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February 5, 2012

Rebuttal to statements made by Jim Etchison

It’s a sad day when a Part 65 course operator resorts to libel in a public comment

docket in an attempt to discount Sheffield School support for the problems within the

original 2008 policy and subsequent policy draft of further restrictions. Using a

condescending reference to me, he seems to indicate that all Sheffield support,

including the 100s of testimonials we have online must be false, according to his

“chats” with “several past students” of mine. FAA inspector compliments must be

false; dozens, if not hundreds of airlines must be wrong, and 1000s of successful

students over the past 6 decades must certainly be delusional to support Sheffield.

Unfortunately, Mr. Etchison failed to clearly state “failed Sheffield students” in his

libelous statement. Since this is about policy, I will try to keep it to that, but I shall

also enlighten everyone regarding his sources. In doing so, Mr. Etchison will see that

he only brought more attention to the true problems within this training industry,

and for that, I thank him.

Yes, Mr. Etchison, we think you should have the right to apply to a local office to

have a DADE who is on staff, and we think ALL Part 65 schools should have the right

to pursue that. If you have asked and been turned down, ask your local office why.

If a local office only has limited ability to oversee a limited number of DADEs, then if

not all schools can be afforded that right, then isn’t it common sense that the schools

with the largest volume of students have the greatest need for that capability?

Do you actually believe the only reason Sheffield School has a high student volume is

because we have examiners on staff? Delta Air Lines and many others chose us

because they had previously received poor training elsewhere – they never asked us

“so who does your exams?” In fact, reading Mr. Buckalew’s (x-Delta) comment that

conveniently followed yours, it appears that many schools in many states didn’t

seem to meet Delta’s training requirements. A previous major airline director, now

an FAA inspector, also seems to disagree with you, along with many others:

"While the cost of training is a factor which must be considered, the true cost

is found in the quality of the product. For this very reason we chose Sheffield.

Their experience and commitment to quality in all phases of instruction is

unequaled."

Hank Echols-Director Flight Control-July 2000, current FAA Aviation Safety

Inspector

I can’t locate an in-house examiner blurb in that quote. Do you actually believe it has

nothing to do with the instruction we provide, or the school’s reputation, or satisfied

airline customers, or our 64-year history of providing a consistent high-standard

product? Also, you and others should thank me for upholding my standards - it

means that unqualified individuals who we believed could not perform the required

tasks in a practical examination, and who therefore failed the Sheffield course –

could end up at your school later, and provide some income for you.

According to your logic, the FAA is helping us out and trying to actively hurt

everyone else. You could definitely NOT think that the FAA is trying to help us and

us alone, if you had seen all of our submissions for the last several years including

still-unanswered questions in an FAA Administrator’s Hotline complaint regarding the

evolution of this very policy. You have made this comment without knowing relevant
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facts that were unfortunately omitted by the policy authors. But rest assured, you

do NOT know the history of the last three years.

If you actually read what we are writing and submitting, we are not in favor of

Sheffield School simply keeping an “exception” for us alone. We are arguing that

such a policy that discriminates against ANY OR ALL Part 65 course operator

employees is inherently discriminatory on its face and it exceeds AFS-200’s scope to

even write such policy. So, you’re welcome.

If your graduates are unable to secure a practical test in a reasonable amount of

time when needed, then you should have them file complaints against those DADEs

with the FAA office having jurisdiction over them. Lack of availability of DADEs

within a reasonable timeframe is cause to question whether those DADEs should be

allowed to be renewed or replaced, and it also bolsters the case for school-affiliated

examiners for your institution. Know why they can’t get exams quickly? Most likely

the DADEs you use are too busy with their active dispatch jobs, and yet AFS-200 is

trying harder to push to make only active dispatchers DADES. But thank you for

making our case that NOT having the ability to have school-related DADEs is harmful

to the public, and that the public interest actually requires the allowance of schoolrelated DADEs.

The statement that the DADE policy should be used to spread employment elsewhere

is just frivolous – so, designations are now a jobs program, and the FAA should make

policy decisions based on ensuring even distribution of wealth? I believe that is a bit

beyond the FAA’s regulatory scope – to find “jobs” for examiners who are

typically...employed and probably receive a paycheck.

It is interesting that virtually everyone that has posted comments in favor of this

Part 65 school restriction is either a Part 65 school that doesn’t have DADEs, who

would actually benefit more by ALLOWING school-related DADES instead of removing

them across the board – or FAA inspectors who either authored the policy or have

other conflicts of interest against Sheffield School, or are current DADEs who stand

to lose a few dollars to school-related examiners, some of whom (Sheffield) perform

this task for the FAA for free.

Since you seem to suggest something about quality of schools or that our quality is

not better than others, then you surely wouldn’t mind if the FAA started an

investigation of how many schools have accepted people who FAILED other schools,

and how much credit those students have been granted for failing elsewhere. This

actually is quite relevant since AFS-200 seems to think that the basis for granting

credit under 65.61(d) should be placed in the official course graduation certificate.

Will you join me in asking the FAA to have all Part 65 schools publicly provide

numbers regarding how much credit they have granted to students who failed at any

other school, and calling for ALL practical tests to be observed by an FAA specialist

when credit was granted for failed attendance elsewhere?? I am sure that we can all

agree that especially in these cases, those exams should be monitored, whether or

not it is a school-related DADE giving the exam. I’ll start, in fact – since the Morris

family has owned the school, Sheffield School has granted zero students any credit

for failed coursework elsewhere. In fact, to my knowledge, I know of zero students

who failed elsewhere who have then decided to attend Sheffield. Join me, Mr.

Etchison. Your turn.
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[On April 11, 2011 – Mr. Etchison requested transcripts of 3 previous Sheffield

students who failed miserably at my school, and who slandered Sheffield in the past,

according to their own airline – it’s in writing. He was asked for his FAA inspector’s

contact information (John Charny), which he provided, in order for me to request

FAA observation of any FAA practical exams of any previous failed students. He

neglected to include this information in his post. I requested this in the interest of

aviation safety.]

He failed to mention a few things about these students, and how much they

complimented the class....until they failed. He failed to mention that one student

from the same airline as the ‘failed 3’, had nothing but compliments about the

course. He failed to mention that another student from the same airline who

attended later that year passed and loved...the same course. He failed to mention a

few things about these students’ classmates and how much they enjoyed the class.

He failed to mention the failed students’ performance in the class, or what they were

suspected of doing (cheating) from their own airline.

For the truly appalling details, feel free to visit:

http://www.sheffield.com/SG-TheUglyTruth.html

For written documentation of these student’s admission of failure with their

airline’s opinion, feel free to visit:

http://www.sheffield.com/SG-EmailedTruth.html

How do you go through an organized online course, the same course which received

accolades from the same group verbally during the class, who also “passed” quizzes

and tests online, yet after additional instruction and review in residence, proceeded

to regress and then call “center” a “ceiling” among dozens of other errors? Online

cheating perhaps? Cramming and forgetting? How about this new dispatch equation

– “Burn fuel + alternate fuel = Max TOGW.” All of these examples obviously

EXCLUDE critical thinking ability. These are basics! I realize that Sheffield is the devil

to many, but guess what - we really don’t feel compelled to put these people into a

position (sitting for a certification exam), that could result in their planning of flights

with human beings on board.

Would any legitimate course operator pass a person who can’t define

various altitudes, can’t differentiate an isobar from a freezing level, verbally

state that “RVR and ceilings are the same thing” multiple times after being

corrected, or that Runway 4 represents 400 degrees, after initially stating 4

degrees? I doubt it. What should disturb the FAA is that we all know that

they may be certified one day, if not already. Just don’t blame me - I did my

job.

Most absurd of all, is how a group of students, who received additional help from

Sheffield online, who arrived at Sheffield unprepared and admitted it in writing, who

complimented me and course while here, who received additional free help on

weekends and after class for up to 3 hours on weekdays, who were provided

additional review due to their lack of study and/or lack of aptitude, who requested to

return for additional training, who are employed at an airline who employs a

high-level manager, who is also a board member of Sheffield School of

Aeronautics, AND who even RECOMMENDED SHEFFIELD to other co-workers after

leaving here, then turns against Sheffield. All of this occurring a few days after they

were apparently granted zero hours of recommended credit, after failing tests,
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retests, and verbal questioning. Anybody out there prefer that I hand out credit

hours for cheating and ignorance? I keep the interest of aviation safety in mind,

when deciding on passing or failing.

Here is a comment for the policy authors to consider going forward based on Mr.

Etchison’s and others’ comments already submitted. Why is it that there are those

who want to wring their hands that people feel the need to support a particular

school (mine) in this forum and say that isn’t germane? It would seem that if people

on both sides of this discussion think that “it’s all about Sheffield,” that means that

the overwhelming majority of the public who has commented DOES think that this

policy is more about an individual school and less about the public interest. This

means the policy is inherently flawed and should be discarded; how can you go

forward with a policy initiative when the public views it as targeted, for better or for

worse?

Referencing Mr. Etchison’s complaint about the inclusion of “unless approved by the

FAA managing specialist,” and the possible allowance of course operators to be

examiners, well, it is due to a regulation found in Part 183, and FAA legal Counsel

siding with Sheffield sometime after 11:00am on January 31, 2011. I suggest

reading the FAR and embracing a phrase I fought for in order to help myself,

yourself, and others. I have NEVER cared what another school does in the form of

examiners – in-house or not. Regardless of a school’s quality, no exam

authority will alter their reputation.

I recommend to Mr. Etchison and others, who “heard stuff” about me or my school,

to ask others, even those who performed at a level higher than failure. You might

just find a collective answer reflective of the comments already posted.

Perhaps these students have improved their knowledge and aptitude somehow –

maybe not, but it is unfair to try to convince the FAA that numerous positive

statements posted about Sheffield School and myself and against policy draft have

no merit due to your “chatted” gossip with students who at one time believed

mountain waves “require no wind” or who couldn’t determine which side of

a front has cold air.

With regard to the Sheffield class that included Mr. Etchison’s sources, and in case

the FAA still needs clarification, this is why 100% of that particular graduating class

passed the practical exam, including using an outside DADE – because we didn’t

graduate the group of students who failed a Part 65 AD course miserably.

Eric (the younger) Morris

President

Sheffield School of Aeronautics (est. 1948)