Appendix 2 operator prepares to more fully list and explain the particular procedural changes that pertain to the maneuver in the “Procedural Change” column.
(6) Other Use of ODRs. The ODR process may be used for other applications such as flight attendant or dispatcher qualification tracking, but such use is not required as part of this AC’s provisions.
c. Selecting Base Aircraft. An operator chooses a base aircraft from one of the aircraft operated. Base aircraft are defined in Appendix 1. Additional information regarding base aircraft selection is in paragraph 7.
d. Identification of Differences and the Analysis of Effects of Those Differences.
Differences must be described between base aircraft and other related aircraft. This may be done from base to each other related aircraft. Differences may also be described from any related aircraft to each other related aircraft. As long as a complete and clear relationship can be drawn from the base aircraft to each other related aircraft and all MDR requirements are met from the base aircraft, to each other related aircraft, there is no need to describe each possible combination of aircraft. This permits a comprehensive identification of differences that exist in the fleet, determines the effects of those differences, and shows compliance methods. Differences are generally organized to follow an operations manual or flight manual to facilitate use and review, and should be categorized by design, systems, and maneuvers. Effects of differences are stated in terms of effects on flight characteristics and procedures. Procedures include normal, nonnormal, alternate, and recall procedures, as applicable. Since complete descriptions may be to lengthy for direct incorporation in ODR tables, appendices, or references to other operator’s documents may be used to describe differences or effects. Some differences or effects may be repeated in the analysis. For example, an FMS difference may be noted in both a navigation system section and maneuver section associated with preflight setup. The objective is to assure each difference that pertains to pilot training, checking, or currency is identified and addressed, so it is not necessary to limit difference descriptions to prevent overlap.
e. Identification of Compliance Methods. Once differences and difference effects are described, methods of comprehensively addressing each difference (compliance methods) are shown. With the difference descriptions, redundancy may occur. The same training or checking compliance item shown for one item may also be associated with and credited for other items.
The objective for description of compliance methods is to show that each difference is addressed in some appropriate way, to show that the method and level chosen is consistent with the FSB MDRs, and example ODRs at a level at least equal to that required by the MDRs.
f. When Proposed ODR Compliance Methods Do Not Meet MDRs. If proposed ODR compliance methods do not satisfy MDRs or other FSB report constraints, the following alternatives exist:
(1) Differences may be reduced or eliminated by modification of aircraft, systems, or procedures.
(2) Other training methods or devices that fully comply with MDRs and other FSB provisions may be acquired, leased, or otherwise applied.
Appendix 2
(3) Pilot assignments may be separated for a fleet so that mixed flying of related aircraft does not occur.
(4) MDR change proposals may be requested through FAA POIs to the FSB. If FSB authorized changes to the MDRs are made, the operator may then apply the revised criteria.
g. Maximum Number of Related Aircraft. Comparative differences between related aircraft may comply with FSB provisions. Other limitations may also constrain mixed fleet flying. To prevent cumulative effects of differences for multiple related aircraft from adversely affecting pilot performance, the FAA sets guidelines for the maximum number of related aircraft to be flown. At difference level A, the number of related aircraft is greater since differences are fewer and less significant, whereas at level D or level E the number of related aircraft that can be flown is fewer because the differences are greater. To accommodate an increase in the differences level, increasing limitations are placed on the number of related aircraft that may be flown at the higher levels. Paragraph 7k contains specific guidance to POIs for approval of multiple related aircraft.
h. Application, Review and Approval. Paragraph 7 describes the FAA review and approval process. The process is summarized here to facilitate ODR table preparation. An operator submits the proposed ODR tables and necessary supporting information to the POI to apply for differences program approval. The supporting information may include any appendices to the ODR tables necessary for evaluation of the proposal, a transition plan if needed, and a proposed schedule for implementation. POIs may also require review of such pertinent and additional information as copies of bulletins, manuals, or other training materials, before they approve proposed ODRs. If devices are proposed that are not approved by the POI, or evaluated by the NSET, a review and approval of those training devices may be necessary before ODR approval. Sufficient lead-time must be provided to the FAA for review. Lead-time depends on such factors as the complexity of program, proposed difference levels, number of related aircraft, other operator precedents already set, and FAA experience with the proposed aircraft, training devices, and methods. Many non-controversial level A changes can be reviewed and approved in a few days. Complex programs with many related aircraft can require months for review and approval. It is the operator’s responsibility to consult with the POI to ensure that sufficient leadtime is provided to review initial submissions or changes. At least 60 days notice is acceptable for most programs. After the operator submits the program proposal, POIs compare the proposed ODR with the FSB report provisions including the MDRs. POIs consult pertinent FAA policy directives (Handbook, notices, Safety Alerts for Operators (SAFO), etc.) for interpretations or guidance in accomplishing the review. In certain instances the POI should consult with the FSB before ODR approval. If ODRs are consistent with FAA policies and within the constraints of the MDRs and example ODRs, the POI may approve the operator’s ODR tables and its proposed differences program. When approved by the FAA, ODRs establish the basis for training, checking, and currency programs for a given fleet for that operator.
i. Transition Period for ODR Implementation. In certain instances, a transitional period, agreed upon by the POI with FSB concurrence, may be necessary to permit operators to continue operations under previously approved programs. This is necessary when ODRs are initially set or revised and they require lead-time for program preparation, device acquisition, or to revise Page 37
Appendix 2 previously approved programs. Paragraph 7m and the individual FSB reports for each typecertificated aircraft discuss FAA approval of transition provisions.
j. ODR Revision. ODR revisions are initiated when changes occur in an operator’s fleet relating to differences, difference effects, or compliance methods. ODR revisions are appropriate when such changes affect pilot knowledge, skills, or abilities relevant to flight safety. Examples of program changes or factors that may require ODR revision include:
(1) Addition or deletion of aircraft in a fleet;
(2) Modification of base aircraft or comparison aircraft in a fleet;
(3) Change of base aircraft;
(4) Discontinuation of use, addition of new or modification of training devices referenced by ODRs;
(5) Revision of training methods with a resulting change in compliance levels;
(6) Changes in effects of differences such as revised procedures, performance, or flight characteristics;
(7) FAA revision of MDRs or other FSB provisions;
(8) Adverse OE or training and checking experience that dictates inadequacy of ODRs, MDRs, or other FSB provisions;
(9) FAA surveillance results, enforcement actions, or failure of an operator to comply with provisions of their approved ODRs; and
(10) Other factors as determined by the POI.
NOTE: Revisions to ODRs are approved using the same procedures as for initial ODRs approval.
Appendix 2 FIGURE. 8 FSB PROCESS
FSB PROCESS ORDER 8900.1
OTHER REQUIREMENTS
MOR TABLE
APPROVAL OF TRAINING FSB → PROGRAM(S) CHECK AIRMEN FSE → REPORT * CHDO → POI OPS-SPECS ETC.
FAA REVIEW
APPROVED
ODR OPERATIONS
TABLE(S) ODR REVISIONS * KEY
MOR-MASTER DIFFERENCE REQUIREMENTS
ODR-OPERATOR DIFFERENCE REQUIREMENTS
POI-FAA PRINCIPAL OPERATIONS INSPECTOR
FSB-FAA FLIGHT STANDARDIZATION BOARD
OPSPECS-OPERATIONS SPECIFICATIONS Page 39
Appendix 2
7. FAA REVIEW AND APPROVAL OF OPERATOR PROGRAMS.
a. General.
(1) FAA Responsibilities. FAA has the responsibility for review, approval, and continuing surveillance of individual operator programs consistent with this AC and FSB recommendations. Within a CHDO or FSDO, POIs have the responsibility for program review and approval. In addition to review, approval, and continuing surveillance of operator programs, CHDO and other district offices manage pilot certification consistent with the criteria of this AC and FSB recommendations.
(2) Approval Basis. FAA approvals are based on FSB report findings and policy guidance included in FAA directives (e.g., 8900.1, notices, SAFOs, etc.). Except as provided for in transition plans, all preparations must be complete and provisions approved before conducting training, checking, or establishing currency under this AC and an FSB report.
b. Operator Application of ODRs.
(1) Operators Using Related Aircraft in Mixed fleet Flying. If FSB provisions are published, operators operating aircraft in mixed fleet flying should apply recommendations of this AC and the FSB report. AC criteria and FSB MDRs may be applied anytime pilots operate mixed fleets between training and checking events.
(2) Threshold Requiring ODR Preparation. Even though an operator has different configurations of aircraft used in mixed fleet flying, there is some threshold below which ODR tables and POI approval is not required. The threshold requiring AC and ODR application occurs when differences in related aircraft affect pilot knowledge, skills, and/or abilities pertinent to flight safety. If systems, controls, indications, procedures, or maneuvers are different and these differences have an effect that significantly relates to what the pilots needs to know or do for safe mixed fleet flight operation, then an operator should prepare ODR tables and must seek FAA approval. Conversely, ODR tables would not need to be prepared in situations that do not affect flight safety. In such instances ODR tables are not needed even though pilots routinely operate several related aircraft. A minimum threshold is set to preclude unnecessary administrative assessment of mixed fleet flying, which has no safety implications. If changes to the fleet do not affect pilot knowledge, skills, or abilities affecting flight safety, then such changes need not be considered in addressing FSB provisions or this AC provision.
(3) FAA Review of ODR Proposals. After preparation the carrier submits proposed ODR tables and supporting information to the CHDO and POI for review and approval. POIs evaluate the following:
(a) The operator has made an appropriate identification of a base aircraft.
(b) Operators have comprehensively identified differences in the particular fleet.
This includes appropriate ODR table comparisons between the base aircraft and each related aircraft.
Appendix 2
(c) The operator’s assessment of the affects of differences on flight characteristics and procedures for the base aircraft and each related aircraft are suitable and valid.
(d) The compliance methods listed are consistent with the requirements of the MDR tables, footnotes, other pertinent FSB report provisions, FAA Order 8900.1, and associated advisory materials.
(e) ODR provisions adequately address any “subtle differences” between related aircraft that have a possibility of inducing potentially serious pilot errors.
(f) Training materials, methods, devices, and simulators proposed are acceptable, approved by the NSET if necessary, or if FSB provisions are applied, the ODR tables meet FSB constraints.
(g) ASIs, APMs, and APDs are prepared to apply FSB report checking standards.
(h) Implementation plans are adequate and consistent with FSB recommendations and other FAA policy.
(i) Other factors determined necessary by the POI are considered and any requirements met.
(4) Example ODR tables and MDRs. The POI uses the example ODR tables and the MDRs provided in the FSB report as a basis for evaluating the suitability of a particular operator’s proposed ODR table. The MDR always remains the primary basis for comparison.
The AEG should be consulted in the absence of conclusive guidance in making such judgments.
Guidance for evaluation of specific system or maneuver items may be found by comparison of the proposal with the example ODR table shown in the FSB report and other approved ODR tables. The operator may use devices, techniques, or methods of an equal or higher difference level. Critical methods should be at least at the level specified by the FSB on the MDRs and shown in the example ODR table. Actual ODR tables proposed by the operator may show a variety of compliance methods to satisfy a particular item, ranging from level A through the level required by the MDRs. For example, if the MDR requirement is a minimum of level C, the operator may propose to use a combination of level A bulletins, level B slide tape presentations, and level C training devices to satisfy pertinent items. However, at least level C should be shown for critical items. The operator may choose to satisfy a level C MDR provision with level D or level E methods.
(5) ODR Review Example. The following is an example of the process for review of a specific item on a proposed ODR table. For each proposed ODR item both the FSB example ODR table and MDRs are consulted and compared with the operator’s proposal. If the MDRs specify that level C devices are needed for training, checking, and currency between the base aircraft and a related aircraft and the example ODR table shows applicable level C systems differences or maneuvers, then the POI should ensure that the proposed ODR table submitted also shows at least level C for those pertinent systems or maneuvers.
Appendix 2
c. Base and Other Aircraft Identification.
(1) Selecting the Base Aircraft. Base aircraft are defined in Appendix 1. In general, base aircraft are used as reference for comparison of differences that affect, or could affect, pilot knowledge, skills, or abilities pertinent to flight safety. A base aircraft should typically be the aircraft that the operator trains to first, the aircraft that the operator has the largest number of, the aircraft most pilots fly frequently, or the aircraft that represents a configuration that the operator eventually will have as a standard. Another aircraft may be selected as a base aircraft when the previous base aircraft is being phased out, converted to a new configuration, or other such factors. A base aircraft may be redesignated at the discretion of the operator with FAA concurrence. A base aircraft is identified by make, type-certificated aircraft, model, and series or other distinguishing classifications. Classification should distinguish pertinent differences in configuration, handling characteristics, performance, procedures, limitations, controls, instruments, indicators, systems, installed equipment, options, or modifications.
(2) Identifying Related Aircraft. A related aircraft is an aircraft or a group of aircraft with the same characteristics that have pertinent differences from a base aircraft. Pertinent differences are those that require different or additional pilot knowledge, skills, and/or abilities that affect flight safety. Differences considered pertinent are those relating to configuration, handling characteristics, performance, procedures, limitations, controls, instruments, indicators, systems, installed equipment, options, or modifications. Related aircraft can exist between different models, series or within a model/series. When designated in FSB reports, any aircraft included in a MDR table is considered a related aircraft. Like base aircraft, operators designate related aircraft by one of the following:
• Model/series.
• FAA registration “N number”.
• Operator tail number.
• Any other classification that can uniquely distinguish pertinent differences between each related aircraft group and a base aircraft.
(3) Accounting for Each Related Aircraft. The important factor in base and related aircraft identification and ODR table preparation is that regardless of the combination used, there should be direct and complete traceability of both differences and compliance methods. There must be a clear description showing the adequacy of compliance methods to assure proper training, checking, and currency to safely operate each aircraft assigned.
d. Approval of ODRs.
(1) Approval Method. Following review and determination that an operator’s program addresses the FSB recommendations, the POI approves that particular program by signing ODRs. ODR tables are approved for each applicable related aircraft. Signature of ODRs or revisions, together with other relevant documents such as training programs and OpSpecs, constitute approval by the POI of that operator’s differences training, checking, and currency Page 42
Appendix 2 program requirements. ODR tables are used for most programs. In instances where aircraf only a few minor differences at level A, appro t have val may take the form of a letter including necessary information in lieu of using tables.
This is arded to the pertinent FSB for permanent retention, comparison, and future FSB evaluation.
ults equivalent level of safety as proposed by the MDRs, the POI may not approve that program.
ce sting .
gulatory compliance and managing surveillance of training, checking, and currency programs.
DR s ay FSB reports, other operator ODR, and the manufacturer’s larger databases for operators.
s d to the justified, forward the proposal with recommendations for revision of MDRs to AEG/FSB.
POI
(2) POI Authority at level A and B. POIs have authority at A and B level to make determinations without AEG coordination if compliance methods are within the MDRs.
important to provide timely response to minor differences requests. The results of these determinations are forw
(3) POI Coordination Required at Level C and Above. At C, D, and E level the POIs may approve operator programs only if the programs are clearly within the requirements of the MDRs. If there is doubt whether or not an operator’s program meets the MDRs, the POI cons with the FSB well before the operator’s program approval date, to allow time for review and resolution of open issues. If the operator’s request is unclear or does not establish an
(4) Initial and Final Approval. Like other training programs, POIs may authorize “initial” approval for an assessment period to review program effectiveness. Final approval should be made after suitable experience is obtained (generally within 6 months) in accordan with criteria in FAA Order 8900.1. When operators propose to add aircraft, modify exi aircraft, change base aircraft, phase aircraft out, or take other actions, which make the applicability of ODRs unclear, then the ODR tables for that operator should be updated. For some operators a continuous series of ODR table modifications will occur as its fleet changes Nevertheless, the ODR tables must be current at all times. ODR tables are used as a primary means for establishing re
e. POI Uncertainty Regarding Program Compliance. The POI should resolve any questions before approval if it is not clear that the operator’s proposal complies with the M table or other FSB recommendations. When issues cannot be resolved to clearly establish compliance with MDRs, other FSB report recommendations, or an otherwise acceptable mean of compliance, the AEG/FSB should be consulted. Early in program development, POIs m need more consultation with FSB members. In mature programs, better examples will be available in
f. Proposals that do not Comply with FSB Provisions. If the operator proposes a program less restrictive than the requirements of the MDRs or other FSB recommendations, then option of paragraph 6h apply. If an operator wishes to pursue a proposal less restrictive than the FSB report or MDRs, details of the proposal and supporting documentation should be presente POI for forwarding to the AEG/FSB. The POI will evaluate the carrier’s proposal and, if
g. FSB Revision of MDRs or Other FSB Provisions. When requested by a POI, the FSB reviews an operator’s proposals and if necessary modifies MDRs and other FSB provisions. If master requirements have been amended and the proposal meets the revised requirement, the Page 43
Appendix 2 may approve the proposal. Other operators can also apply for similar approval or reductions based on the revised FSB report. Major changes in the MDR table may require review by the fu FSB. The FSB may consider minor changes or interpretations on an ad hoc basis between F meetings for that aircraft. For some requests changes can be made based on existing or the supplied information. Complex cases may require testing to be conducted by the applicant before the MDR table is changed. Should the MDRs be updated to accommodate a change request, the proposed ODR can be approved within the new MDRs. Proposals for revisions to levels C, D, or E must be forwarded to the FSB for resolutio ll SB
n through the formal FSB process. Allow at least 60 days for FAA evaluation of such proposals.
hts,
n FAA-approved plan. FAA Order 8900.1 describes policies for FAA approval of proving tests.
ew
accordance with recommendations of the FSB report and subsequent approval of the POI.
by the FSB for experience with related aircraft, may be permitted with the approval of the POI.
k. Limitations on the Total Number of Related Aircraft.
rcraft nces r overall combination of aircraft to be flown should be examined to ensure the following:
excessive level of complexity for pilots to adjust to or retain important differences information;
iations in differences information are not mistakenly applied and lead to unsafe conditions; and of differences information is not excessive, not applied to the wrong aircraft, or not forgotten.
h. Proving Tests. When a related aircraft with difference levels C or greater is introduced by an applicant, proving runs may be needed. Proving runs are usually needed for levels D and E. At level E, regulatory provisions for proving runs must be met. Training flights, test flig delivery flights, and demonstration flights may be credited toward levels C and D proving requirements if necessary operational experiences are demonstrated and the flights are in accordance with a
i. Line-Oriented Flight Training (LOFT), LOS, or SLF. When operators have LOFT/LOS/SLF programs and additional related aircraft are approved, the POI should revi those LOFT/LOS/SLF programs to assure applicability to each related aircraft. SLF in the aircraft, or in some instances simulator (as determined by the FSB), may be necessary in
j. OE. As described in this AC and FSB reports, OE is consistent with definitions and requirements of 14 CFR. OE credit, as provided
(1) Mixed Flying of Multiple Related Aircraft. When mixed fleet flying involves pilots operating more than a base aircraft and a single additional related aircraft, additional constraints limiting the total number of aircraft may apply. Operation of multiple related ai requires a review by the POI to ensure that pilots can retain and properly apply necessary differences information or skills for each related aircraft without confusion. When more than two related aircraft are flown, POIs should specifically ensure that subtle or compounded differe between the various related aircraft do not result in confusion of procedures, maneuvers, o limitations. ODRs proposed for the
(a) That multiple differences do not result in confusion of requirements or an
(b) That subtle var
(c) That the amount Page 44
Appendix 2
l. Compliance Checklist for CHDOs. FSB reports provide a regulatory compliance checklist. The checklist identifies those 14 CFR parts, ACs, or other FAA requirements that are in compliance. Pertinent 14 CFR items not shown on the checklist or items shown but not reviewed by the AEG/FSB for compliance should be reviewed by the CHDO before POI approval of OpSpecs permitting those aircraft to be used under 14 CFR. Items found not compliant by the AEG/FSB should be reconciled and compliance established before operation.
The compliance checklist is an aid to CHDOs used to show the status of those 14 CFR items evaluated by the AEG/FSB, but does not comprehensively address all possible 14 CFR items and ACs that an operator may need to demonstrate compliance. OpSpecs, exemptions, deviations, or other factors, which the AEG/FSB may not be aware of, may also apply and may modify compliance status or methods shown in the checklist.
m. Implementation of FSB Provisions. These provisions are addressed in each typecertificated aircraft FSB report. POIs approve implementation provisions at the same time ODR tables or revisions are approved. Operators that do not elect to apply this AC or implement FSB provisions specified by the FSB report require review by AFS-200.
n. Aircraft That Do Not Have an FSB Report. When an FSB report is not prepared for a given type-certificated aircraft, or when MDRs or other recommendations are not shown, programs are approved in accordance with the 14 CFR, Order 8900.1, and other pertinent inspector guidance material.
8. APPLICATION OF REQUIREMENTS TO AIRMEN CERTIFICATION.
a. General. In addition to master requirements, the FSB report contains specifications for administration of pilot type rating or proficiency checks by FAA inspectors or operator check airmen. FAA pilot certification inspectors, APMs, operator check airmen, APDs, and DPEs should be familiar with FSB provisions regarding the proper administration of any necessary checks or evaluations for type-certificated aircraft or their series covered by the FSB report.
b. Checking Specifications. FAA pilot certification inspectors and APMs should assure proper application and administration of checks recommended by FSB reports as constrained by the MDR and specific ODR tables. FSB reports describe difference levels which constrain the various maneuvers, procedures, or unique factors to be considered by inspectors or check airmen when administering checks or observing OE. For example, certain nonnormal procedures may be required and others may be waived (for example no flap landings). Other unique procedures or maneuvers particular to an type-certificated aircraft may be necessary. Any unique configurations or failure conditions that should be observed while administering checks are described.
c. Checks Regarding Complex Systems.
(1) Partial proficiency checking is required for differences associated with systems that are determined to be at or greater than level C.
(2) Complex systems checks include hands-on operation and ensure demonstrated procedural proficiency in each applicable mode or function. Specific items and flight phases to Page 45
Appendix 2 be checked are specified (e.g., initialization, takeoff, departure, cruise, arrival, approach, and pertinent nonnormals).
NOTE: The FSB may recommend additional training beyond that which is otherwise required by 14 CFR to qualify in each type certificated aircraft.
9. TRAINING DEVICE AND SIMULATOR APPROVAL.
a. Training Device and Simulator Characteristics.
(1) Minimum Device and Simulator Characteristics. AC 120-40 and AC 120-45 describe minimum acceptable characteristics and standards for flight training devices and simulators. The FSB directly applies these standards in difference level specifications. When applicable, the FSB specifies other device characteristics as the minimum acceptable for differences training, checking, or currency between certain related aircraft. The FSB reports identifies these characteristics.
(2) Coordination with the FAA National Simulator Program (NSP). When the FSB specifies device characteristics, the FSB coordinates with the NSET to ensure simulator criteria compatibility and approval process definition. If device or simulator characteristics have not been previously recognized by the FAA as meeting the provisions of this AC, FSB, or the simulator evaluation and approval process, they must be evaluated by the NSET in consultation with the FSB before use in an approved program.
b. Aircraft/Simulator/Device Compatibility.
(1) Devices and Simulators to Match Aircraft. When pilots fly related aircraft in a mixed fleet, the combination of simulators and training devices used must satisfy MDR and ODR provisions specific to the aircraft flown by that operator. The POI, FSB, and the NSP must address the acceptability of differences between training devices, simulators, and aircraft operated as appropriate. The FSB, POI, and when necessary, the Air Transportation Division, AFS-200, or the General Aviation and Commercial Division, AFS-800, as applicable, identify acceptable credit for simulators and training devices.
(2) Differences Between Devices, Simulators, and Aircraft. When differences exist between related aircraft and the proposed training devices, or simulators to be used, then MDRs and ODRs may be used as guidance for acceptance and approval as is done between aircraft. The FSB, the NSP, and AFS-200 or AFS-800, as applicable, should be consulted when uncertainty exists regarding the use of MDRs and ODRs for acceptance or approval of these devices. The FSB will not recommend use or approval of devices that differ significantly from the actual operated aircraft.
c. Simulator and Device Approvals.
(1) NSP Representation to the FSB. An NSP member may serve as an advisor to the FSB or a member of the FSB, to address designation of and approval processes for devices and simulators at C, D, and E difference levels.
Appendix 2
(2) Coordination of NSP Criteria with the FSB. National simulator team development of criteria for training devices and approval test guides for new aircraft are coordinated with the FSB. This ensures compatibility of FSB/NSP requirements and effective use of resources for development of approval test guides and determination of FSB provisions.
10. REVIEW AND APPROVAL. FSB reports are approved as designated by AFS-1. In the event that revision of an FSB report is necessary, the FSB is provided with necessary policy guidance to implement applicable changes.
11. APPEAL OF FAA DECISIONS. When there is disagreement with provisions of an FSB report, that disagreement may be expressed to the FSB chairman for the pertinent typecertificated aircraft. If an issue cannot be resolved, the issue may then be addressed to AFS-200.
Additional information, data, or analysis may be provided to support differing views regarding the FSB provisions in question.