Flight Safety Information April 4, 2012 - No. 067 In This Issue Canada air safety checks have big flaws: auditor Airlines for America (A4A) Committed to Safety Partnership with FAA The European Commission Updates The European Safety List Of Airlines Subject To An Operating Ban Russia's poor aviation safety record FAA To Host UAS Webinars PRISM ANNUAL SMS AUDIT RESULTS Boeing 747-8 Approved to Serve Two Hundred Airports Globally East Africa: EA Aviation Facing Severe Manpower Loss WFP Promotes Aviation Safety The ISASI Rudolf Kapustin Memorial Scholarship Canada air safety checks have big flaws: auditor OTTAWA, April 3 (Reuters) - Canada's system for monitoring airline safety has major flaws that could result in more accidents unless improvements are made, the government's spending watchdog said on Tuesday. Auditor General Michael Ferguson said that although the transport department's regulations call for aviation companies to be inspected every year, about 70 percent of them were not investigated in the 2010-11 fiscal year. "Transport Canada is not adequately managing the risks associated with its civil aviation oversight," he said. "The significant weaknesses that need to be addressed involve how the department plans, conducts, and reports on its surveillance activities," he wrote in a report. There are more than 34,000 aircraft in Canada and a total of more than 5,000 air carriers, maintenance firms, airports and aerodromes. In 2010 more than 75 million passengers flew with the borders of Canada, the world's second largest country. In 2009 and 2010, the total number of accidents was the lowest recorded in a 10-year span in Canada. The last serious accident occurred last August when a First Air jet crashed in the northern Arctic, killing 12 people. Ferguson said that the International Civil Aviation Organization has forecast that the current volume of air traffic in North America could more than double by 2025. "If nothing else changes, this increase in volume could lead to more accidents. The department recognizes that it will have to do more just to keep the accident rate per revenue-generating passenger mile traveled in Canada at current levels," he said. Transport Minister Denis Lebel, while noting Canada's good safety record, said he had ordered his department to address the problems identified in the report. "The department is continuously looking for ways to make the skies safer for all Canadians and agrees that there is still more that can be done to improve its administration of oversight activities," he said in a statement. Canada moved to a new system of surveillance in 2008 that shifted the focus away from inspecting aircraft and more toward ensuring airlines were able to comply with safety rules. This means Transport Canada has had to work out which airlines might be more at risk. Ferguson, though, found that the department was missing key information for most large air carriers, maintenance organizations and large airports. "The problem is particularly acute with aviation companies and large airports that were not inspected in the previous year," he said. "Without complete and reliable risk profiles to conduct risk assessments, the department may not inspect the aviation companies that present the highest risks to aviation safety." In 2010-11, the department only examined 67 percent of the operations it had itself identified as higher risk. Ferguson also found that Transport Canada overestimated the time inspectors had to carry out surveillance work and did not have accurate records of what the inspectors were doing. "In the absence of such information, it is difficult for the department to develop realistic surveillance plans," he said. Back to Top Airlines for America (A4A) Committed to Safety Partnership with FAA DALLAS, April 3, 2012 /PRNewswire via COMTEX/ -- Recognizes Annual Nuts and Bolts Award Winners at MRO Americas Airlines for America (A4A), the industry trade organization for the leading U.S. airlines, today reaffirmed its commitment to robust data-driven safety initiatives along with the deployment of infrastructure enhancements to ensure that commercial aviation remains the world's safest form of transportation. "Aviation is in its safest period in history and remains our number-one priority," said A4A President and CEO Nicholas E. Calio. "Safety underpins every aspect of airline operations, and making further enhancements, including modernizing our infrastructure, should be a key component of a U.S. National Airline Policy." Speaking at the Aviation Week Maintenance, Repair and Overhaul (MRO) Americas conference, Calio attributed the industry's exemplary safety record to a strong working partnership with the Federal Aviation Administration (FAA) that encourages increased sharing of data and information. The industry supports the work of FAA to implement a wide range of initiatives included in the recently enacted FAA Modernization and Reform Act, which will enhance safety. A4A is committed to a safe and efficient transition to a next-generation air traffic management system and is a key component of a National Airline Policy. Some of the projects supported by A4A include the deployment of ground radar at major airports, promoting the sharing of safety data by airlines and their employees with the FAA, and establishing a risk-based inspection system for aircraft repair stations located overseas. A4A Nuts and Bolts Award Also at MRO Americas, the 45th Annual A4A Nuts and Bolts Award was presented by the A4A Engineering, Maintenance and Material Council (EMMC) recognizing exceptional service and contributions in the engineering or maintenance fields of the commercial aviation industry. The winner in the airline category is Mark Yerger, FedEx Express Vice President of Aircraft Engineering; and the recipient in the industry category is Carol Giles, former manager of the Aircraft Maintenance Division of the FAA Flight Standards Service. "A4A congratulates the 2012 recipients of the Nuts and Bolts Award. The accomplishments of these dedicated aviation professionals have advanced aircraft and airline engineering and maintenance operations and support an industry safety culture that is second to none," Calio said. Yerger has served with FedEx Express for 23 years, having been steadily promoted through the engineering ranks to his current position of vice president. During Yerger's tenure with FedEx, he has provided leadership and critical industry representation on multiple fronts and implemented innovative programs to improve FedEx aircraft performance. He has been the co-chairman of the FAA Airworthiness Assurance Working Group since 2006. A4A recognized Giles for her 31-year aviation career, most recently serving at FAA. She began her FAA career in 1990 as an aviation safety inspector, specializing in aviation and aircraft maintenance and eventually became assistant deputy director of Flight Standards Service. Giles worked to develop and implement safety rules, regulations and policies affecting aviation maintenance facilities, air carriers and maintenance personnel. ABOUT A4A Annually, commercial aviation helps drive more than $1 trillion in U.S. economic activity and more than 10 million U.S. jobs. A4A airline members and their affiliates transport more than 90 percent of all U.S. airline passenger and cargo traffic. For more information about the airline industry, visit www.airlines.org and follow us on Twitter @airlinesdotorg. SOURCE Airlines for America Back to Top The European Commission Updates The European Safety List Of Airlines Subject To An Operating Ban. Source: European Commission The European Commission has adopted today the 19th update of the European list of air carriers which are for safety reasons subject to an operating ban or operational restrictions within the European Union. Conviasa, an air carrier certified in Venezuela, was added to the list due to safety concerns. Following constructive consultations, Libyan authorities decided to adopt strong measures applicable to all air carriers licensed in Libya, which exclude them from flying into the EU until at least November 2012. The Vice-President of the European Commission responsible for transport, Siim Kallas, said: "The Commission is ready to spare no effort to assist its neighbours in building their technical and administrative capacity to overcome any difficulties in the area of safety as quickly and as efficiently as possible. In the meantime, safety comes first. We cannot afford any compromise in this area. Where we have evidence inside or outside the European Union that air carriers are not performing safe operations, we must act to guarantee to exclude any risks to safety." The European Commission has adopted today the 19th update of the European safety list of air carriers subject to operating bans and other operational restrictions within the EU, better known as "the EU air safety list". The decision is based on the unanimous opinion of the Air Safety Committee, composed of representatives of the 27 Members States of the EU, Croatia, Norway, Iceland, Switzerland and of the European Aviation Safety Agency (EASA). The new list replaces the previous one established in November 2011 and can be consulted on the Commission's website. In order to ensure that safety risks are contained, an operating ban on Conviasa certified in the Bolivarian Republic of Venezuela was rendered necessary due to numerous safety concerns arising from accidents and the results of ramp checks at EU airports. The safety performance of two other Venezuelan air carriers, Estellar Latinoamerica and Aerotuy, was also reviewed in depth; however, measures were not considered necessary at this stage. Nonetheless, these two air carriers remain subject to increased monitoring. Serious concerns were identified regarding the safety oversight of air carriers licensed in Libya. So, intense consultations were held with the civil aviation authorities of Libya and with the Libyan Minister of Transport. As a result, the Libyan civil aviation authorities have adopted restrictions applicable to all air carriers licensed in Libya, which exclude them from flying into the EU with immediate effect and until at least 22 November 2012. On this basis, the Commission, with the full support of the Air Safety Committee, considered that inclusion of Libyan air carriers in the EU air safety list was not necessary. Nonetheless, implementation of the measures decided by the Libyan authorities remains subject to close monitoring. The European air safety list was also updated to reflect air carriers in existence in States referenced on the list in previous decisions: for the Democratic Republic of Congo, Jet Congo Airways was added; for Equatorial Guinea, Punto Azul was added whilst GETRA, Guinea Airways, UTAGE, Euroguineana de Aviacion y Transportes, General Work Aviacion, Star Equatorial Airlines and EGAMS were removed upon evidence they ceased operations; for Indonesia, TransNusa Aviation Mandiri, Enggang Air Service, Surya Air, Ersa Eastern Aviation and Matthew Air Nusantara newly certified in Indonesia were added, whilst Megantara was removed upon evidence they ceased operations; for Mauritania, Mauritania Airlines was added whilst Mauritania Airways was removed upon evidence it ceased operations; for the Philippines, Aero Equipment Aviation Inc, AirAsia Philippines, Certeza Infosys Corp., Mid-Sea Express, Southern Air Flight Services, NorthSky Air Inc., Island Helicopter Services were added. Finally, the Commission recognises the efforts of the safety oversight authorities of Albania, Aruba, Indonesia, Libya, Pakistan and Russia to reform the civil aviation system and notably to improve safety to guarantee that international safety standards are effectively and consistently applied. The Commission is ready to provide active support for these reforms in cooperation with ICAO, EU Member States and the European Aviation Safety Agency. The Commission remains fully committed to supporting better compliance with international safety standards whenever possible and has in this perspective mandated the European Aviation Safety Agency to carry out a series of technical assistance missions to support the competent authorities of a number of states in their efforts to enhance safety. The updated European air safety list includes all carriers certified in 21 States, accounting for 279 known air carriers, whose operations are fully banned in the European Union: Afghanistan, Angola, Benin, Republic of Congo, the Democratic Republic of Congo, Djibouti, Equatorial Guinea, Gabon (with the exception of three carriers which operate under restrictions and conditions), Indonesia (with the exception of six carriers), Kazakhstan (with the exception of one carrier which operates under restrictions and conditions), Kyrgyzstan, Liberia, Mauritania, Mozambique, Philippines, Sierra Leone, Sao Tome and Principe, Sudan, Swaziland and Zambia. The list also includes five individual carriers: Blue Wing Airlines from Surinam, Meridian Airways from Ghana, Rollins Air from Honduras and Silverback Cargo Freighters from Rwanda and Conviasa from the Bolivarian Republic of Venezuela. Additionally, the list includes 11 air carriers which are subject to operational restrictions and allowed to operate into the EU under strict conditions: Air Astana from Kazakhstan as mentioned before, Air Koryo from the Democratic People Republic of Korea, Airlift International from Ghana, Air Service Comores, Afrijet, Gabon Airlines and SN2AG from Gabon, Iran Air, TAAG Angolan Airlines, Air Madagascar and Jordan Aviation. http://www.egovmonitor.com/node/48788 Back to Top Russia's poor aviation safety record The Russian plane crash in Siberia is the worst since a passenger plane slammed into a riverbank near the city of Yaroslavl in September 2011. Pilot error was blamed for the crash in Yaroslavl. 44 people were killed including a professional ice hockey team. September 2011: mourners grieve near grave of Ukranian-Russian ice-hockey player Sobchenko Credit: Reuters Pilot error and fog were also found to be the main causes of a crash in April 2010. It killed Poland's president and 95 other people as their plane was trying to land near Smolensk, in western Russia. April 2010: an Interior Ministry officer stands guard near a part of the wreckage of a Polish government Tupolev Tu-154 aircraft Credit: Reuters Russian President Vladimir Putin has already said airlines should put passenger safety above commercial interests. Russia and the former Soviet republics had one of the world's worst air-traffic safety records last year. The International Air Transport Association said the total accident rate was almost three times the world average. The ATR-72 has also been involved in several accidents in recent years. Most recently, a plane went down in bad weather in Cuba in November 2010. All 68 people on board were killed. Cuban aviation officials said the investigation showed there was nothing wrong with the aircraft. November 2010: burning remains of an ATR-72-212 twin turboprop aircraft which crashed near Guasimal in Cuba Credit: Reuters In August 2009, an ATR-72 flown by Bangkok Airways skidded off the runway and crashed into a building after landing in stormy weather on the Thai resort island of Samui. It killed the pilot and injured seven people. http://www.itv.com/news/2012-04-02/russias-poor-aviation-safety-record/ Back to Top FAA To Host UAS Webinars FAA will hold two webinars scheduled to discuss the identification of six test ranges/sites for Unmanned Aerial Systems (UAS) integration into the NAS. This is a pilot project in response to the congressional mandate found in the FAA Modernization and Reform Act of 2012, H.R. 658, Section 331(c). The webinars will explain the actions FAA intends to take. A comment period will be opened for feedback on the issue, which will help the agency develop UAS site requirements, standards and oversight activities. Registration is required for participation in the webinars due to limited space. The webinars have been scheduled to accommodate interested parties in all time zones. The first webinar will take place at 10 a.m. EDT April 10, 2012 (to register, visit https://www.eventbuilder.com/encounter/event_desc.asp?p_event=q5d2e4p8), and at 2 p.m. EDT April 11, 2012 (to register, visit https://www.eventbuilder.com/encounter/event_desc.asp?p_event=e45e2w71). AAAE Regulatory Affairs staff will participate in the April 10, 2012 webinar, and will submit comments on behalf of association members. Members should submit comments to Natalie Johnston, director - regulatory affairs, by May 1, 2012. http://www.aviationnews.net/?do=headline&news_ID=203737 Back to Top Back to Top Boeing 747-8 Approved to Serve Two Hundred Airports Globally - London Heathrow is 200th airport to welcome 747-8 operations - Newest member of 747 family today serves twice as many destinations as its competitor SEATTLE, April 3, 2012 /PRNewswire via COMTEX/ -- The Boeing /quotes/zigman/220026/quotes/nls/ba BA -0.69% 747-8 is approved for operations at 200 airports around the world - less than six months after entering service. To date, 63 airports around the world are supporting revenue flights from 14 in-service 747-8 Freighters operated by five carriers. The approval shows the newest member of the 747 family can operate safely within an airport environment, accounting for regulatory requirements, clearances, pavement loading and parking requirements. London Heathrow Airport is the 200th airport to receive regulatory approval for 747-8 operations. "No one knows the 747-8 better than the teams at Boeing. We put that knowledge to work by partnering with airlines, airports and regulators around the globe to ensure that our customers get the ultimate value out of their investment," said Sherry Carbary, vice president, Flight Services, Boeing Commercial Aviation Services. The 747-8 family is the only airplane above 400 seats approved to serve more than 60 airports around the world. The 747-8's increased wingspan over the 747-400 places the airplane in the lower end of International Civil Aviation Organization's (ICAO) airport design code F. ICAO airport design codes categorize airplanes based on wingspan and outer main-gear wheel span. As part of its commitment to provide customers a competitive edge, Boeing is working with airports and civil aviation authorities worldwide to ensure that the proper plans are in place to accommodate safe operations. "Boeing applied a true working together approach to create a fruitful and constructive environment to gain regulatory approvals for 747-8 operations," said Sten Rossby, chief technical pilot of Cargolux. "Our business success depends on having a sizeable choice of destinations." Boeing 747-8 operators have identified a total of 240 destination airports, significantly more than the airplane's main competitor is able to serve. Boeing offers a comprehensive portfolio of commercial aviation services, collectively known as the Boeing Edge, bringing value and advantages to customers and the industry. Boeing Flight Services offers integrated offerings to drive optimized performance, efficiency and safety through advanced flight and maintenance training as well as improved air traffic management and 24/7 flight operations support. The company offers a variety of airport technology services to help ensure that airports and Boeing airplanes interact as effectively as possible. The 747-8 family provides airlines with double-digit improvements in fuel burn, operating costs and emissions, while being 30 percent quieter and adding more capacity. A technical article on 747-8 airport compatibility is available in Boeing's award-winning customer support magazine Aero [ http://www.boeing.com/commercial/aeromagazine/articles/2010_q3/3/ ]. Contact:Samantha Solomon Boeing Commercial Aviation Services Communications+1 206 304 8127Samantha.solomon@boeing.com Jim ProulxBoeing 747 Communications +1 206 850 2102 Jim.proulx@boeing.com SOURCE Boeing Back to Top East Africa: EA Aviation Facing Severe Manpower Loss Nairobi, Kenya - The East African aviation industry is losing highly skilled manpower to other countries, especially the Middle East. The General Secretary for the International Civil Aviation Organisation, Raymond Benjamin said until recently, the rate of loss was manageable but it is now important to avert a crisis by focusing on the training and hiring of more staff. Low pay has however resulted in brain-drain as Kenyan pilots leave to seek better returns with international airlines. Regional airlines have voiced their concern about losing pilots to the bigger players. Benjamin was speaking during the launch of a training programme for pilots, air traffic controllers and technical staff. Director General of the Kenya Civil Aviation Authority (KCAA) Hilary Kioko said the national airspace regulator has spent Sh1.2 billion over 10 years to improve the East African School of Aviation (EASA). Kioko said the funds have been used to improve on infrastructure, training facilities as well as instructor development programs. Kioko added that it will contribute largely to Vision 2030 by helping the aviation industry meet its human resource needs. Kenya needs 2,000 more pilots to meet the current demand of 5,000 pilots. There are 500 aircraft engineers at the moment. Estimated costs for training a traffic controller stands at Sh3.5 million while an aviation engineer takes up Sh1 million at the diploma level. "We are looking to set up schools of excellence in every county that will set the standards for any new training facility," Benjamin further added. He said most of the skills offered by private colleges cannot be absorbed by international airlines because they don't have recognised certification. The airlines industry has in the recent past witnessed expansion and entry of new players that has piled pressure on the local talent pool. The number of aircraft landing in Kenya has also increased from 757 in 2008 to 1,056 in 2011 with operators acquiring bigger aircraft. http://allafrica.com/stories/201204040157.html Back to Top WFP Promotes Aviation Safety Organizing Safety Awareness Campaign Dubai-UAE April 22 - 26 2012 The United Nations World Food Programme the world's Largest Humanitarian Organization and UN's front line agency in the fight against global hunger is very pleased to inform you that we are organizing within the RASG-MID framework a Safety Awareness Campaign with great support of UAE GCAA and in close coordination with ICAO, IFALPA, with other support partners such as Boeing and GCC COSCAP. The Safety Awareness Campaign will be taking place in Sheraton Dubai Creek Hotel and Towers , Dubai- UAE, April 22nd - 26th 2012. The campaign is part of WFP Aviation Safety annual plan and endeavourers to promote aviation safety worldwide. We are entrusted to provide the utmost possible support to all WFP service providers and the aviation industry in general and to ensure the highest benefits exposure, the safety Awareness campaign will be FREE OF CHARGE to attend. The Safety Awareness Campaign will include essential components that are supported by ICAO and their strategic objectives in the implementation of safety and threat management across all safety-related disciplines and staff members in all States. The Safety Awareness Campaign agenda is put to address as many vital safety factors and principles as possible: 22 - 26 April 2011 SMS Course A: * Full Introduction to ICAO Safety Management System Course (0830-1630) 23rd April 2011 Full day session: Perspectives on Regional safety concerns: (0830 - 1730)(please see attached Agenda) 24th April 2011 Workshop A: * State Safety Program (SSP) and Safety Mangement System (SMS) Implementation workshop (0900-1600) Workshop B: * Exploring Threat and Error Managment (TEM) in the Air Trafice Control Worl (0900-1600) 25th April 2011 Workshop A: * State Safety Program (SSP) and Safety Mangement System (SMS) Implementation workshop (0900-1600) Workshop B: * Safety reporting system ( the need to have the State in the loop (0900-1600) Workshop C: * Safety Managment System (SMS) Interface Aspects in an Airport Enviroment (0900 - 1600) 26th April 2011 Workshop A: * Stay Alert- Applying Fatigue Risk management system (FRSM) in a large scale in the Mega-Carriers (0900-1600) Workshop B: * Safety reporting system ( the need to have the State in the loop ) (0900-1600) Workshop C: * State Safety Program (SSP) and Safety Mangement System (SMS) Implementation worshop (0900 - 1600) For ICAO SMS Course 22-26 April ; Note 01: ICAO requires all 4 days course attendance and exam passing grade to be awarded a successful completion of the ICAO SMS course certificate. Note 02: Please fill the Registration form for the related event and send it to sharjah.asu@wfp.org Please find attached the Registration Form. Thank you and hope to see you with us. *********** Back to Top Calls for Application for The ISASI Rudolf Kapustin Memorial Scholarship DEADLINE for filling application 15 April, 2012 The 2012 ISASI Seminar will be held at the Baltimore Marriott Waterfront Aug 28-30, 2012 INTERNATIONAL SOCIETY OF AIR SAFETY INVESTIGATORS 2012 The ISASI Rudolf Kapustin Memorial Scholarship (In memorial to all ISASI members who have died) Purpose: To encourage and assist college-level students interested in the field of aviation safety and aircraft occurrence investigation. Funding: The ISASI Rudolf Kapustin Memorial Scholarship fund will be established through donations and will provide an annual allocation of funds for the scholarship if funds are available. Eligibility: Applicants must be enrolled as full time students in a recognized (note ISASI recognized) education program, which includes courses in aircraft engineering and/or operations, aviation psychology, aviation safety and/or aircraft occurrence investigation, etc., with major or minor subjects that focus on aviation safety/investigation are eligible for the scholarship. A student who has received the annual ISASI Rudolf Kapustin Memorial Scholarship will not be eligible to apply for it again. Administration of the Fund: The President of ISASI will appoint a two person committee to be executors and administrators of the fund. The ISASI Treasurer will oversee all expenditures. The Scholarship Fund Committee will check that the education program is at a recognized school and applicable to the aims of the Society, assess the applications and determine the most suitable candidate. Donors and recipients will be advised if donations are made in honor of a particular individual. Annual Scholarship: Funded attendance at ISASI Annual Seminar An award of $2000 will be made to each student who wins the competitive writing requirement, meets the application requirements and will register for the ISASI annual seminar. The award will be used to cover costs for the seminar registration fees, travel, and lodging/meals expenses. Any expenses above and beyond the amount of the award will be borne by the recipient. ISASI will assist with coordination and control the expenditure of funds. In addition, the following are offered to the winner(s) of the scholarship. 1. A one year membership to ISASI 2. The Southern California Safety Institute (SCSI) offers tuition-free attendance to ANY regularly scheduled SCSI course to the winner of the ISASI Scholarship. This includes the two-week Aircraft Accident Investigator course or any other investigation courses. Travel to/from the course and accommodations are not included. More information at http://www.scsi-inc.com/ 3. The Transportation Safety Institute offers a tuition free course for the winner of the Scholarship. Travel to/from the course and accommodations are not included. More information is available at http://www.tsi.dot.gov/ 4. The Cranfield University Safety and Accident Investigation Centre offers tuition-free attendance at its 5-day Accident Investigation course which runs as part of its Masters Degree program at the Cranfield campus, 50 miles north of London, UK. Travel to/from the course and accommodation are not included. Further information is available from www.csaic.net/ Application requirements: 1.A full time student who meets the Eligibility requirement stated above and has been enrolled for a duration of one year 2. The student is to submit a 1000 (+/- 10%) word paper in English addressing "the challenges for air safety investigators" 3. The paper is to be the students own work and must be countersigned by the student's tutor/academic supervisor as authentic, original work 4. The papers will be judged on their content, original thinking, logic and clarity of expression 5. The student must complete the application form with their paper by April 15, 2012 and submit it to ISASI by mail, fax, or email to isasi@erols.com. ISASI contact information - Ann Schull, International Office Manager 107 E. Holly Avenue, Suite #11 Sterling, VA 20164 703 430 9668 (Main) 703 430-4970 (FAX) Some advice to those applying: 1. Late submissions are not advisable 2. Handwritten applications are not advisable 3. Make sure to include your email address as indicated in 5/ above 4. For email submissions the essay should be in MS Word format; however, the application form may be in pdf, in order to facilitate scanning the completed and signed application. *********** Application Form 2012 INTERNATIONAL SOCIETY OF AIR SAFETY INVESTIGATORS The ISASI Rudolf Kapustin Memorial Scholarship (In memorial to all ISASI members who have died) Name: Date: Address: Course enrolled for: Year /Subjects Studied: Academic Institute: Address: Email: Telephone number: Student Signature:_____________________________________________________________ Tutor/Academic Supervisor title and signature:________________________________________ 1000 Word Paper ""the challenges for air safety investigators" NOTE: Students who wish to apply for the scholarship should visit www.isasi.org or send email to isasi@erols.com. The ISASI office telephone number is 1-703-430-9668. Curt Lewis, P.E., CSP, FRAeS, FISASI CURT LEWIS & ASSOCIATES, LLC