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Disposition of Comments to proposed DADE Guidance - Docket FAA-2011-1149 

Issue #1 - Testing Limitations. Proposed policy contained in FAA Order 8900.1, 

Volume 13, Chapter 3, Section 4, paragraph 13-223B, states that an examiner may not 

administer any portion of the Aircraft Dispatcher Practical Test to more than one 

applicant for an Aircraft Dispatcher Certificate at a time. The previous policy 

established in 2008, allowed Aircraft Dispatcher Practical Tests to be “staggered” for 

more than one applicant. Test “staggering” is defined as administering the oral portion 

of the Aircraft Dispatcher Practical Test one applicant while another applicant works on 

the manual flight plan. 

Sheffield School of Aeronautics, Aviation Dispatch Institute and numerous private and 

anonymous commenters, objected to the proposed limitation of testing a single applicant 

at a time. These commenters cited a reduction in the amount of tests an examiner could 

administer thus increasing the amount of time an applicant would have to wait to be 

administered a test. 

FAA Response: The FAA removed the ability to conduct simultaneous testing 

(staggering) of applicants because the provision conflicts with the previous and current 

editions of the Aircraft Dispatcher Practical Test Standards(PTS) (publication dates 

June, 2008 and May 2013 respectively). Both editions of the PTS state that there is no 

formal division between the knowledge (oral) and Skill portion of the Aircraft 

Dispatcher Practical Test. Further the single applicant testing policy for Aircraft 

Dispatcher Practical Tests is in line with the long standing FAA policy currently 

contained Order 8900.1, Volume 5, Chapter 1, Section 1, paragraph 5-7 (Testing 

Policies) which states only one applicant for an airman certificate or rating shall be 

administered an oral or a flight test at a time. The Aircraft Dispatcher PTS is similar the 

pilot PTS in that knowledge is typically tested through oral questioning. The skill 

portion of the Aircraft Dispatcher Practical Test is demonstrated through a series of 

critical calculations such as those required for aircraft performance, weight and balance, 

and manual flight planning. 

The FAA has considered the numerous comments in favor of the simultaneous testing. 

However, taking into consideration the entire Aircraft Dispatcher Practical test being 

administered as a whole in accordance with the PTS, and the demonstration of skill 

through manual calculations as being comparative to a flight check, the FAA has 

determined that policy introduced in 2008 that allowed an examiner to “stagger” 

Aircraft Dispatcher Practical Tests, was inconsistent with the FAA’s long standing 

policies regarding single applicant testing. To correct this inconsistency the FAA has 

decided to uphold the proposed single applicant testing policy for DADEs. It should 

be noted that this policy is now reflected in FAA Order 8000.95, Designee Management 

Policy, and effective 4/11/2014. 

The FAA recognizes that there could be unique situations not addressed in national 
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policy, where an equivalent or greater level of safety could be provided. FAA Order 

8900.1 Volume 1, Chapter 1, Section 1, Paragraphs 1-3A and 1-5A generally allow 

FAA inspectors, supervisors, and managers to request a deviation from FAA policy 

from the appropriate Headquarters Policy Division, when warranted. If a DADE can 

show a valid need, an equivalent or greater level of testing, and a definitive means to 

prevent cheating, the DADE, may seek a deviation through the FAA managing 

specialist, from the single testing requirement. Requests for deviation must be directed 

to the Air Transportation Division, AFS-200 and the Regulatory Support Division, AFS600. Requests will be considered on a case by case basis and the FAA may require a 

demonstration of the DADE’s testing methods prior to considering any deviation 

request. 

 

Issue #2 - Combination of Knowledge and Skill portions of The Aircraft Dispatcher 

Practical Test. Proposed guidance contained in FAA Order 8900.1 Volume 13, 

Chapter 3, Section 4, paragraph 13-227 suggested that the knowledge and skill portion 

of the Aircraft Dispatcher Practical Test could be combined. 

Sheffield School of Aeronautics objected to this policy, stating that combination of the 

knowledge and skill portion of the Aircraft Dispatcher Practical Test diverged from the 

requirements of the Aircraft Dispatcher Practical Test Standard. Sheffield was also 

concerned that any interruption of the applicant while completing the manual flight plan 

was contrary to the principles of DRM. 

FAA Response: The Aircraft Dispatcher Practical Test Standards specifically state 

there is no formal division of the knowledge and skill portion of the Aircraft Dispatcher 

Practical Test. The policy allowing the knowledge and skill portion of the test to be 

combined is in line with the PTS. The intent of the policy is that an examiner could test 

an applicant’s knowledge based on the completed manual flight plan. In considering 

public comment, the FAA revised the Aircraft Dispatcher PTS in May, 2013. The 

revised PTS section related to an Examiner’s Responsibility, clarifies the FAA’s intent 

with respect to this issue. In addition, the FAA has updated the associated guidance in 

FAA Order 8900.1, Volume 13, Chapter 3, Section 4, paragraph 3-230 to coincide with 

the PTS. 

Issue #3 – Conflict of Interest - DADES may not be Affiliated with a Part 65 

Aircraft Dispatcher Certification course due to the Possibility of Conflict of 

Interest. Proposed guidance contained in Order 8900.1 Volume 13, Chapter 3, Section 

2, paragraph 3-176 prohibited a DADE from being affiliated with a 14 CFR part 65 

Aircraft Dispatcher Certification Course. The FAA felt this limitation was necessary due 

to the conflict of interest that is inherent when a regulated entity or an employee of such 

an entity, is also acting on behalf of the Administrator who is responsible for regulating 

the entity. This conflict-of-interest, could be compounded by the requirement under 

part 65, § 65.63(c)(1) for a course operator to maintain an 80 percent pass rate of its 

graduates, on the first testing attempt, as a condition for renewal of a course. The FAA 
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is concerned that a DADE who is an owner, operator or employee of an FAA-approved 

Aircraft Dispatcher Certification Course might not be objective when administering the 

Aircraft Dispatcher Practical test to an applicant who has graduated from that course. 

Several commenters, including, Academics of Flight, Aviation Dispatch Institute and 

other individuals representing themselves as being affiliated with Aircraft Dispatcher 

Certification Courses, supported this policy citing possible improvement to the system 

of checks and balances, an increase in safety and a level playing field for all part 65 

Aircraft Dispatcher Certification Course operators. 

Several individual commenters, including those representing themselves as being 

affiliated with Aircraft Dispatcher Certification Courses, and Sheffield School of 

Aeronautics, strongly opposed this policy citing lack of data and/or evidence to support 

the FAA’s concerns. Additionally, these commenters cited a lack of similar prohibition 

on an examiner’s affiliation with other airmen certification courses, such as 14 CFR Part 

141 Pilot Schools. 

FAA Response: The FAA agrees that there is currently no data and/or evidence to show 

that the level of instruction, evaluation and testing of an applicant is negatively impacted 

when a DADE is affiliated with an Aircraft Dispatcher Certification Course. The FAA 

has therefore removed the prohibition of a DADE’s affiliation with an Aircraft 

Dispatcher Certification Course. Instead, the FAA has adjusted surveillance 

requirements and included a recommendation to conduct additional surveillance of a 

DADE who tests graduates of a course with which the DADE is affiliated. The 

additional surveillance will help the FAA to collect data and verify that a DADE’s 

affiliation with an Aircraft Dispatcher Certification Course does not affect the DADE’s 

objectivity or overall performance as a representative of the Administrator. The adjusted 

requirements are contained in FAA Order 8900.1, Volume 13, Chapter 3, Section 1. If at 

any time data reveals that a DADE’s affiliation with an Aircraft Dispatcher Certification 

Course negatively affects the DADE’s objectivity and/or performance, the FAA will 

revisit this policy as necessary. The relaxation of the affiliation limitation will be 

applicable to all DADEs and all Aircraft Dispatcher Certification Course operators. This 

will present the level playing field desired by commenter’s who were in favor of 

proposed prohibition. Additional guidance related to DADE’s who are affiliated with 

Aircraft Dispatcher Certification Courses, is contained in 8900.1 Volume 3, Chapter 

63, section 3; Volume 13, Chapter 3, Section 2, and Advisory Circular 65-XX.( The 

actual number of the Advisory Circular will be effective upon publication). 

It’s important to note that need and ability to manage a DADE takes precedence. The 

FAA will not designate additional DADEs for the purpose of school affiliation. The 

FAA designates examiners based on the needs of the public and the FAA, and on the 

FAA’s overall ability to manage its designees. 

Issue #4 - FAA Approval of Credit Allowed by 65.61(d). Proposed policy in Order 

8900.1 Volume 5, Chapter 10, Section 10, paragraph 5-1366 E(1), required a course 

operator’s criteria for determining the amount of student credit hours for previous 

experience or training in accordance with 65.61(d), to be approved by the FAA as part 
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of an Aircraft Dispatcher Certification Course outline. 

Sheffield School of Aeronautics stated that they considered this to be a worthwhile 

attempt to reduce the “abuse” of §65.61(d); however, they objected to this policy 

overall, stating that it was outside of the regulatory requirements of §65.61(d). 

FAA Response: The FAA believes that this requirement is in line with §65.61(b), 

which requires an applicant for approval of an aircraft dispatcher certification course to 

submit an outline that describes the major topics and subtopics to be covered and the 

number of hours proposed for each. The FAA will therefore retain this policy. This 

policy will now be reflected in 8900.1, Volume 3, Chapter 63, section 3 and Advisory 

Circular 65-XX. 

Issue #5 - Graduation Certificate Requirements. The proposed policy in Order 

8900.1, Volume 5, Chapter 10, Section 10, paragraph 5-1355 E(1) required certain 

items to be included in, or attached to a graduation certificate. 

Sheffield School of Aeronautics opposed this policy stating that nothing in Part 65 gives 

the FAA the authority to dictate the contents of the course graduation certificate. 

Sheffield also stated that they believed the policy related to graduation certificates was 

misplaced in this particular chapter of 8900.1. 

FAA Response#1: Section 65.70(b) requires that each student who successfully 

completes an FAA approved Aircraft Dispatcher Certification course be given a Written 

Statement of Graduation. We believe it is well within our authority to establish policy 

on the minimum contents of a document that is required by regulation. The FAA will 

therefore retain this policy. The policy will now be reflected in 8900.1 Volume 3, 

Chapter 63, section 3, Volume 5 Chapter 5, Section 10, paragraph 5-1367 and Advisory 

Circular 65-XX. 

FAA Response #2: The FAA agrees in part, that the proposed policy was misplaced in 

this particular section of Order 8900.1. Therefore, the FAA has established new policy 

that is directly applicable to Aircraft Dispatcher Certification Courses. The new policy is 

contained in 8900.1, Volume 3, Chapter 63, sections 1-3. In addition, the FAA has 

developed AC 65-XX, which applies directly to Aircraft Dispatcher Certification Course 

Operators. 

Issue #6 –DADE and Applicant Feedback on School performance and Lack of 

Adequate FAA Oversight. Proposed policy contained in Order 8900.1, Volume 13, 

Chapter 3, Section 3 requires an FAA Managing Specialist to provide training to a 

DADE on methods of providing feedback to the FAA regarding areas of weakness 

demonstrated by applicants for an Aircraft Dispatcher Certificate. 

Sheffield School of Aeronautics generally opposes this policy, stating that requiring a 

DADE to identify possible deficiencies in a part 65 Aircraft Dispatcher Certification 

Course is outside of the scope of 14 CFR part 183, specifically §183.25(f), which 
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generally allows a DADE to administer the Aircraft Dispatcher Practical Test, and 

administer Temporary Aircraft Dispatcher Certificates, at the discretion of the FAA. 

Sheffield believes that the evaluation and oversight of part 14 CFR 65 Aircraft 

Dispatcher Certification Courses rests with the FAA and not with a DADE. 

FAA Response – #1: The FAA agrees with Sheffield School of Aeronautics that the 

responsibility for oversight of a 14 CFR part 65 Aircraft Dispatcher Certification Course 

rests with the FAA. However, we also believe that the education of DADEs regarding 

feedback to the FAA is of value, particularly if graduates of the same Aircraft 

Dispatcher Certification Course demonstrate weakness in similar areas. Such a 

demonstration could be an indicator to the FAA that a particular 14 CFR Part 65 

Aircraft Dispatcher Certification Course may require additional FAA surveillance. 

Additional surveillance could also help determine whether or not the areas of weakness 

demonstrated by multiple graduates of the same course is a due to deficiencies contained 

in the course itself, or simply the byproduct of students sharing each other’s bad habits 

resulting in the same negative outcome. This policy is now clarified in 8900.1, Volume 

13, Chapter 3, section 3. 

FAA Response #2: Section 183.17 states that each representative designated under part 

183 “shall make such reports as prescribed by the Administrator.” The FAA believes 

that providing feedback is equivalent to making a report and therefore meets the intent 

of §183.17.

Issue #6- Limitation on Examining Applicants to Whom the Examiner Provided 

Instruction. Proposed guidance contained in Order 8900.1 Volume 13, Chapter 3, 

Section 2, paragraph 13-176(E) stated that a DADE may not, at any time, administer the 

Aircraft Dispatcher Practical Test to any applicant to which the DADE has provided 

instruction in any of the subjects (also referred to areas and topics) contained in part 65, 

appendix A. 

Sheffield School of Aeronautics commented that they understand a need for objective 

evaluation of applicants for any airman certificate, but that this particular limitation 

exceeds what is currently in effect in Order 8900.1, Volume 13, Chapter 3, Section 1, 

without explanation. They also noted in their comments that, Order 8900.2, Chapter 7, 

Section 2, paragraph 8 guidance allows for some instruction by Designated Pilot 

Examiners (DPE), provided the applicant receives a certain amount of flight instruction 

by another instructor. Sheffield School of Aeronautics suggested an alternative to the 

prohibition against a DADE testing an applicant to whom he or she has provided 

instruction, would be to prohibit DADEs from testing applicants they have “signed off” 

(recommended) for the Aircraft Dispatcher Practical Test. 

FAA Response: The FAA has removed the prohibition from DADEs being affiliated 

with part 65 Aircraft Dispatcher Certifications Courses altogether, based on public 

comment. We therefore feel that in order to ensure objective evaluation of students, a 

limitation preventing DADEs from testing students to whom they have provided 
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instruction, enhances safety and generally helps prevent the practice of “training the 

test”. A worst case scenario for the FAA could occur if an Aircraft Dispatcher 

Certification Course is operated by a single individual who provides all of the 

instruction and then administers the Aircraft Dispatcher Practical Test to the applicant. 

While the FAA recognizes that no “identical” prohibition exists for other types of 

examiners, there are distinctly similar prohibitions. For example, Order 8900.1 Volume 

13, Chapter 1 section 1, states in pertinent part, that a designated examiner may not 

“normally” conduct an evaluation of any applicant that the designated examiner has 

instructed in preparation for the certificate or rating sought by the applicant. 

The FAA does not believe that simply not testing an applicant the DADE has 

recommended for the practical test would provide the same level of safety for initial 

certification of an aircraft dispatcher, as additional flight instruction would for an 

applicant for a pilot certificate or rating. Nor would it eliminate the worst case scenario 

presented in this response. We believe it is essential that applicants for an Aircraft 

Dispatcher Certificate receive a thorough and objective evaluation from an examiner 

other than one who has provided instruction to the applicant. 

The initial certification of aircraft dispatchers cannot be directly compared to initial 

certification of private pilots or Air Transport Pilots (ATP) undergoing Initial Operating 

Experience (IOE). A private pilot would not be expected to exercise operational control 

at an airline, and an ATP would have received many more hours of instruction, actual 

flying and additional certification prior to undergoing IOE at an airline. Once an aircraft 

dispatcher completes initial certification, the overall training and qualification 

requirements to dispatch at an airline are nowhere near what are required for pilots to fly 

at an airline. Additionally, there no regulatory requirements for an aircraft dispatcher to 

undergo IOE. Only a newly certificated aircraft dispatcher would be in a position to be 

hired by an airline, receive only 70-80 hours of required ground instruction, (depending 

on aircraft group), and then be expected to exercise operational control jointly with the 

pilot-in-command of each flight the aircraft dispatcher is responsible for. This is 

significant because newly certificated aircraft dispatchers are often hired by regional air 

carriers and are often responsible for exercising operational control over more than 50 

flights per shift. 

By the time an aircraft dispatcher is expected to jointly exercise operational control with 

a pilot-in-command, it’s not unusual that total amount of training the dispatcher will 

have received will be 280 hours. It is therefore critical that candidates for an Aircraft 

Dispatcher Certificate be subject to thorough, impartial and objective evaluation by an 

examiner who has not participated in the training required to prepare the candidate for 

the Aircraft Dispatcher Practical Test. 

It should be noted that the policy prohibiting a DADE from testing an applicant to 

whom the DADE has provided instruction, is currently reflected in FAA Order 8000.95, 

Designee Management Policy, effective 4/11/2014. 
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Issue #8 –-Mandatory Failure/Minimum Passing Score. Proposed guidance 

contained in Order 8900.1 Volume 13, Chapter 3, section 4, states that the entire test 

will be considered a failure if an applicant for an Aircraft Dispatcher Certificate 

provides unsatisfactory responses in certain specific areas of the skill phase of the test. 

Sheffield School of Aeronautics generally agreed that the areas cited in the guidance 

were significant, but that requiring mandatory failure could lead to some applicants 

being failed based on slight errors in these areas, such as minor mathematical errors. 

Sheffield was further concerned that the automatic failure requirement stated in the 

proposed guidance was outside of the scope of the Aircraft Dispatcher Practical Test 

Standards (PTS). 

FAA Response: The FAA agrees the that edition of the Aircraft Dispatcher PTS that 

was in effect at the time the draft guidance was initially proposed, did not contain 

mandatory failure items or pass/fail score recommendations. The FAA therefore updated 

the Aircraft Dispatcher PTS to be more in line with other PTS such as those for Private, 

Commercial and Airline Transport Pilots, which all contain “Typical areas of 

Unsatisfactory Performance and Grounds for Disqualification” The updated Aircraft 

Dispatcher PTS, was published in May of 2013. It includes “Typical areas of 

Unsatisfactory Performance and Grounds for Disqualification”, along with a minimum 

passing score. In accordance with 14 CFR§ 65.17, the minimum passing score for the 

Aircraft Dispatcher Practical Test is 70 percent. This is now reflected in the current 

edition of the PTS and in Order 8900.1, Volume 13, Chapter 3, Section 4. 

Issue #9 – Practical Test Time Limitations. Proposed guidance contained in Order 

8900.1, Volume 13, chapter 3, Section 4, paragraph 13-223(E) established time limits 

for the Aircraft Dispatcher Practical test. The limits are based on an average of 2 hours 

spent completing the knowledge portion of the test; 2 hours completing the skill portion 

of the test, and up to 2 hours completing application paper work, for a total test time of 

no more than 6 hours. The limits were set based on numerous reports from FAA 

inspectors and applicants for Aircraft Dispatcher Certificates indicating extremes in 

testing times. The lower extreme being 1.5 hours for the completion of the entire test, 

and the upper extreme being close to 12 hours for the completion of a single test. 

Sheffield School of Aeronautics, along with other individual commenters, generally 

objected to the time limit contained in the proposed policy. These commenters stated 

that the policy was confusing and limited the ability of the examiner to evaluate the 

applicant as the examiner see fit. 

FAA Response: The FAA disagrees. We feel that setting a general guideline on testing 

time is prudent; will help standardize the conduct of the test and reduce the cases of 

extremes in testing times as described above. The FAA has therefore updated the 

Aircraft Dispatcher PTS, and Order 8900.1, Volume 13, Chapter 3, section 4, to state the 

following: 
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“An examiner should allot, on average, no less than 4 hours and no more than 6 hours to 

conduct a test.” 

Issue #10 –FAA Guidelines for Staffing and Assignment of Aviation Safety 

Inspectors. The FAA received comments from Sheffield School of Aeronautics 

regarding the policies related to staffing of FAA Field Offices and the Assignment of 

Aviation Inspector Resources. 

FAA Response: The FAA’s staffing needs and inspector assignments are entirely our 

responsibility. We believe the staffing requirements set forth in this policy are in FAA’s 

and the public’s interest.