December 10, 2011

Dear Sheffield Supporter,

Would you have preferred to receive a delayed, likely out-of-sync, or flawed FAA practical exam from an outside non-Sheffield examiner rather than with us? Or have been required to travel away from our office to do so? Especially, if you were part of a large class?

Designated Aircraft Dispatcher Examiner (DADE) qualifications and exam restrictions have been drafted since 2003, finalized in 2008, proven invalid by us in 2009-2011, yet rogue inspectors within AFS-200 (National HQ) have refused to comply with a directive from a higher office to answer all of our questions fully. Instead, they have pressed on, authoring a 2 nd draft to an already flawed first draft, without answering initial complaints filed by Sheffield School. There is now a comment period for this draft (links below), that was only initiated due to Sheffield’s reports on the matter. We’d appreciate your support. These inspectors are not only insulting Sheffield School, but the industry, and our graduates. Eric M. – SS.

“It’s just dispatch...”

FAA

The above statement has been attributed to some FAA inspectors in the past and it is shameful. Sheffield is asking for the URGENT help of its graduates and airline customers. You would not only help us, but the industry as well. You worked hard for your dispatcher certificate, harder than others. I don’t think you’d want Sheffield to become a test prep mill, but poorly authorized policy drafts are making it more difficult for us to operate efficiently.

Attached is a massive report/complaint that we filed nearly 2 years ago against factions of the FAA for gross misconduct ranging from the local levels through National HQ. It is bookmarked if you’d like to get an idea of what we’ve been through over the years. It involved the suspect authoring of FAA Order 8900.1, a policy document providing guidance of Designated Aircraft Dispatcher Examiners (DADEs), their qualifications, and testing protocol. As you know, Sheffield School have historically had so many students that we were authorized by the FAA to conduct up to 4 exams per day, simultaneous flight plan exercises in a controlled cheat-proof atmosphere, and even simultaneous oral exams – the FAA themselves conducted such exams in Miami years ago and suggested we use these methods to save time. We had up to 4-5 school-related examiners to conduct exams for occasionally up to 20, 30, and 40 students. Why? Because although the FAA is tasked with certification, they are/were either incapable or unable to handle this amount of workload. We also provided this service to our full-time
students for free.

Unfortunately, the FAA has never been able to comprehend the difference between a “course pass rate” and a “practical exam pass rate.” They point to an above 90% exam pass rate that we have as a conflict of interest, yet cannot comprehend that Sheffield has a course pass rate around 60-75%, sometimes as low as 48-50%. In other words, students flunk Sheffield School if they are unqualified for an FAA practical examination. If we were to pass everyone in our course and sign off their application, it would be perjury, which we refuse to do. Additionally, when a student resigns from the course, they are usually entitled to a pro rata refund. Why do I give $ back, if I have a conflict of interest? Eventually, due to this ignorance of the pass rates concept, and a vendetta-driven streak stemming from safety-related issues we presented to the FAA, the FAA began drafting new policy around 2003 without consulting the stakeholders, airlines, and public, which they are required to do. We were told about rumors circulating in recent years regarding my operation, which were/are completely false (such as ‘I only hand out questions and answers to practical exams and don’t really teach’, ‘we give complete practical exams (flight & oral) in under 60-90 minutes’, ‘we don’t give oral exams’, yet also ‘we apparently give 9 oral exams at a time’, and other rubbish). We suspect that these rumors were spread in order to harm Sheffield School by pushing for new policy aimed at handcuffing our operation as a Part 65 AD school. One FAA inspector (a Sheffield grad) actually told me these things. Somebody high up had their feelings hurt, perhaps got in trouble for allowing a diploma mill to operate, or approving an illegal international Aircraft Dispatcher school, (these all happened) etc.. and they no longer appreciated what Sheffield School brings to this industry.

To summarize, new examiner policies severely restrict how examiners conduct exams and who qualifies to be examiners. Basically, the attached report says it all and asks MANY questions that have never been answered to this day, although after about 2 years, the FAA Associate Administrator informed me that this became a hotline issue and I would get answers by May or June 2011, if no unforeseen delay occurred. The FAA did agree to a policy rewrite based on my complaints and have forthe 1st time offered this up for public comment. However, instead of answering numerous questions regarding the motivation of this policy and why the public, the stakeholders, and airlines were not contacted regarding possible effects of the policy, the FAA (AFS-200) decided to ignore AVS-1’s directive to answer our complaint and simply proceeded to amend 8900.1 CHG2 to the wording of their liking, which in certain passages is more restrictive than the original unanswered policy change. We plan to publicly comment; however, we would appreciate your support. We know that this conduct is not befitting in the true mission, goals, and objectives of the FAA per their own ethics and conduct policies.

FAA legal counsel has agreed with Sheffield School on many issues over the past 2+ years, enabling us to operate as usual. They had to concede that there is no legal and regulatory (FAR Part 183) basis for some of the restrictions my local FAA (they were replaced, by the way) initially attempted to place on us at Sheffield School per the edicts coming from National HQ. As you know, regulations trump policy. The regulation has not changed; only unanswered, still unaccountable policy has been

redrafted.

We requested an extension to the current 30-day comment period. The current policy change drafts were slipped into the Federal Register on Nov 8, 2011 without warning as usual; therefore, we all originally had until Dec. 8 to comment. Even my own local inspector was unaware of this even though he asked about the published date multiple times. He contacted me around 6:00am on Thanksgiving Day morning while I was on vacation, which I did appreciate – however, this is a poor example of FAA (National) screwing FAA (local) and the public. Now, due to my appeals and an email to my Congresswoman, we all have until February 8, 2012 to comment. (Please reply soon if you choose to support us. There are already false statements made by disgruntled examiners who OUR grads had to correct during their examination!!! Another commenter was threatened with a copyright infringement/misrepresentation lawsuit by us years, and yet another is anti-Sheffield because we caught him slandering Sheffield years ago and “corrected” him on the phone. And yet another poster WAS INVOLVED IN THE AUTHORING OF THE POLICY and worked for the FAA, yet failed to mention that fact! So we kindly request your help. We will be writing a mammoth report but strength is in numbers, and we desperately need your support to continue operating in an efficient manner.

We find it appalling that a group of inspectors decided to disobey superiors above and NOT answer our Hotline issue of over 160 questions, who then received repetitive requests (which were not directly answered) from local FAA inspectors regarding WHEN these new policy drafts would be made available in the Federal Register, and then placed them into the Register with an unusually short comment period and over a holiday period. These tactics counter the support required by the FAA to work harmoniously with airlines, stakeholders, and the public. Neither these actions nor other conduct which was painstakingly outlined in a large report sent to the Administrator and the DOT nearly two years ago, has ANY interest in the promotion of aviation safety.

Why should you comment? The FAA apparently trusts flight schools to allow school affiliates to provide exams, but not dispatcher schools. Therefore, regarding dispatcher exams if policy goes through, then airline employees unfamiliar with school materials will provide out of sync, delayed, and inefficient practical exams, thus delaying certification in many cases. We have already received written testimonials to this already occurring. One airline I recently trained REFUSED to use outside non-school affiliated DADEs, based on reports of their earlier problematic examinations of past graduates.

If Sheffield is to now rely on outsiders to follow a very flawed set of Practical Test Standards (you’re to be tested on ADF flying, and certain other obsolete or soon-to-be obsolete topics), then we will effectively become a producer of simple “Q & A” style instruction that we abhor. Ex. – instead of harping of alternate minimum navaid rules, which we are not required to instruct, we will spend wasted time outlining the specific differences and uses between the virtually obsolete LORAN, MLS, etc.. since the PTS requires this, yet does not stipulate HOW much detail must be covered. Are these the graduates you prefer to work with in the future – graduates who know plenty about MLS and NDB operation but nothing about basic airline policies like 1- and 2-navaid rules for alternate minimums? How about we stop instructing the reading of Jeppesen plates and only use the wretched government charts found on the ADX? Will an outside DADE use the school’s materials, as required, and follow the school’s assigned OPSPECS and Jepp plates, or will they force applicants to use government plates because they are cheaper? Most new-hire non-Sheffield examiners who we tried were unable to follow the FAA directive to use course OpSpecs and Jeppesen plates for Part 65 school applicants, earlier in 2011. All of our graduates had to correct their examiners, 3 examiners were so “off” that one did not have a flight plan key to grade the applicant’s flight plan, 2 wanted our applicants to use illegal airports – they were corrected. One forgot to providedthe weather for the flight plan which delayed the process by 15 minutes, and much more. Are these the people that you want to examine you? After all your hard work passing the class, to endure this nonsense is not in the public interest, airline interest, or anyone’s

interest!!

Fatigue & Long Days The new policies would produce exhausted examiners, who may be employed with an airline. Their examinations will be during off-days or holidays, and/or long weekends. This poses a fatigue issue with examiners returning to airlines because they are limited to one single exam at a time – can’t even stagger a flight plan with an oral with 2 applicants anymore to reduce a 10-12 hour exam days to 6-9 hours. We had to fight for “staggered exams” due to the number of graduates we have, and the potential number of consecutive 12-hour days.

Puppets AFS-200 (National Headquarters) wants to puppeteer all local inspectors – we pointed this out earlier that they were not following their own rules of policy construction and also ignored their own definitions of ‘should’ vs. ‘shall’, and they proceeded to apply further restrictions thus castrating the decision-making ability of local FAA inspectors – the inspectors who not only should be the most qualified to understand what is going on at a school, along with the effectiveness of local examiners, but actually show up to inspect. The policy authors likely have not ever stepped foot into a large reputable aircraft dispatcher school, and have never operated one.

Vendetta Sheffield School is being punished for being bold enough to ask the FAA pointed questions regarding illegal dispatcher schools, ETOPS changes, schools allegedly instructing and/or examining in Spanish, illegal international dispatcher schools, the absurdity of contract dispatching (see our lengthy public comment), etc.. So because some good ole buddies got their feelings hurt, I’m the bad guy.

A New Era If this policy goes through, it will signal the end of quality dispatcher training in the USA – guaranteed. Will it alter the operation of diploma mills and their examiners? No. But it will affect large schools having a large number of international graduates, and airline personnel waiting for an exam to return to their airline initial training. One recent airline had scheduling conflicts with their initial training due to a variety of reasons, one of which was the ever-uncertainty of an examiner showing up as planned and being competent enough to administer an exam consistent with school course procedures. Due to the ignorance of the FAA coupled with a vendetta-driven policy aimed at Sheffield School, the airlines will be suffering in the near future.

Sheffield prided itself on trying to prepare students to become not only graduates, and certified dispatchers, but to facilitate their advancement through YOUR (airline) training. If we now have to guess to what depth new examiner ‘John Doe’ wants to question the concept of HSI/RMI, flying ADF/NDBs, whether he understands navaid rules or applies mythical frequency rules, etc .. then we will no time to instruct at our previous level. We will become a glorified ADX standardized test prep course, which exists in many locations to this day – (one school actually guarantees course graduation!)

Instead of a 450+ box flight plan requiring answers and reasoning, we can give our students a simple flight log. (You see, the FAA doesn’t want simultaneous flight plans administered during the testing process, even though all flight plans are different and begin/end at the same time, and does not allow ANY cheating whatsoever. They also want exams kept to 4-6 hours for each individual, and limited to only 2 exams per day, thus increasing the number of days an applicant will need to wait for an exam.) They even placed a clause in the policy allowing an examiner up to 2 hours to conduct paperwork after an exam! Do you want to wait another 2 hours for either your paperwork or your exam to begin while the other applicant completes his paperwork?? It is ludicrous and inefficient. Also, outside examiners are not available on many days or are time-limited due to their work, resulting in delays returning home, to work, to airline initial training, etc.. Sheffield examiners have worked full weekends, holidays, and early AM/late PM hours. I once postponed a Friday surgery to conduct a weekend set of exams in pain – to accommodate the students already prepared for their exam with the need to leave town within a few days. What outside examiner, who has ZERO interest in our Sheffield students is going to do this? NONE!

No more comprehensive flight plans that were at one time lauded by many airlines, including Delta. We will reduce it all to a standard log with a basic scenario. Naturally, the button pushers that we produce will no longer be able to anticipate increased burn or VWS either. Since FAA in all their vastPart 65 school ownership/instruction experience (essentially ZERO), have decided that an ADX-type log is sufficient for flight plan checks, that is what we’ll have to teach. By the way, these ‘experts’ have placed numerous technical errors in the policy’s flight plan samples– anyone ever hear of “Max ZFW + fuel = Max ZFW”, or “Landing limit” + trip burn = “Landing limit”?? So this is guidance for new DADES? Only Sheffield has caught these errors over the past 2 years! We informed the FAA a while ago – not interested. The flawed policy remains to this day. Would you like to take an exam with bogus questions?

So instead of spending extra time on weather briefings, which has helped one major airline avert a disaster in LIT one poor weather evening (Sheffield grad), we will instead focus more heavily on HSI/RMI interpretation problems and the inner workings of Doppler radar, differences between IRS/INS, omega, and obsolete Advisory Circulars still published in the Practical Test Standards.

Below are the links. You may be able to remain anonymous, but it doesn’t matter – it is illegal for the FAA to retaliate. They’ve opened this comment period up because they screwed up. Take advantage of it if you can. Please note how FAA inspectors or recently retired inspectors, who likely have authored or contributed to the policy drafts are trying to stack the comments. If they can do this to a school, they can and will bully an airline. But, PLEASE hurry.

Clarification of Policy Regarding Designated Aircraft Dispatcher Examiners Docket Type: Rulemaking Document Docket ID: FAA-2011-1149 Agency: FAA RIN: 2120-AA66

http://www.regulations.gov/#!docketDetail;dct=FR%252BPR%252BN%252BO%252BSR;r pp=10;po=0;D=FAA-2011-1149

To submit a comment: http://www.regulations.gov/#!submitComment;D=FAA-2011-1149-0001

Whenever any of these people imply that what Sheffield does is not ethical, they are slapping not only us, but you in the face. They are basically saying I gave you a ticket. Did any of you at any time think my course was simple, required no work, and you’d be handed a certificate by me, as an examiner, even if I owned the school? If anything you witnessed students dropping orquitting throughout the course. Then you likely arrived for your exam nervous, anxious, but wellprepared. And hopefully, you discovered that you were prepared well for your airline training, and other attending mills or “getting” their certificate from non-school affiliated examiners were at times, pitiful, or at least lacking in some basic knowledge.

If so, please point this out for us and support Sheffield School. Thank for taking the time to read all of this - it has absorbed my time over the past 2 years. Even though the FAA lawyers keep siding with me, these rogues keep trying...

If you have any questions, please contact me anytime. Your support will definitely be remembered. The other “Emergency Report” file is over 130 pages, but just skipping through the bookmarks and some of the Appendices will show you how disgusting all of this truly is.

Thank you so much for reading all of this.

Best Regards,

Eric Morris
President Sheffield School of Aeronautics (est. 1948)