LEGISLATIVE AND REGULATORY UPDATE August 12, 2015

LEGISLATIVE AND REGULATORY UPDATEAugust 12, 2015Highway Bill Related Legislation Involving SMS MethodologyBefore the Senate skipped town for a month, a Bill was introduced as a compromise in an effort by the Senate to pass a highway funding bill (S....

By |August 13th, 2015|ASECTT, Legislative Update, SMS Methodology|Comments Off on LEGISLATIVE AND REGULATORY UPDATE August 12, 2015

ASECTT v. FMCSA – Win, Lose or Draw?

ASECTT v. FMCSA – A Win, Lose or Draw?
Henry E. Seaton

On June 17, 2014 The D.C. Court of Appeals issued its decision in ASECTT v. FMCSA.  At issue was whether the FMCSA's guidance issued in May of 2012 amounted to a new rule directing shippers and brokers to use SMS methodology in credentialing carriers.  Petitioners' arguments were supported by Declarations showing that SMS methodology does not accurately measure carrier safety performance and that the guidance amounted to a new rule requiring shippers and brokers to use SMS methodology to bar from use thousands of carriers which the Agency itself has found are fit to operate on the nation's roadways.


The Court ignored the effect the Agency's website publication and on procedural grounds denied Petitioners' relief finding that the Agency's guidance did not amount to a new rule for which relief could be granted. The press largely covered the Court's decision as a loss.  To be sure, the Court which was not "astonished" by the Agency's action and missed an excellent opportunity to rein in a clear bureaucratic overreach of the type that has come to characterize the current Administration and its Agency.

Yet, was the decision a resounding defeat for Petitioners as some pundits have concluded? 

A close reading of the decision shows that the Agency's defense was based upon the argument, which the Court accepted, that the Agency did not intend its guidance as a new rule and the Agency argued that its website advice and publication of SMS methodology does not change the Agency's duty to determine carrier safety fitness, nor does it trump the settlement in NASTC et al. v. FMCSA to which the Agency agreed when suit was filed after the Agency announced SMS scores would be made public.

Thus, in finding that the Petitioners lacked the basis to sue because the "Guidance" did not constitute a new rule, the Court may have allayed Petitioners' and the industry's worst fears.  That is, the Agency through website guidance and a highly orchestrated publicity campaign, could abdicate its responsibility for determining carrier fitness, transferring that duty to shippers and brokers under peril of negligent selection liability.

Clearly, ASECTT v. FMCSA was not a resounding victory, but I believe it was not a defeat. 

It drew clearly the battle lines between rulemaking and agency advocacy, forcing the Agency into a "rope-a-dope" posture of defending its website publications as having no legal effect in trumping existing regulations or rules.

In the meantime, after it was sued, the Agency has buried the complained of "guidance document" and in shuffling its website, largely refrained from further pronouncements which could provide fodder for an activist plaintiff bar intent on using SMS methodology to sue upstream shippers and brokers for negligent selection in every fatality accident.

Hopefully ASECTT v. FMCSA will be seen in the light of history as just a draw – a necessary battle in a longer war.

In the two years it took to litigate this case, the Agency's industry support for SMS methodology has deteriorated.  In December 2013 the ATA publicly reversed its policy and issued a statement condemning the accuracy of SMS methodology.  It has seen the light and urges that scores be removed from public view.  OOIDA has issued a call for the Administrator to step down because the website is being used for lobbying, not carrying out the Agency's existing regulatory duties.  The TIA, whose members are the object of "broker busting" classes by plaintiff's bar have called for legislation to remove SMS methodology as an issue in tort suits.

Finally, the Inspector General and GAO studies of SMS methodology which were commissioned by House Committees at the request of ASECTT and others have been completed.  These independent studies confirm the mounting criticism of all who have studied SMS methodology.  It is systemically flawed and lacks sufficient data to statistically measure small carriers which make up the vast majority of carriers the FMCSA regulates.

It now seems doubtful that the Agency can deliver a safety fitness determination rulemaking involving SMS methodology any time soon.  As a result of building pressure, the battlefront should move from the Agency and the Court to congressional oversight and regulation reining in the FMCSA.  Congress needs to confirm, once and for all, that the Commerce Clause applies.  The Agency's ultimate safety fitness determination is the sole standard for determining whether a carrier is fit to use.  The Agency's finding preempts and trumps the effort by plaintiff's bar to hold the shipping public liable for the negligent acts or omissions of authorized interstate carriers.

It is time for the industry as a whole to put aside parochial interests and send clear and unified messages to Congress that broad legislation is needed.  Until then, ASECTT v. FMCSA must be seen as an important battle in a longer war, the results of which will have broad implications on competition, carrier choice, federalism and preemption.

I can only hope that the cavalry is on the hill.

By |July 3rd, 2014|ASECTT, ASECTT v. FMCSA, decision, SMS Methodology|Comments Off on ASECTT v. FMCSA – Win, Lose or Draw?

ASECTT Newsletter 5/15/2014

The Agency has proposed a new highway bill. Two controversial proposals to be taken up by the Senate include:requiring hourly driver compensation for on duty not driving time andseeking direct regulatory authority over shippers and brokers found gu...

By |May 15th, 2014|ASECTT, FMCSA, highway bill, SBA hearing, SMS Methodology, usdot|Comments Off on ASECTT Newsletter 5/15/2014

ASECTT Update

Dear ASECTT Member:ASECTT has joined ATA and others in calling for Administrator Ferro to voluntarily remove publication of SMS Methodology from the web. See Tom Sanderson's letter.The Inspector General report on SMS Methodology was issued on Marc...

By |March 11th, 2014|ASECTT, ATA, Ferro, GAO, IG, SMS Methodology, study|Comments Off on ASECTT Update

ASECTT Newsletter March 15, 2013


ASECTT Newsletter
March 15, 2013
1.         ASECTT et al. v. FMCSA
All briefs have been filed and we are awaiting scheduling of oral argument.  To view copies of these pleadings, see http://www.asectt.blogspot.com/p/asectt-et-al-v-fmcsa.html.

2.         Motor Carrier Safety Advisory Committee and Parker Committee Update.  

The FMCSA has made additional appointments to its handpicked Motor Carrier Safety Advisory Committee and the Parker subcommittee considering SMS methodology. The new appointees consist primarily of safety advocate groups, a union representative and law enforcement.  While Schneider and the TIA were added, affected small business nominees were ignored.  A report from the Parker Committee critical of SMS methodology, particularly the inclusion of non-preventable accidents in the crash BASIC is predicted in the coming months.  The agency has again signaled that it is not prepared to submit SMS methodology for rulemaking and the earliest possible date for submission is now January of 2014.

3.         Ferro Speaks to House Subcommittee.

The following link contains the agency’s summary of Administrator Ferro’s testimony to the Subcommittee on Highways and Transit Committee on Transportation and Infrastructure concerning various aspects of MAP-21, including implementation of SMS methodology.  Emphasizing that “Safety is the FMCSA’s number one priority,” the agency claims that the agency has realized great success in reducing crashes, injuries and fatalities, noting it has “developed a Strategic Plan” to raise the bar to enter the motor carrier industry and maintain high safety standards to remain in the industry.

Touting CSA as a “compliance model to improve safety and ultimately … reduce large truck and bus crashes” the agency claims CSA is an operational success “developed with an unprecedented level of stakeholder input, analysis, and planning” and that “recently implemented enhancements to the Safety Measurement System (SMS)” reflect input collected from the comments of more than 19,000 carriers and 2,900 law enforcement personnel.

It is not surprising, but no mention was made of the lawsuit, publication of SMS methodology for shipper and broker use, or opposition to the agency’s use of Internet guidance to leverage the public as the enforcers of SMS methodology.

4.         Overdrive Magazine Concludes Inconsistent Enforcement is Picking on the Little Guys and Owner-Operator Fleets. 

Although the FMCSA concludes the system is not biased against any carriers, the March 14 edition of Overdrive concludes that an owner-operator’s truck is four times as likely to get inspected as a truck operating under the authority of a 500 unit fleet.  

Importantly, the article further notes that two years after its advent, CSA has still failed to produce a single public score for 80% of the carriers with operating authority.

After referencing our pending lawsuit, the article notes that “The agency denies CSA / SMS constitutes a safety rating and washes its hands of how the data is treated in the real world.” When asked, the agency spokesman did not address the May 16th guidance but instead stated, “SMS quantifies the on-road safety performance of motor carriers so that FMCSA can prioritize them for intervention.”  Further, “Use of the SMS for purposes other than those identified may produce unintended results and inaccurate conclusions.”

This article is a recommended read.  

5.         GAO and IG Studies

As a result of the Small Business Committee and T&I subcommittee hearings in which we played a large role, both the DOT’s Inspector General and the General Accounting Office are conducting investigations of SMS methodology and CSA.  ASECTT will be advising its members on the best way to make their concerns and comments known to these important investigators.

By |March 15th, 2013|ASECTT, newsletter, SMS, SMS Methodology|Comments Off on ASECTT Newsletter March 15, 2013

ASECTT Newsletter March 15, 2013


ASECTT Newsletter
March 15, 2013
1.         ASECTT et al. v. FMCSA
All briefs have been filed and we are awaiting scheduling of oral argument.  To view copies of these pleadings, see http://www.asectt.blogspot.com/p/asectt-et-al-v-fmcsa.html.

2.         Motor Carrier Safety Advisory Committee and Parker Committee Update.  

The FMCSA has made additional appointments to its handpicked Motor Carrier Safety Advisory Committee and the Parker subcommittee considering SMS methodology. The new appointees consist primarily of safety advocate groups, a union representative and law enforcement.  While Schneider and the TIA were added, affected small business nominees were ignored.  A report from the Parker Committee critical of SMS methodology, particularly the inclusion of non-preventable accidents in the crash BASIC is predicted in the coming months.  The agency has again signaled that it is not prepared to submit SMS methodology for rulemaking and the earliest possible date for submission is now January of 2014.

3.         Ferro Speaks to House Subcommittee.

The following link contains the agency’s summary of Administrator Ferro’s testimony to the Subcommittee on Highways and Transit Committee on Transportation and Infrastructure concerning various aspects of MAP-21, including implementation of SMS methodology.  Emphasizing that “Safety is the FMCSA’s number one priority,” the agency claims that the agency has realized great success in reducing crashes, injuries and fatalities, noting it has “developed a Strategic Plan” to raise the bar to enter the motor carrier industry and maintain high safety standards to remain in the industry.

Touting CSA as a “compliance model to improve safety and ultimately … reduce large truck and bus crashes” the agency claims CSA is an operational success “developed with an unprecedented level of stakeholder input, analysis, and planning” and that “recently implemented enhancements to the Safety Measurement System (SMS)” reflect input collected from the comments of more than 19,000 carriers and 2,900 law enforcement personnel.

It is not surprising, but no mention was made of the lawsuit, publication of SMS methodology for shipper and broker use, or opposition to the agency’s use of Internet guidance to leverage the public as the enforcers of SMS methodology.

4.         Overdrive Magazine Concludes Inconsistent Enforcement is Picking on the Little Guys and Owner-Operator Fleets. 

Although the FMCSA concludes the system is not biased against any carriers, the March 14 edition of Overdrive concludes that an owner-operator’s truck is four times as likely to get inspected as a truck operating under the authority of a 500 unit fleet.  

Importantly, the article further notes that two years after its advent, CSA has still failed to produce a single public score for 80% of the carriers with operating authority.

After referencing our pending lawsuit, the article notes that “The agency denies CSA / SMS constitutes a safety rating and washes its hands of how the data is treated in the real world.” When asked, the agency spokesman did not address the May 16th guidance but instead stated, “SMS quantifies the on-road safety performance of motor carriers so that FMCSA can prioritize them for intervention.”  Further, “Use of the SMS for purposes other than those identified may produce unintended results and inaccurate conclusions.”

This article is a recommended read.  

5.         GAO and IG Studies

As a result of the Small Business Committee and T&I subcommittee hearings in which we played a large role, both the DOT’s Inspector General and the General Accounting Office are conducting investigations of SMS methodology and CSA.  ASECTT will be advising its members on the best way to make their concerns and comments known to these important investigators.

By |March 15th, 2013|ASECTT, newsletter, SMS, SMS Methodology|Comments Off on ASECTT Newsletter March 15, 2013

ASECTT Newsletter March 15, 2013


ASECTT Newsletter
March 15, 2013
1.         ASECTT et al. v. FMCSA
All briefs have been filed and we are awaiting scheduling of oral argument.  To view copies of these pleadings, see http://www.asectt.blogspot.com/p/asectt-et-al-v-fmcsa.html.

2.         Motor Carrier Safety Advisory Committee and Parker Committee Update.  

The FMCSA has made additional appointments to its handpicked Motor Carrier Safety Advisory Committee and the Parker subcommittee considering SMS methodology. The new appointees consist primarily of safety advocate groups, a union representative and law enforcement.  While Schneider and the TIA were added, affected small business nominees were ignored.  A report from the Parker Committee critical of SMS methodology, particularly the inclusion of non-preventable accidents in the crash BASIC is predicted in the coming months.  The agency has again signaled that it is not prepared to submit SMS methodology for rulemaking and the earliest possible date for submission is now January of 2014.

3.         Ferro Speaks to House Subcommittee.

The following link contains the agency’s summary of Administrator Ferro’s testimony to the Subcommittee on Highways and Transit Committee on Transportation and Infrastructure concerning various aspects of MAP-21, including implementation of SMS methodology.  Emphasizing that “Safety is the FMCSA’s number one priority,” the agency claims that the agency has realized great success in reducing crashes, injuries and fatalities, noting it has “developed a Strategic Plan” to raise the bar to enter the motor carrier industry and maintain high safety standards to remain in the industry.

Touting CSA as a “compliance model to improve safety and ultimately … reduce large truck and bus crashes” the agency claims CSA is an operational success “developed with an unprecedented level of stakeholder input, analysis, and planning” and that “recently implemented enhancements to the Safety Measurement System (SMS)” reflect input collected from the comments of more than 19,000 carriers and 2,900 law enforcement personnel.

It is not surprising, but no mention was made of the lawsuit, publication of SMS methodology for shipper and broker use, or opposition to the agency’s use of Internet guidance to leverage the public as the enforcers of SMS methodology.

4.         Overdrive Magazine Concludes Inconsistent Enforcement is Picking on the Little Guys and Owner-Operator Fleets. 

Although the FMCSA concludes the system is not biased against any carriers, the March 14 edition of Overdrive concludes that an owner-operator’s truck is four times as likely to get inspected as a truck operating under the authority of a 500 unit fleet.  

Importantly, the article further notes that two years after its advent, CSA has still failed to produce a single public score for 80% of the carriers with operating authority.

After referencing our pending lawsuit, the article notes that “The agency denies CSA / SMS constitutes a safety rating and washes its hands of how the data is treated in the real world.” When asked, the agency spokesman did not address the May 16th guidance but instead stated, “SMS quantifies the on-road safety performance of motor carriers so that FMCSA can prioritize them for intervention.”  Further, “Use of the SMS for purposes other than those identified may produce unintended results and inaccurate conclusions.”

This article is a recommended read.  

5.         GAO and IG Studies

As a result of the Small Business Committee and T&I subcommittee hearings in which we played a large role, both the DOT’s Inspector General and the General Accounting Office are conducting investigations of SMS methodology and CSA.  ASECTT will be advising its members on the best way to make their concerns and comments known to these important investigators.

By |March 15th, 2013|ASECTT, newsletter, SMS, SMS Methodology|Comments Off on ASECTT Newsletter March 15, 2013

ASECTT Newsletter March 15, 2013


ASECTT Newsletter
March 15, 2013
1.         ASECTT et al. v. FMCSA
All briefs have been filed and we are awaiting scheduling of oral argument.  To view copies of these pleadings, see http://www.asectt.blogspot.com/p/asectt-et-al-v-fmcsa.html.

2.         Motor Carrier Safety Advisory Committee and Parker Committee Update.  

The FMCSA has made additional appointments to its handpicked Motor Carrier Safety Advisory Committee and the Parker subcommittee considering SMS methodology. The new appointees consist primarily of safety advocate groups, a union representative and law enforcement.  While Schneider and the TIA were added, affected small business nominees were ignored.  A report from the Parker Committee critical of SMS methodology, particularly the inclusion of non-preventable accidents in the crash BASIC is predicted in the coming months.  The agency has again signaled that it is not prepared to submit SMS methodology for rulemaking and the earliest possible date for submission is now January of 2014.

3.         Ferro Speaks to House Subcommittee.

The following link contains the agency’s summary of Administrator Ferro’s testimony to the Subcommittee on Highways and Transit Committee on Transportation and Infrastructure concerning various aspects of MAP-21, including implementation of SMS methodology.  Emphasizing that “Safety is the FMCSA’s number one priority,” the agency claims that the agency has realized great success in reducing crashes, injuries and fatalities, noting it has “developed a Strategic Plan” to raise the bar to enter the motor carrier industry and maintain high safety standards to remain in the industry.

Touting CSA as a “compliance model to improve safety and ultimately … reduce large truck and bus crashes” the agency claims CSA is an operational success “developed with an unprecedented level of stakeholder input, analysis, and planning” and that “recently implemented enhancements to the Safety Measurement System (SMS)” reflect input collected from the comments of more than 19,000 carriers and 2,900 law enforcement personnel.

It is not surprising, but no mention was made of the lawsuit, publication of SMS methodology for shipper and broker use, or opposition to the agency’s use of Internet guidance to leverage the public as the enforcers of SMS methodology.

4.         Overdrive Magazine Concludes Inconsistent Enforcement is Picking on the Little Guys and Owner-Operator Fleets. 

Although the FMCSA concludes the system is not biased against any carriers, the March 14 edition of Overdrive concludes that an owner-operator’s truck is four times as likely to get inspected as a truck operating under the authority of a 500 unit fleet.  

Importantly, the article further notes that two years after its advent, CSA has still failed to produce a single public score for 80% of the carriers with operating authority.

After referencing our pending lawsuit, the article notes that “The agency denies CSA / SMS constitutes a safety rating and washes its hands of how the data is treated in the real world.” When asked, the agency spokesman did not address the May 16th guidance but instead stated, “SMS quantifies the on-road safety performance of motor carriers so that FMCSA can prioritize them for intervention.”  Further, “Use of the SMS for purposes other than those identified may produce unintended results and inaccurate conclusions.”

This article is a recommended read.  

5.         GAO and IG Studies

As a result of the Small Business Committee and T&I subcommittee hearings in which we played a large role, both the DOT’s Inspector General and the General Accounting Office are conducting investigations of SMS methodology and CSA.  ASECTT will be advising its members on the best way to make their concerns and comments known to these important investigators.

By |March 15th, 2013|ASECTT, newsletter, SMS, SMS Methodology|Comments Off on ASECTT Newsletter March 15, 2013

ASECTT Newsletter March 15, 2013


ASECTT Newsletter
March 15, 2013
1.         ASECTT et al. v. FMCSA
All briefs have been filed and we are awaiting scheduling of oral argument.  To view copies of these pleadings, see http://www.asectt.blogspot.com/p/asectt-et-al-v-fmcsa.html.

2.         Motor Carrier Safety Advisory Committee and Parker Committee Update.  

The FMCSA has made additional appointments to its handpicked Motor Carrier Safety Advisory Committee and the Parker subcommittee considering SMS methodology. The new appointees consist primarily of safety advocate groups, a union representative and law enforcement.  While Schneider and the TIA were added, affected small business nominees were ignored.  A report from the Parker Committee critical of SMS methodology, particularly the inclusion of non-preventable accidents in the crash BASIC is predicted in the coming months.  The agency has again signaled that it is not prepared to submit SMS methodology for rulemaking and the earliest possible date for submission is now January of 2014.

3.         Ferro Speaks to House Subcommittee.

The following link contains the agency’s summary of Administrator Ferro’s testimony to the Subcommittee on Highways and Transit Committee on Transportation and Infrastructure concerning various aspects of MAP-21, including implementation of SMS methodology.  Emphasizing that “Safety is the FMCSA’s number one priority,” the agency claims that the agency has realized great success in reducing crashes, injuries and fatalities, noting it has “developed a Strategic Plan” to raise the bar to enter the motor carrier industry and maintain high safety standards to remain in the industry.

Touting CSA as a “compliance model to improve safety and ultimately … reduce large truck and bus crashes” the agency claims CSA is an operational success “developed with an unprecedented level of stakeholder input, analysis, and planning” and that “recently implemented enhancements to the Safety Measurement System (SMS)” reflect input collected from the comments of more than 19,000 carriers and 2,900 law enforcement personnel.

It is not surprising, but no mention was made of the lawsuit, publication of SMS methodology for shipper and broker use, or opposition to the agency’s use of Internet guidance to leverage the public as the enforcers of SMS methodology.

4.         Overdrive Magazine Concludes Inconsistent Enforcement is Picking on the Little Guys and Owner-Operator Fleets. 

Although the FMCSA concludes the system is not biased against any carriers, the March 14 edition of Overdrive concludes that an owner-operator’s truck is four times as likely to get inspected as a truck operating under the authority of a 500 unit fleet.  

Importantly, the article further notes that two years after its advent, CSA has still failed to produce a single public score for 80% of the carriers with operating authority.

After referencing our pending lawsuit, the article notes that “The agency denies CSA / SMS constitutes a safety rating and washes its hands of how the data is treated in the real world.” When asked, the agency spokesman did not address the May 16th guidance but instead stated, “SMS quantifies the on-road safety performance of motor carriers so that FMCSA can prioritize them for intervention.”  Further, “Use of the SMS for purposes other than those identified may produce unintended results and inaccurate conclusions.”

This article is a recommended read.  

5.         GAO and IG Studies

As a result of the Small Business Committee and T&I subcommittee hearings in which we played a large role, both the DOT’s Inspector General and the General Accounting Office are conducting investigations of SMS methodology and CSA.  ASECTT will be advising its members on the best way to make their concerns and comments known to these important investigators.

By |March 15th, 2013|ASECTT, newsletter, SMS, SMS Methodology|Comments Off on ASECTT Newsletter March 15, 2013

ASECTT Newsletter March 15, 2013


ASECTT Newsletter
March 15, 2013
1.         ASECTT et al. v. FMCSA
All briefs have been filed and we are awaiting scheduling of oral argument.  To view copies of these pleadings, see http://www.asectt.blogspot.com/p/asectt-et-al-v-fmcsa.html.

2.         Motor Carrier Safety Advisory Committee and Parker Committee Update.  

The FMCSA has made additional appointments to its handpicked Motor Carrier Safety Advisory Committee and the Parker subcommittee considering SMS methodology. The new appointees consist primarily of safety advocate groups, a union representative and law enforcement.  While Schneider and the TIA were added, affected small business nominees were ignored.  A report from the Parker Committee critical of SMS methodology, particularly the inclusion of non-preventable accidents in the crash BASIC is predicted in the coming months.  The agency has again signaled that it is not prepared to submit SMS methodology for rulemaking and the earliest possible date for submission is now January of 2014.

3.         Ferro Speaks to House Subcommittee.

The following link contains the agency’s summary of Administrator Ferro’s testimony to the Subcommittee on Highways and Transit Committee on Transportation and Infrastructure concerning various aspects of MAP-21, including implementation of SMS methodology.  Emphasizing that “Safety is the FMCSA’s number one priority,” the agency claims that the agency has realized great success in reducing crashes, injuries and fatalities, noting it has “developed a Strategic Plan” to raise the bar to enter the motor carrier industry and maintain high safety standards to remain in the industry.

Touting CSA as a “compliance model to improve safety and ultimately … reduce large truck and bus crashes” the agency claims CSA is an operational success “developed with an unprecedented level of stakeholder input, analysis, and planning” and that “recently implemented enhancements to the Safety Measurement System (SMS)” reflect input collected from the comments of more than 19,000 carriers and 2,900 law enforcement personnel.

It is not surprising, but no mention was made of the lawsuit, publication of SMS methodology for shipper and broker use, or opposition to the agency’s use of Internet guidance to leverage the public as the enforcers of SMS methodology.

4.         Overdrive Magazine Concludes Inconsistent Enforcement is Picking on the Little Guys and Owner-Operator Fleets. 

Although the FMCSA concludes the system is not biased against any carriers, the March 14 edition of Overdrive concludes that an owner-operator’s truck is four times as likely to get inspected as a truck operating under the authority of a 500 unit fleet.  

Importantly, the article further notes that two years after its advent, CSA has still failed to produce a single public score for 80% of the carriers with operating authority.

After referencing our pending lawsuit, the article notes that “The agency denies CSA / SMS constitutes a safety rating and washes its hands of how the data is treated in the real world.” When asked, the agency spokesman did not address the May 16th guidance but instead stated, “SMS quantifies the on-road safety performance of motor carriers so that FMCSA can prioritize them for intervention.”  Further, “Use of the SMS for purposes other than those identified may produce unintended results and inaccurate conclusions.”

This article is a recommended read.  

5.         GAO and IG Studies

As a result of the Small Business Committee and T&I subcommittee hearings in which we played a large role, both the DOT’s Inspector General and the General Accounting Office are conducting investigations of SMS methodology and CSA.  ASECTT will be advising its members on the best way to make their concerns and comments known to these important investigators.

By |March 15th, 2013|ASECTT, newsletter, SMS, SMS Methodology|Comments Off on ASECTT Newsletter March 15, 2013