t7 b2 morse- mike fdr- (faa national security coordinator) entire contents- mfr and 3 sets...

8/14/2019 T7 B2 Morse- Mike Fdr- (FAA National Security Coordinator) Entire Contents- MFR and 3 Sets Handwritten Notes-

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MEMORANDUM FOR THE RECORD

Event: Interview with Mike Morse, FAA National Security Coordi nation Staffer

Type of Event: Interview

Date: September 15. 2003

Special Access Issues: None

Prepared by: LisaSullivan

Team Number; 7

Location: FAA Headquarters, Washington, DC

Participants -Non- Commission: Mike Morse, FAA National Security CoordinationStaffer; and Susan Caron, FAA Office of the Chief Counsel

Participants- Commission: John R aidt ,Bill Johnslonc, and Lisa Sullivan

(Unc) Prior to coming to the FAA in 1986, Morse was in the U.S. Air Force Oifice ofSpecial Investigations, Hedealt with counterintelligencc an d couniertcrrorism from 1966to 1986. He moved lo the FAA where he assisted in (he establishment of an intelligencedivision for civil aviat ion security. The impetus for the mtcIligcjKcJjvmott^gs the ..-- ' ' ' 9/11TWA 800 crash. Ik named Richard Clarke, Oliver North, and^^^^^^^] a ' 5 mree Working-levelmembers of the Administration who were instrumental in establishing an intelligence Employeedivision for FAA because of their perception that FAA needed help in its overseas

intelligence. Initially, FAA's connection to the intelligence community was an onlinedata system, Flieschboard (SP'?)> hosted by the National Security Agency. A secureintelligencefacility (SClF) was buil t at FAA Headquarters to accommodate the division.Between 1986 an d 1994, Morse served as Deputy Director and then Acting Director ofCivil Aviation Security Intelligence.

(Unc) Morse was made Deputy Director of Aviation Security Operations in 1994. Tieheld a variety o f posts within security operations for FAA over the next 1 years. He wasSpecial Assistant to the Director of Aviation Security Operations from 1999 through2001 Al first, this was Bruce Butterworth, but by 2001 (including 9/1 1), the Directorwas Lee Longmire.

(Unc) As of the end of October 2001 Morse was made responsible for setting up anol'fice {Litigation Support Staff) within FAA to coordinate and expedite F A A responsesto Congressional and Executive inquiries. He reported that FAA fielded 20-30 calls perda y from Hill smflers and members alike. The Administrationwanted answers as well.There were 7-8 congressional hearings in a 3-4 week period. His role helped to decreasethe impact of the response process on regular FAA operations as much J L Spossible. As

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th e name of Morse's ne w office suggests, the FAA saw thepotential fo r major litigationas a result of 9/11. Mo rse and his staff acted as a cen tral reposito ry for allessential an drelevant records related to Ihe attacks. Issuepapers, records, inc ludin g all of the ema iltraffic, were saved.All of these materials have been sentto TSA. Morse has mostrecently moved intothe lead role on the NationalSecurity CoordinationStaff within the

FAA . He was instrumentalin Ihe set-up an d design of this office. The staff is made upof himsel f and two intelligence officers. National Security CoordinalionStaff is the entrypoint for al l outside requeststo th e FAA from the intel l igence communityon projects,data, and people that might be needed to c ondu ct clandestine projects at home andabroad.

(Une) On the split between FAA and TSA, Morse ind icated that he wasdirectly involvedin th e development of the Memorandumof Understandingof February 28, 2003 whichprovided fo r transfer of functions an d personnel to TSA. Morse further stated that he wasthe "keeper' of the MOU for FAA, In order to mai ntain a singlesource for aviationintelligence. Annex 5 of the MOU, TSA agreed to provide FAAwith intelligenceinformation. Wi th respeelto security, FAA isstill responsiblefo r securityof its ownfacilities (including the Air Traffic Control System) and forproviding FAA support fo rclandestine government operations (especial lymilitary and intelligence).

(CS) Moise depicted the FAA before 9/11 as strictlya regulatory agency.Tnthatcapacity, the organization often "got its nose bloodied" in attempting to exert influenceover the industrystakeholders, and to do more than thesystem would sustain. Civi lAviation Security officialswanted to do more, but absence of public or Congressionalsupport, the security system did "as good a job as it could." This was the greatestweakness of the system,accordingto Morse. A n examplehe used to describe this pointwas an attempt by the FAA toinstitute background checksfor those who w ere givenunescorted access to secure areas in airports inthe late-198Qs. FAA proposals received

severe pushback from Congressand the indu stry stakeholders. The mostunpopular onessuch as this wouldoften result in legislation (appropriationsriders) that would restrictFA A ability to enforc e suc h unpopula r proposals, Morse saidKarl Shruni (SP?) fromFAA policy would rememberthe specific details of thebackground investigation issue.

(CS) When askedhow itwas that the FAA arrived at the conclusionto proposebackground checks foral l employeeswith unescortedaccess to the airports, Morse saidthat the movementfol lowed the crash offlight TW A 800 and came at at ime when "thedomestic threat levelhad significantlyincreased." In addition to TWA 800, he referredto the World Trade Center attack and the Bojinka plot as incidents that combined tofinally produc eCongressional concern that enabledthe F A A to try to raise the securitybaseline. Morse indicated that some significantimprovementswere made atIbis time.

(CS) Morse referredto the "tombstone mentali ty"of the system as a whole. Theindustry stakeholdersbelieved the justif icationsthe FAA provided lor tighter securitymeasures were not valid.Airlineswanted to see more specificindicationsof threats.Morse claimedthe FAA did a lot to communicatethe threat to the industry. Factors thatinhibitedthis communicationwere th e classified nature of the intelligencereporting; the

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need fo r the intelligence community to conceal the intelligence methods an d sources; an dthe difficulty of sanitizing the intelligence lor the industryin a meaningful way. Inaddition,he believed thaithe airline security directors werenot highly placed within thecompanies, and werem airily retired law enforcementofficials with limited experiencewith terrorism an d with limited access to current intelligence. Morse cited Larry

Wans le y at American as anexception, who w as well-connected withinh is company,

the intelligence for the industry stakeholders wasdone by the ACl andthe intelligence provider. Morse stressed that this was a difficult process.

(CS) Overall, Morse reported th atit was slow an d difficult to get the security hasclineraised. The Baseline W ork ing Group met for the firstt ime on the day TW A 800exploded , and som e of itsefforts were relatively quicklydiverted into the work of thesubsequentGore Commission,

(CS) Morse considered the FAA intelligencedivision to be a strength of the system inthat its function was to act as an advocate for the aviation community's intelligence needswithin the intelligence community. The intelligence reportingdid not, however, lenditself to lone-term strategic planning for ihe system, Wh ere the intelligence d ivision waseffective was in disseminating imm ed iate threatsin real-time to the right parties. liereported thatth e ACThad a direct lineto the FAA Administrator, Actiontaken inresponse to threat reportshad a short turn-aroundtime. ACI had a " fair amount" ofautonomy withrespect to the issuance of Security Directivesan d Information Circulars,

(CS) In the late 1980s and the early 1990s, (post-PanAm 103 crash), Morse said the FAAAdministratorand the Secretary of Transportation were"hungry" for in telligence onthreats to civil aviation. Wha t made things difficult fo r the government was that the FAAhad merely a regulatory role within the system. Given the cumbersomerulemaking

process, Security Directives and to a lesser extent Intelligence C irculars became chosenmethods of tightening security measuresan d increasing threat awarenessto the airlines,airports, and all other significant parties. As these instruments(particularly SecurityDirectives) became more common,they became less "popular" with industry, and this inturn led to a slowing dow n of the process of issuing them. In this time period (late1980s-carly 1990s), Morse indicated thatgovernment leadershipsometimes becamefrustrated with the aviation securityprocess because of thelack of threat specificity an dthe accompanyingdifficultyof "selling"the remediesto industry,to Congressand to thepublic .

(CS) Security D i r e c t i v e swere e ff ec t ivelo a c e r t a i n ex ten t ,b u t they were only e n a c t e do na t empora rybasis. Stakeho lde r ssaw th e issuance of directives as ihe federal author i t iesin te r fe r ing , ra ther thanadv i s ing ,on airline a n d a i rpor topera t ions .Inev i t ab ly,this strainedthe r e l a t i onsh ip .From th e s t akeho lde r s 'perspective,th e government would better servethe industryby providing re levanti n fo rma t ionrather than l o o s e l yqua l i f i ed SecurityD i r e c t i v e sthat the industry m ustg r u d g i n g l ya d h e r eto . lest t hey incur penalties,



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(CS) Morse characterizedihe regulatory process as a weakness in the aviation securitysystem. He went on to say thai financially, the airlines were in"dire straits," Thiscontributed to their resista nce to security regulation simposed by Ihe FAA . In addition tothe rnlcmaking process, Morseidentified deficiencies in the num be r of inspectors and thelack of a streamlined enforcement mechanismas sources of the FAA's regulatoryweaknesses. Withou t the enforcementauthority it needed to ensure securitydirectiveswere fol lowed, there was little the FAA could do tosignificantly improve civil aviationsecurity, despile good intelligence the FAA w as receivingthat it was imprudent not to doso.

(CS) Morse felt that fines and other enforcement mechanism swere not an effective toolin producing better performance. The airlines an d airports saw penalties as a "cost ofdoing business," and Morse quoted one airline security director as commenting that. "Weplane for these violations like bad weather." Frequent reductions in thefines frustratedthe security inspectors, loweringtheir morale.

On the topic of checkpoint screening, Morse dwelt on the human factor inseparablefrom this layer of the security system at the airport, W ithscreener turnover as high as /9/1 1400 percent in some places, therewas no room for job-performance improvement. Morse/ Classif iedindicated that one factor contributing tottehightumoverratejs^^ / I nformation

higher performancelevels from the scrcencrs.

When asked what he thought th e mission of civil aviation securitywas before9/11/01. Morse said it was "to keep bombs off of planes... Before Pan Am 103. all wecould talk aboutwas hijackings." After Pa n Am 103, FAA Security was concerned mostabout the possibility of a sophisticated explosivedevice getting on a comm ercialflight.

H e candidly admitted that screeningat the checkpoint did not do agood enough job toprevent it, observing thai"screening is inherently tough." The deploymentof EDSmachines marked the FAA'sbest effort to address the problem that itsaw as the biggest,most probable threat to theindustry.

(CS) Neither the FAA nor ihe industry was prepared forthe type of attack the countryfaced on 9/11/01. None of the security measuresin place could have prevented it .

(CS) Morse said that before9/1 1/01 , it was not 1:AA"s role to actively provide protectionfor ihe aviation industry. E xceptions ,where a direct federal security role was inplace,included putting K.-9 teams at airports, maintainingthe small Federal Air Marshalprogram, an d conducting research and development.

(CS) Compliancewith FAA regulationsan d procedures was what FAA was looking forfrom the airports. Essentially, this is what the Special Assessment teams covertly testedfor at airports,



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(CS) Morse was asked to discuss th e "Common Strategy," the doctrine and trainingmaterials developedby the FA A7 in consultation with Ihe FBI and ATA, and provided toth e industry on how to deal with hijacking s. The strategy, which he indicated was "easilymisunderstood," was many yearsold, dating back to around 1980, and was also thesubject of an FAA/H3I MOU \vhich had last been updated in 1997, Morse said the pointof th e strategy, which was incorporated into the t rainin gvideo shown to pilots and flightcrews during training, was to "optimize actions taken by a crew to resolve hijackingspeacefully." It was geared toward a systematic delay through appeasement of thehijackers. Appeasement was employed to prevent th e hijackers from doing any thingrash. Morse said that over time, history had shown that the longer a hijacking persisted,th e more likely it was to have a peaceful resolution. One reason forthis might be that thehostages had time to develop relationships with th e hijackers,

(CS) Th e Common Strategy operated on the assumptionthat hijackers issue demands,most often fo r asylum or the release of prisoners fromjail, Morse admitted th e scenariowhich played out on 9/1 1 /Ol was not imagined when designing th e strategy; they thought

that '"suicide wasn't th e game plan1" of hijackers.

(CS) Prior to the 1996 Atlanta Olympics, the FAA tried to update th e ''CommonStrategy" video used by the airlines fo r training its Might crews because of changes inaircraft and communications which had rendered the old version obsolete. Overtheyears, some of the carriers, such as Continental and Am erican, had developed their ow nupdated training materials to supplement the antiquated FAA video. Ihe training itselfhad always been (he responsibilityof the airlines. Morse would sit in o n trainin g sessionsfrom time to time. Morse indicated that the training materialsdeveloped by AmericanAirlines ''mocked" the Common Strategy, apparentlyin an effort to use humor to get th epoint across. Com mission staffhas not viewed th e American Airl ines training materials,

A s part of its efforts to update th e Com mon Strategy, FA A gave th e training film tothe FBI to review (1996-1997) because the content of the video was based on aMemorandum ofUnderstandingbetween the FAA and FBI on delegation ofresponsibilities in the event of a domestic hijacking. The Bu reau reported back that it had"lost track" of the Com mon Strategy principles, Morse saidthat th e FB I had not beenkeeping track on incidents of hijackings abroad or the changes in technology that couldbe used in or would be relevant in a hijack situation.

rMorse reported thatat that time, the FAA and the FBI "renegotiated" theMemorandum of Understanding that had established th eCommon Strategy. Hie FBIcame back and said that th e substantive contentof the video was no t, in fact, irrelevant; it

was pretty good. However, it agreed th e tape could use updating for the benefit ofth eviewers. The idea of suicide hijackers never enteredtheir discussions. Looking back,Morse realizes now that intheir discussions, key factors weren't considered such as thecommunications improvementsover th e years (air phones, cell phones, ACATCSmessages, etc). It goes without saying that on 9/11/01, these communicationtools wereinstrumental to our understandingof what happened that day.

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(CS) Around 1999, some of the airlines,particularly US Air's Security D irector LauraGimlet, were also concerned thatthe AA training materials weresubstantivclyirrelevantand used obsolete equipment. Since many of the airlines, includingUS Air, were on theverge ofbankruptcy, aneflbn w as made on the part of the airlines and FAA to worktogether lo finance a new video .

In late 1999 tir early 2000, the topic of updating the training materials for theCommon Strategywas raised at a meeting at ATA Morse attended with the airlinesecurity directors. The FAA needed the air carriers to invest in the project. Morsereported, "It did not go well;" no one wanted lo help. For instance,no airline w anted toIcian a plane to the project forfilming, an d there was little enthusiasm from ATA, Inspile of this reaction, FAA proceeded w ith plansto update the Strategy, primarily throughplanning on use of current planeoutfitted withcurrent communications devices(including ACARS an d cell phones). In response to a question, Morse indicated that atthis time (2000 an d early 2001) he was '"nol so sure" the basic doctrine w as still sound,

In 2000 and 2001, Murse held a numb er ofmeetings on updating the Com monStrategy w ith groups suchas military counter-terrorism forces an d "U.S. governmentspecialists" on how to "absolve anaircraft'' in the event of hijacking: several w ithFBI;the State Department; and withrepresentatives from the airline carriers. lie indicated thattheir existed a "disconnect" between the military and the FBI ontactics in the event of ahijacking, but thehijacking model w as the same (i,e,non-suicide).

(ii) In May 2001 , a meeting was held in Quantico to bring all interested partiestogetherto discuss updating the Common Strategy, It included three airline captains withsecurity-clearances, ATC representatives, other FAA representatives, but not NORAD. Thesuicide h ijacking modelwas not formally discussed, but discussions did take place on theimperativeof keeping hijacked planes on the ground, and they did seek to developtechniques lor th e crew to disable aircraft to achieve this goal.

(CS) Morse reported that ATA continued to "drag its feet" on revisingthe trainingmaterials.

(CS) In the summer of 2001, the joint project to updatethe Comm ion Strategy wasunderway an d they began filming the new training v ideo, A highjack exercisew asconducted in collaboration with the Miami 1'Bl Field Office, Miami Dadc County PoliceDepartment,the S WAT team, and Varig Airlines, utilizing a 767. The underlyingdoctrine w as still und er development atthis time, and was not finalizedbefore 9/1 1/01,The video and all of thematerials have b een turned overto TSA.

When asked how he assessed the possibilityof a suicide hijack m ission , Morse saidthat in the back of his mind, he was aware of the possibility of the event (based onincidents in th e 1970s an d 1980s), but he stressed that he never saw any specificintelligence on a suicide hijacking plot. Morse admitted thathe feared hijack ing couldbecome a popular tactic with terrorists again. W hen they lookedat the AirFrancehijacking, authorities suspected an d feared that explosives may have been used in that



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attack. Other possible terrorist tact icscommercia lflight., arehard to prevent R)day^nar ad


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started in to 1 ;AA headquarters. It took him approximatelyone hour to get there by car.Along the way, he heard al of therumors an d false alarms (he mentioned the supposedear bomb al the S tateDepartmentwhich waswidely reported that day). By 10:00 a.m.,he was at headqua rters and w ent to the Com mandCenter, where he slayed fo r the next 24hours. The C om ma nd Center was run by LeeLongmire that day. Initially, PeterFalconemay have been in charge of the Center whe n M orsearrived, Mo rse spent the better partof the day acting as a"dispatcher" uf sorts for the primary ne t.

(CS) Longmire. Falcone,an d Mouse rotated in and outof positionson the dais, facing thestaff members answering calls. A "SCtF" adjacent to the Command Center was wheresecure video and teleconference com mu nications tookplace that day, between nationalleadership, FA A , and the military, Fran Lozito, a FAA representative to one of the aircarriers, manned phones from the C omm and Centerthai day; as did Jan etRiffe, why wason (among othercalls) the primary-an d tactical nets that day .RiiTe was the PrimarySecurity Investigator for Americanal the time.

(CS)The primary communications net w asunclassified and

wasused by air carriers andair traffic controllers involved in theincident, "lie tactical net was used fordiscussions

ol ' deployingassets. Intelligencewas another comm unications provider in the sensethatit linked peoplethrough the internet,

(CS) Because the crisisunfolded and ended relatively quickly, the Command Center'sftmctum quickly changed ki consequence management.They were worried aboutdeploying resources. Questions they needed answeredpertained to what kindof cargothe flights had onboard, whetheror not & n yla w enforcement people were on board, thephysical lay-outof th e planes, th e amount of gas in th e tanks,

(CS) Before 9/11, it was the Com mandCenter's job in a crisis to direct the activities oflaw enforcementin response to a hijack. It was organized that way because FA Aprovided the expertise to determine wha t could and could no t feasibly be done to thwart ahijacking underway. Law enforcement doesnol have such expertise. (Morse reportedthai the F131 was not neces sarily pleased bythis arrangement.) TheAssociateAdministratorfo r Civil Aviation Security(ACS -1) was responsible forcoordinatingFA A ' s response to a hijacking. On9/11/01, the lead FAA staff were LeeLongmire,w hoserved asDirector, an d Morse, who served asIn formation Manager.

___."'-""9/11(CS) Information gathered on9/11 at the Co mm and Centerwas. compiled" for the Working- levelAdministrator. Most of the informationwas kcjJilogcthfer'fn what is now room 312 A at E m p l o y e eK AA headquarters,dU^UUJedlKe effort to sort through th e information on thefour separate hijacks includ ingall of the m iscellaneousreports ( includingmany "redherrings," as Morse called them ). It was in this room that the'"butcher paper" was hungon the walls to keep track of information as it came in. Morse did not think the paperstill exists. If it did, he thought he wo uld know aboutil ,

(CS) Morse recalled thai Lee Lonemire questioned.Tanel Rifle (sometimebetween 10 and12) on her initial report of a gun being firedon one ol' Ihe hijacked American flights.



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based on reporting from American. Moist informed Commission staff that Riffe wastalking to all of the air carriers lhat day, rot just American. Morse recalled that Rifle, atthe time, indicated to Longrnire that, : 'I think 1 got" the information on the gun, indicatingsome uncertainty on her part. In subsequent discussion, American Airlines denied theywere the source of the information.

(CS) Morse said, "It is almost impossible to overstate the chaos of that day, v He addedthat Janet Riffc may have been in one of the most "stressful roles that day," No one hadever anticipated die number of attacks at the same time,

(CS) Morse was not sure whojv^aUroJiiejnforrnation from the butcher paper ( h _ c_ _ _ _ _ _ _thought il might have beanF ^^^^ T? ))


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9/1 1/01 After A c t i o nreport . lie found it impossible because people cou ldno t make t imeto cooperate.Willie Grippcrthan tasked M orse withthe assignmen t, atwhich pointMorse indicatedthat to accomplishthe mission would require that higher levelofficialsmade it a priority.

(CS) In separate areas ofinterest ,intensestudies wer e com pleted. A nd operationally,these led to a great deal of chan ge as a result of9/1 1/01. A n example ofthis is the DL-N(Domestic Events Network), whichwas formedthat day and hasremained operational24-hours a day ever s ince.

(CS) In Morse's opinion, rapid congr essional action quelled theFA A ' sin te rna lenthusiasmfo r iden tifying lessons-learned.Afte ra drastic o rganizationaloverhaullessons-learnedby an out-modedbureaucracyquicklybecamei r re levant .

(CS) Today,FA A ' ssecur i tyresponsibil i tyis limite dlo i ts ownassets and personne l. I tstill owns an doperatesth e nationalair space, w hich inMorse's words, "rem ainsvital to

public safely." Airporttowers ,TRACO Ns, andc i rcu i t sare also important assets thatareunderthe protect ion ofK A A , In th isregard,KA A has a role in supportingnationalsecurityactivit ies( includingmil i ta ry,la w enforcement ,an d in te l l igence) .In addition,airt raff iccontrol lershave an added sec ur i ty componentto theirjobs since 9/11/01inimplement ingcertain ISA funct ions ,such as restrictingthe use ofnational airspace.

orse feels that Osama Bin Ladens ne tworkof terrorists havea preoccupationwith aviation. The U.S. governme nt needsto be familiarand well traine don theworkingso T ihe aviationsystem in o r d e rto pro tec tit ; theset r a i n i n goperat ionsneedto goon outs ide ofihe publ ic view .

(CS) Morseleelsthat i t is better the c oun try has taken security responsibili t ies awayfromthe air carriersbecause theywere allunwil l ingto absorbthe overheadin su ch a highlycompet i tive m arketan d they were neververy good at doing se cur i ty,"They were happyto co ntract out scre en ing tothe lowest bidder" and did n't l ike allIhe data entryt ime an dcost o f workingt he C A P P Ssystem. Fur the rmore .Jong-termconsiderat ions seemedtonot have mu ch impacton the airl ines 'behaviorwith respectto secur i ty.

(CS) Morse does nol seethe evidence thatthe newly federated aviat ion secu r i ty systemis being tested andexaminedwith the same rigor that i t wasbefore 9/11/01. He saidcri t ical ly,!vTS A is beingexpected to inspect i tself;" implying that one agency cannotbeexpectedto per fo rmboth functions verywell . In the oldsystem, testing of the securitymeasure s was done bymultipleparties: the airlines the mse lves, the private security

companies involved, and FAAassessments.Airlines stillhave obligatio n to check thesecurityof theplane 's cabinbeforean d after takeoff,but lor themos tpart, they havebeen relieve d of secu rity responsibili t ies,

(CS) Morse describedthe old system as having been "junked" in the change ove r toth ecurrentsystem. He worr iesthat the newstructurehas minimalknowledgeof aviation,andlittle expertise in regulatoryaffairs. His ini t ial impressionis that TSA is doing aworse

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job in regulation and inspection and "in many respects, security is now worse." Hebelieves that ISA's expedited rulemakingauthority is a good thing, but that th e agencyneeds a belter management focus to fix problems with inspection, enforcement an dcompliance.

(CS) Morse recommended that a strong and independent testing mechanism beestablished lor the aviation security system. M e said TS A has hired talented andhardworkingpeople with law enforcement backgrounds and no aviation or regulatoryexpertise. The regulatory function of FAA did not survive th e transfer to TSA. Keypeople have left appointments since ISA's inception, Morse believes this is due to thetendency to underestimate th e complexity of the skill-set needed in leadership roles fo rregulation of aviation in this country. H e warned , "When all yo u have is a hammer.everything looks like a nail," Morse concluded that law enforcement is not a "cure-all"for the system of transportation security in this country.

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W I T H D R A WA L N O T I C E

RG: 148

Box: 00001 Folder: 0066 Document: 4

Series: 9/11 Commission, Team 7, box 1

Copies: 1 Pages: 1

ACCESS RESTRICTED

The item identified below has been withdrawn from this file:

Folder Title: Morse, Mike

Document Date:Document Type: Handwritten Notes

From:

To:

Subject' Clearances/Accesses needed to continue classified

discussion

In the review of this file this item was removed because access to it is

restricted. Restrictions on records in the National Archives are stated in

general and specific record group restriction statements which are availablefo r examination.

NND: 40474

Withdrawn: 11-10-2005 by:

RETRIEVAL #: 40474 00001 0066 4


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