Quoting 98redrang correction : the accident rate is listed as '1.07', and the ETS doc does have a name on it. I have posted the docs to this site: http://s191.photobucket.com/albums/z...t%20documents/ according to his declaration, that's a pure "pace" and if he duplicates that at the TDN, you're going to get nowhere arguing a requirement for the survey or any details therein! Good luck!