Is that right? Because it appears that the first step in the process is to determine the need for an evaluation based on the following....you may notice one or two items that might be applicable:

10-8-1-9 PROCEDURES.

A. Determine the Need for an Evaluation (see flowchart process step 10-8-1-9A). If you are the national, regional, or local AFS manager, then steps 10-8-1-9A through 10-8-1-9F apply to you. The following conditions may indicate the need to conduct an evaluation:

· Substantial change in certificate holder management;
· Substantial turnover in personnel or reduction in force (RIF);
· Labor dispute;
· Rapid expansion or growth;
· Merger, takeover, or change in ownership;
· Enforcement actions;
· Noncompliant attitude;
· Accidents/incidents/occurrences;
· Department of Defense (DOD) reviews;
· Department of Transportation (DOT)/Office of the Secretary of Transportation (OST) economic authority/insurance requirements;
· Change in fleet type;
· Substantial change in outsourcing;
· Financial distress;
· Substantial customer or employee complaints;
· Hotline complaints; and
· Certificate transfer (refer to part 119, § 119.63 regarding the status of operation/dormant certificates).