CVR recordings in evidence were effective both in supporting litigation and in preventing public release of the recordings. Testimony revealed the need for other countries that lack similar protections to enact national legislation and rulemaking to extend those protections worldwide. Finally, hearing participants discussed the possibility of encrypting data that are recorded by the cockpit image recorders. Several witnesses testified that encryption is technically feasible, but the issues surrounding encryption, including who would have control over encryption keys and how that information would be shared in the international arena, were not resolved. At the hearing, FAA witnesses testified that even though virtually all of the specifications are already established in ED-112, a TSO addressing image recorders would not be released for public comment before the end of 2005. The FAA also stated that previous recorder system TSO efforts have taken 3 to 3 1/2 years to complete even with established EUROCAE documents in place. The FAA further testified that no action has been taken to initiate rulemaking in response to the Safety Board's image-recorder recommendations or to establish a priority for such rulemaking. The Safety Board continues to believe in the need for these recommendations and urges the FAA to take the recommended actions as quickly as practical. Because the FAA has not initiated action to issue an image-recorder TSO based on the EUROCAE's Minimum Operational Performance Standard for Crash Protected Recorder Systems (ED-112), Safety Recommendation A-99-59 was classified "Open--Unacceptable Response" at a November 9, 2004, meeting of the Safety Board that reviewed the List of Most Wanted Safety Improvements, which includes Safety Recommendation A-99-59. At that same meeting, Safety Recommendation A-03-64, which is also on the Most Wanted List, was classified "Open--Unacceptable Response" because the FAA has not yet taken any action in response to the recommendation. In neither its letter of March 29, 2004; the June 3, 2004, meeting between Safety Board and FAA staff; nor its testimony at the July 27 to 28, 2004, Safety Board Public Hearing on Aviation Image Recording has the FAA indicated that any action is being taken in response to Safety Recommendations A-03-62, -63, or -65. Accordingly, Safety Recommendations A-03-62, -63, and -65 are classified OPEN—UNACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/7/2004
Response: Letter Mail Controlled 4/7/2004 11:54:09 AM MC# 2040154

From: FAA
To: NTSB
Date: 3/29/2004
Response: Letter Mail Controlled 8/18/2004 3:13:14 PM MC# 2040154 Despite numerous improvements in recorders of all kinds that have been mandated over the years, safety recommendations in this area continue to be uniquely difficult for the FAA to respond to in a manner that the Board finds acceptable. At present there are 25 open recommendations relating to CVRs, FDRs, or video recorders. Seven of these recommendations are on the Most Wanted list and currently classified as "open unacceptable." While the FAA works to address every safety issue identified by the Board, and our overall record of success is excellent, our results in the recorder area have been mixed. Recorder recommendations present unique challenges, including difficulties in cost/benefit analysis, technical hurdles, retrofit problems, issues about the use of data, and privacy concerns. All of these challenges are presented in these latest recommendations. This situation calls for a fresh approach. Our staffs have agreed that we should convene a meeting of top FAA and Board officials over the next few weeks to try and achieve a consensus on how to approach these issues across-the-board. This will not be a SWAT meeting where specific recommendations are targeted, but rather a meeting to work toward some conceptual agreements on how we can best meet the need for recording devices for effective accident investigation. Preparations for this meeting are underway. I give this effort my full support, and am confident you will do the same.