EMERGENCY

REQUEST

for

FAA Administrator Intervention

due to

Inspector Misconduct/Ethics

Violations at Washington HQ &

Local Offices

[Bookmarked pdf file with password can be accessed

by emailing:

morris@sheffield.com]

From: Eric W. Morris

President

Sheffield School of Aeronautics (est. 1948)
Sheffield School of Aeronautics

Introduction-1

Office of the Administrator

Attn. J. Randolph Babbitt

Federal Aviation Administration

800 Independence Ave., SW

Washington, DC 20591

February 24, 2010

Dear Mr. Babbit,

Sheffield School of Aeronautics, established in 1948, is requesting your immediate

assistance in putting an end to several ongoing problems that have now reached a

national scope, including provable misconduct on the part of individuals within AFS200/220. We have also reached our limit of how much abuse and harassment we

can take from the Certificate Management Office (CMO) overseeing us.

We recognize that it is unusual for such a request to be forwarded directly to your

office. However, we’ve been advised of a rewrite in progress for Order

8900.1 that, if enacted, will be discriminatory to a certain group of

individuals and will open the door to legal action against the Federal

Aviation Administration. We are requesting that your office take immediate

action to suspend any rewrites to Volume 13 of Order 8900.1, pending a full

review and investigation into the misconduct and ethics breaches that will

be detailed herein. This rewrite, if enacted, would also have a devastating effect

upon aircraft dispatcher certification immediately upon implementation.

There are two chief concerns that require review.

First, Order 8900.1, Volume 13 regarding the Designated Aircraft Dispatcher

Examiner (DADE) program has been written in such a way as to destroy certification

activities of approved Part 65 courses, especially at those schools conducting large

classes. The authoring of this policy was conducted behind closed doors, without any

input from the industry; we can and will provide evidence that the origination of this

policy appears to have its roots in personal vendettas held by the past and current

occupants of AFS-200/220 against Sheffield School, and directly violates the ethics

and conduct standards for inspectors as outlined in Order 8900.1.

We will demonstrate that the policies regarding the limitations on DADEs are

dangerously flawed, and actually discriminate against a certain group of individuals

overseen by the FAA – indeed, we’ve already heard discussions by some of the

affected parties of potential class action lawsuits against the FAA if this

continues.

Second, the actions and inactions of AFS-220/200 and our local CMO in their

dealings with us, both as DADEs and as course operators, has gone beyond the level

of harassment and abuse. Our requests for clarification of policy, suggestions for

potential rewrites to solve some of the problems the policy creates, and requests for

our FAA Specialist to exercise the authority that is given to him in existing national

policy to grant waivers and exemptions have been met with threats and changing

stories at the local level, and attempted rewrites at the national level to avoid having

to answer our questions – and that is in the cases when we’ve received replies. Most

often, we have been ignored and many of our communications with these offices

have not even been acknowledged.
Sheffield School of Aeronautics

Introduction-2

We are not the only school and examiners affected by this. We have been advised

by another school owner halfway across the country that he is currently in contact

with his representatives in Congress to request investigation into discriminatory

practices of the Flight Standards Service in creating and enforcing these policies; and

his is not the only plan for Congressional intervention that we’ve heard. We’ve also

heard from graduates of other programs who are desperately seeking assistance

because they can no longer get practical exams administered in a reasonable amount

of time.

The scope of misconduct on the part of local Dispatch Aviation Safety Inspectors and

AFS-200/220 necessitates the involvement of the highest office of the Federal

Aviation Administration. I recognize that this document is lengthy, and that you

have many other important tasks to perform as well. However, please consider the

amount of time that it took me, a small business owner, to put all of this together

over the last few months, and how significant a problem it must be for me to have to

put aside the day-to-day operation of my business to write this.

Sheffield School of Aeronautics was established in 1948, and pre-dates the Federal

Aviation Administration. We have always worked to assist the FAA wherever

possible, which is why we are directing this to your office. The actions of a select

few within the FAA have opened the door to litigation, Congressional intervention and

investigations by both the Small Business Administration and the Department of

Justice, and we’d like to help the FAA avoid this, if your office is able to right the

wrongs that have been committed.

Respectfully,

Eric Morris

President

Sheffield School of Aeronautics (est. 1948)

499 NW 70th Ave, Suite 110

Plantation, FL 33317

954-581-6022
Sheffield School of Aeronautics

i

Table of Contents

• Preface & school history 1

• Present & Past linked 5

• History & Objectivity & Our Service to FAA 5

• Past relationship with FAA compared to present day 7

• Excerpts from an ASI report 9

• Vendetta/FOIA/Irony 11

• Order 8900.1 Sequence 13

• Selected Order 8900.1 Policy with suggestions 14

• New Order 8900.1 Policy 19

• Objectivity (as owners, directors, instructors) 19

• Lack of customer service towards DADEs 20

o CMO-29 20

 Recent exam schedule/local FAA office

 Fatigue

 DADE relief from inside or outside district

o Southern Regional Office 26

o AFS-200 27

o AFS-220 27

o Assistance and relief sought and not received 30

• Questions (authoring of Order 8900.1) 31

• Summary 37

APPENDICES

A – Sheffield 2009 customer/airline list

B – CB email

C – EP email

D - Objectivity

E – Sheffield–2009 dropouts/failures list

F - Original request for policy relief sent to AFS-220 & CMO-29

G - Subsequent request for policy amendment/rewrite sent to AFS-200

H – Original denial of policy amendment/rewrite sent from AFS-200: Dec 16, 2009

I – Practical exam schedule per 8900.1 policy (~60 hours-based with LESS test 

security)

J – Practical exam schedule following 8900.1 policy if approved for simultaneous flight 

plan exercise (~33 hours-based with COMPLETE TEST SECURITY)

K – Complete Aviation Safety Inspector report on Sheffield School – W. Bonatti

L – Stagger exams request – to prevent FATIGUE

M – CMO-29: statements & false accusations

N – January 29, 2010 telephone call w/CMO-29 log

O – Inspector misconduct in classroom

P – Ownership restrictions for examiners

Q – Response to Certified letter from CMO-29

R – FOIA excerpts linked to vendetta origin

S – Highlighted references of Personal Ethics and Conduct policy violations
Sheffield School of Aeronautics

1

Preface

On September 30, 2008, the Federal Aviation Administration implemented national

policy regarding the Designated Aircraft Dispatcher Examiner (DADE) program.

These changes were published in Change 35 to FAA Order 8900.1 in Volume 13,

Chapter 3. Neither the sweeping redesign of this policy nor its implementation were

conducted with any consultation with those in the industry who would be affected by

it – namely, the existing DADEs and Part 65 Aircraft Dispatcher Certification Course

operators.

In our discussions with other DADEs and operators, the consistent theme that we

have heard is that all of them were blind-sided by the changes and found out about

them after the fact. The fact that no consultation with the industry occurred is a

violation of Order 8900.1 ethics and customer service standards. Sheffield School of

Aeronautics was established in 1948; we are the world’s oldest aircraft dispatcher

certification course operator, and DADEs attached to Sheffield School have

administered over 4,500 aircraft dispatcher practical exams. If anyone in the

industry were to be consulted, we would have expected to be on the list so that we

could offer our input as to what works, what does not work, and what improvements

could be made to the program.

Indeed, Mr. Babbit, it appears that you agree with this philosophy based upon your

speech before the Senate Committee on Commerce, Science and Transportation,

Subcommittee on Aviation when discussing the FAA’s safety programs:

“It is essential that those who have captured the essence of the

professionalism have opportunities in and out of the cockpit to pass it

on. Experience is a wonderful teacher, and there is no substitute for

learning at the hands of someone who has already been there. The

inexperienced people in the system need to meet the ones who have

been around the block. They need to seek them out and mine

whatever golden nuggets they have. That is one of the main reasons I

think we need to see more mentoring throughout the industry.”

December 10, 2009

Statement of J. Randolph Babbitt, Administrator

Before the Senate Committee on Commerce, Science and Transportation,

Subcommittee on Aviation on the Federal Aviation Administration’s Safety Programs

We completely agree with and respect the above statement, but this philosophy has

been disregarded at virtually every level of the Aviation Flight Standards Service with

which we have dealt in the last few months. We were only made aware of the new

policy in October 2009, when the oversight of our DADE responsibilities was

transferred to Mr. , a Dispatch Aviation Safety Inspector attached to

Certificate Management Office (CMO) – 29 in South Florida.

It became clear to us from our initial meeting with Mr. (who indicated in the

first 90 seconds of our initial meeting that he did not want this assignment, did not

ask for this assignment, and would need to spend more of his time on the “more

important” work of overseeing air carrier dispatch sections), that this policy had been

designed behind closed doors without any input from the industry.
Sheffield School of Aeronautics

2

Some of the restrictions added in this new policy not only cripple certification

activities at programs with large classes, but also discriminate against certain

existing designated examiners without cause. These new restrictions on the conduct

of the examinations that invalidate long-standing approved methods of conducting

the exams with no reasons provided, and significantly reduce test security. In some

cases, the new policy contradicts the existing (and still current) Practical Test

Standards, and apparently there has been no attempt to reconcile the differences.

Our concerns are not only technical, in terms of contradictions and procedures that

are flawed. They are also based on the fact that this “rulemaking by policy”

approach avoids any opportunity for those who are affected by the policy to

comment, and is effectively an end-around of the requirement for

rulemaking to consider the impact on small business entities – of which the

vast majority of dispatcher certification programs happen to be. That we were not

afforded the opportunity to comment means that much of the policy creates undue

burden on us, and is highly contrary to the public interest.

Our efforts to address these concerns to the local office have been met with threats

and harassment, and our efforts to address petitions for changes to policy to AFS200/220 have been meet with non-answers, and in many cases, lack of

acknowledgement – from the very office that is responsible for promulgating changes

to policy when it is deemed inadequate.

After months of attempting to work within the system, and having been threatened

and bullied by our local office for daring to ask any questions, we simply cannot

abide any further mistreatment. We have had a harmonious relationship with the

local offices of the FAA for our entire 62-year history prior to being transferred under

CMO-29. We would encourage your office to contact past Principle Operations

Inspectors who have overseen operations at Sheffield School across the years – we

have nothing to hide.

However, after having apparently angered a previous occupant of AFS-200 when we

asked questions several years ago on other matters, pointed out the illegal approval

of an aircraft dispatcher certification program in the Middle East (which may have

had implications for terrorism, since there is a distinct possibility that one airline’s

confidential security procedures were in manuals used in that course outside the

USA) and helped others in the FAA fix that error; and having been completely

exonerated in a failed attempt at a “sting operation” (one inspector’s choice of words

in an email located in a FOIA search) thereafter, it is clear to us that those in

Washington who have harbored a vendetta against us began writing a policy aimed

directly at destroying our business – this policy is the current Volume 13, Chapter 3

of Order 8900.1.

If that sounds beyond belief, this report will lay out a compelling case that there is

no other logical explanation for some of the changes implemented in the policy that

was initiated under that individual’s tenure in AFS-200, and we can and will prove

that AFS-200/220’s treatment of us in this matter in the last several months is a

clear violation of customer service and ethics standards established for all inspectors.

There is so much information to follow, all of which is interconnected, that some

items will seem repetitive, and it is difficult to lay it all out in any simple format.

Because of the simultaneous actions of multiple FAA offices and individuals, even a
Sheffield School of Aeronautics

3

chronological approach will be difficult because it would take away from the attention

that we wish to bring to the problems of each individual piece.

Briefly, in order to establish context, we will review the history of both our

relationship with the FAA and the DADE program. This is not intended to be selfserving, but rather to frame the current problems in the light of how things have

functioned historically, and to highlight the incredible and in many cases shameful

changes that have been initiated in the last 18 months.

We will then list the specific portions of Order 8900.1, Volume 13 that are not only

objectionable, but absolutely crippling to the entire DADE program when combined

with the unwillingness of local Flight Standards District Offices (FSDOs) and

Certificate Management Offices (CMOs) to perform their certification duties as

required by the Order. This is not only affecting us. Because of these changes and

the unwillingness of local offices in another part of the United States to help, we

have been advised that another schools’ graduates are being told to expect a wait

time of fully two to three MONTHS to be able to take a practical exam for aircraft

dispatcher certification. Why? Because an existing DADE with years of experience

was not allowed to continue under the new policy, and the local office there either

cannot or will not administer the exams in a timely fashion.

During that portion of the discussion, we will also point out which portions of the new

policy are apparently being rewritten to remove any possibility of local FAA

Specialists granting local waivers to operators who are unduly burdened – which, if

allowed to happen, will force the application of a discriminatory standard

that may subject the FAA to legal action. This pending rewrite, which has

been mentioned to us by our local inspector, needs to be halted before it is

published in Order 8900.1 to avoid potential litigation against the FAA from

other course operators, and almost certain Congressional inquiry. We have

heard that all of this WILL happen if this rewrite restricts some operators even

further, and at the time of this writing, we are already aware of one of our

competitors who plans to meet with his Congressman regarding the subject.

We will then outline additional aspects of the application of the new policy, which

violate existing Federal Aviation Regulations – which has not stopped Dispatch ASIs

from proceeding anyway. Again, if the FAA is knowingly acting outside of regulation,

then the likelihood of Congressional intervention and/or civil action cannot be

discounted.

We will go on to point out that, when the responsibility of oversight for Part 65

aircraft dispatcher certification courses was transferred from local offices who were

familiar with overseeing schools, to Dispatch ASIs that have neither the time nor the

training to oversee certification programs, that disastrous results have followed. The

lack of the required training as dictated by other portions of Order 8900.1 is not a

random allegation – it was confirmed by Mr. of CMO-29 during

discussions that were witnessed. We will also bring into question the examination

process for Dispatch ASIs to gain their inspector credentials, based upon statements

BY AVIATION SAFETY INSPECTORS, both past and present, who have indicated that

their internal testing was laughable, and in some cases, nonexistent.

All of the above have national implications. However, we have been forced to

tolerate an excessive amount of abuse, harassment, lies, changing stories, false

accusations, threats and non-answers from our local Certificate Management Office
Sheffield School of Aeronautics

4

since this shift of oversight responsibility. We understand that these are serious

charges that we are making. We will provide documentation and specifics for of all

of the above. Aside from our desire to see the national policy scrapped until proper

policies can be formulated in consultation with the industry, we are asking for your

intervention in these issues as well. It is inconceivable that the FAA believes

that having our school and DADEs overseen by CMO-29 in light of the evidence that

we will offer, is in the best interests of the FAA or Sheffield School. We are

requesting to be transferred out from under not only our current Dispatch ASI, 

, but also out from the jurisdiction of CMO-29 completely. Having seen this

office’s conduct toward us after having simply requested relief from one aspect of the

new policy, we ABSOLUTELY expect that CMO-29 will engage in retaliatory

action against us, notwithstanding FAA policies to the contrary. Again, they

have already been engaging in retaliation, so we have no reason to expect that to

cease.

We believe that disciplinary action, and indeed even termination, is warranted in the

case of several FAA inspectors mentioned herein. This is, of course, your decision,

but we will be documenting multiple, consistent violation of inspector ethics and

conduct standards not only at the local level, but also within AFS-200/220. It is

because some of this misconduct has been committed in the Washington

Headquarters of the Flight Standards Service that our report cannot be

addressed directly to any AFS office, and must go above the level of AFS-1.

Finally, we will present a list of questions regarding the formulation of the national

policy. We respectfully request to be provided answers to each of those questions.

At the end of this report, there are numerous appendices. We realize that this report

alone is quite lengthy and will take ample time to read and digest. However, we

STRONGLY request that you read through all of the appendices as well. They contain

a significant amount of specific documentation that will provide necessary insight

into the nature of misconduct that many within the FAA have been committing.

To be clear – we would like for this all to be resolved within the FAA, as we believe

the FAA should have the chance to fix the problem. However, the rapid pace at

which we have been told the next 8900.1, Volume 13 rewrite is being pushed, and

the ever-increasing abuse at the local level both mean that we cannot wait long. We

are a small business, and this is our livelihood. If we cannot get rapid resolution

to these problems, then we must pursue every avenue available to us to

seek relief. These include Congressional inquiry, escalation to the Office of the

Secretary of Transportation and above, the Small Business Administration, media

and legal action if required. We do not WANT this – it is our sincere desire to work

WITH the FAA to resolve these issues, but please understand that we must defend

ourselves when agents of the government agency charged with both overseeing us

and assisting us, instead choose to attack our livelihood. And we are requesting

your assistance because although we know your office directly has nothing to do with

what has transpired, these individuals are undermining the credibility of the FAA on

your watch.
5

Present & Past linked

“Another challenge is (that) the school is not able to find an

examiner, which could takes months....”

Excerpt from email (see Appendix B for full email) sent to Sheffield School from

graduate of another school seeking assistance – December 3, 2009 09:39:53 (PST).

An example of how new restricting policy has not only eliminated some

DADEs, but also exposed the unwillingness or inability of the FAA to conduct

a practical examination in order to assist this person.

“..an inspector in the Phoenix office...who would like to take the

school’s ability to conduct practical examinations.”

Excerpt from email (see Appendix C for full email) sent to Sheffield School from

owner of another school regarding alleged FAA bullying – September 11, 2002 3:36

PM

My report will link these two emails along with a vast number of other events to

present my school’s appeal for relief from portions of the Order 8900.1 and its’

relatively new and questionable DADE policy. I am also requesting an improvement

of customer service from various levels of the FAA.

You are my next step in attempting to “right” a wrong. Our case presented herein is

completely reasonable, logical, safe, true, and in the very best interest of the public.

We’ve worked the way we have for decades, and have been approved by the FAA to

do so due to our size. We have NEVER committed any questionable testing activities;

yet now, due to closed-door policy with ZERO coordination with us, we are asked to

fatigue ourselves for many consecutive days and delay our customers’ return back to

work, which defies public interest in every way possible. From the local level and

above, there is ZERO interest to recognize these issues and coordinate and

effectively communicate with me in a timely manner. I hope you can help me.

History & Objectivity & Our Service to FAA

Normally, FAA customer service over the years has been better than our recent

experience. I have had much respect for the FAA as did my father, Ron Morris;

however, I am closer to calling him out of retirement to help rectify a variety of

issues regarding Aircraft Dispatcher Certification policy and customer support. Ron

Morris bought Sheffield School of Aeronautics in 1971, and the school has operated

successfully, and without any problems, under the Morris family for nearly four

decades. He also mentored me, served in important appointed positions under four

Presidents and four Florida Governors (both Democrat & Republican), and was asked

at one time by influential Reagan supporters to submit his name for the position of

FAA Administrator, which he respectfully declined. Unfortunately, he is as unhappy

as I am regarding the following, and we are appealing to your office for assistance.

The FAA Dispatch Aviation Safety Inspector oversight and training program and its

Order 8900.1 policy, including how inspectors wrote it, apply it, misapply it, misread

it, and REWRITE portions of Volume 13 when tough questions are presented is in

need of an immediate review. I also believe the FAA should not threaten personnel

who LEVERAGE the FAA’s workload; such threats have occurred on the local level. I

actually received a veiled threat regarding contacting upper FAA offices.
6

I am President of and operate Sheffield School of Aeronautics (est. 1948), an FAAapproved aircraft dispatcher certification school – a SMALL BUSINESS. As you can

see, we pre-date the FAA. This is our 62nd year in business without any problems,

shutdowns, name changes, etc.. We are the world’s oldest and most reputable

Aircraft Dispatcher Certification school in the world (see our customers – Appendix

A). I am also a Designated Aircraft Dispatch Examiner (DADE), who likely leads the

world among active Aircraft Dispatcher examiners in total number of AD practical

exams conducted. My father, who retired, has conducted over 2600 “check rides”;

therefore, we know what we’re doing and have proven so countless times.

Unfortunately, the FAA has chosen to seriously affect my business with either

ignorance-laced policy or vendetta-based policy, which this report will detail.

Sir, as an airline pilot for Eastern Airlines, you are fully aware of the importance of

the role of the aircraft dispatcher in operational control of flights. You promote a

“mentoring” way of learning. My mentors are Mr. Ron Morris, my father, who

dispatched for Eastern for 10 years, and Mr. Leon Jansen, who sadly passed away in

December 2009, and had dispatched for Eastern Airlines for 40 years.

This small business has been in my family for nearly 40 years. It appears now that

the FAA is trying to put me out of business. This presents a problem that I will get

fixed one way or another, but preferably with your help.

Sheffield School, through the use of its’ DADES, have collectively conducted

approximately 4,514 FAA Aircraft Dispatcher practical examinations (“check rides”)

since October 29, 1976. My father, Ron Morris, and I together have conducted over

3,400 exams. Sheffield School was established in 1948, is now in it’s 62nd

CONSECUTIVE year of operations/dispatcher training. We are not only the oldest

dispatcher school in the world, but the most reputable as well. This results in a

LARGE number of students/graduates, resulting in our school consistently

using the DADE concept to relieve the local FAA offices that otherwise is

required to conduct these examinations. We act as examiners for our school due

to our efficiency, objectivity (many students do not get signed off for the practical

exam), and professionalism. We have NEVER had an issue with the conduct of

our examinations. Our objectivity has never been questioned – we have PROOF

that our school, who typically employs its own DADEs, as approved by the FAA, have

likely on many occasions had more students fail or resign than most other schools

have passed. (See Appendix E). We have likely issued more pro rata refunds to

students who’ve never even reached the practical exam, than many other schools

have grossed. We have SUBMITTED this information following EVERY CLASS to the

FAA for years BEFORE IT WAS EVER REQUIRED! How can anyone within the FAA

question the objectivity of Sheffield School DADEs or their exam procedures? Yet

Order 8900.1 condemns and restricts many of our past practices. There was no logic,

no discussion with local district offices or us regarding any questionable rumors –

NOTHING. Nobody officially or formally mentioned any concerns to us. It now

appears that more DADEs must be hired, trained, checked, and if that plan of action

fails, the FAA must administer these exams, as policy mandates. One problem now

appears to be poorly trained DADEs.

February 1, 2010 3:12:00 PM EST email

“The FSDO set about to get some new DADEs. They used us to train them. One quit

and the other needs more training.” - From another Aircraft Dispatcher school
7

The other problem is that our local FAA office, and likely others, have claimed

everything from “we won’t do exams” to “nobody in this office can give exams” to

recently, after prodding by the Southern Regional office per my request, “we have a

limited number of inspectors to help you, but here’s a list of DADEs.”

If you average the amount of time required for each exam, the production of

certification paperwork involved, the time lost on the phone due to others’ clerical

errors, we have likely saved the FAA between 25,000 to 40,000 hours of work over

the past 34 years alone. We believe that the public interest has been greatly

served by Sheffield School and its examiners, whether it is saving FAA inspectors’

time or increasing the quality and quantity of time available for of airline oversight

due to the extra 25-40,000 hours.

During the past 34 years, the amount of money that Sheffield DADES have

earned is ZERO. In good faith, we decided not to charge graduates extra fees for

practical exams – in fact, we paid Leon Jansen (Eastern dispatcher for 40 years) to

assist us because we were so busy. So busy, in fact, that the local FAA permitted 4

DADEs WITHIN SHEFFIELD to simultaneously conduct exams. This is UNHEARD OF

and speaks volumes for the quantity of qualified applicants requiring certification and

processing. You are welcome to check our graduation rate as well as our EXAM pass

rate over the past 4 decades.

Based on either a lack of logic or a vendetta towards our school for some ironic

reason, Sheffield School has now been handcuffed based on the most recent policy

change to Order 8900.1. We respectfully asked for our case to be heard and for relief

to be granted until the next policy change. We sought relief (see APPENDIX F/G),

but were denied (Appendix H) without specific reasons, including having one

request completely ignored and unanswered. As stated multiple times within this

document, there is a very simple, effective, logical, secure, and safe solution.

Hopefully, you will agree.

Sheffield School, and it’s associated Designated Aircraft Dispatch Examiners

(DADEs) are asking for an immediate emergency waiver/exemption from

Order 8900.1, Volume 13, Chapter 3, Section 2, Paragraph 13-175(b-c-d.)

Past relationship with FAA compared to present day

For the past 40 years, my family has operated Sheffield School of Aeronautics (est.

1948). Between my father, Ron Morris, and myself, we have had a good working

relationship with the FAA. Usually, if we had a question or comment for the FAA, it

was respectfully presented, and subsequently answered respectfully by the FAA,

whether we agreed or not. Unfortunately, over the past 6-8 years I’ve noticed a

trend that I find uncomfortable and disappointing. Beginning with Theodore Perry,

now deceased, and apparently continuing to present day, I’ve noticed a reluctance of

the FAA on the national level to coordinate harmoniously with my school. We’ve also

never had a problem on the local level, until recently. In minor defense of the local

CMO, the recent transition to dispatch Aviation Inspectors assigned the task of FAR

Part 65 school oversight (with DADE oversight) has been rockier than foreseen.

However, as a Designated Dispatch Examiner since 1995, having conducted over 840

FAA practical examinations in addition to operating the most successful and

respected FAR Part 65 school in the world, I feel that I’m due a bit of courtesy and

understanding from those tasked with working harmoniously with me for the sake of

aviation safety, efficiency, and the public interest, which includes my customers and
8

students. I can handle oversight by those untrained and/or inexperienced with their

assigned tasks; however, I shall not accept vague answers, slow responses, nonanswers, changing answers or directives, from the local level through the national

level.

Just 2-3 weeks ago, there was a national dilemma regarding over 47% of the

aviation testing centers being shut down due to the lack of a “backup plan.” I wrote

a strong, but fair statement to AFS-630 who quickly called me, were extremely

courteous, clarified the situation, assisted me for the next two days, then proceeded

to rectify the entire situation much more rapidly than initially planned. This was a

stellar example of the FAA working with the public. I’ve had good experiences

with various inspectors within AFS-200 and AFS-220 in the past regarding the

shutdown of illegal schools outside the U.S.A., the revocation of FAA dispatcher

certificates issued to unqualified applicants in New York, and other questionable

practices. I’ve always applauded those who listened to my father and myself, and

took action without feeling they were bullied or degraded. Any owner/operator of a

small business cannot afford to have an uneven playing field. However, I now feel

acrimony from people who are supposed to assist me, work with me, coordinate with

me, etc..

I am a DADE and course operator who is not receiving consistent and timely

assistance from various levels of the FAA; therefore, I am turning to your office for

assistance.

Beginning on page 9 are excerpts from an ASI report (Appendix K) years

ago conducted as a “sting operation” on Sheffield School (FAA’s words per

FOIA.) The following specific questions are in regard to the FAA report

quotes that follow:

1. Why have these quotes now been discounted as worthless or no longer valid?

2. What has transpired between the date of the report and the 8900.1 policy change

date to alter policy to hamper a large school’s operations?

3. The report praises how Sheffield handled 9 applicants performing individual flight

plan exercises, effectively, efficiently, and securely. With FAA policy now severely

restricting how we administer exams in addition to the number of daily exams, how

are we to NOT continue with this methodology considering the current graduating

classes average 18-20 students requiring testing? [We have had over 35 in 2 classes

in the past!]

[We appeal to you now because recent requests and questions asked of our local

office and AFS-200/220 have been met with no replies, slow replies, or vague replies

or conflicting statements, applicable to not only the school’s DADEs, but the

approved course curriculum as well.]

4. Inspector William Bonatti’s report, which completely exonerated Sheffield of any

alleged misconduct, and highly praised our complete operation, was addressed to

Ted Perry who apparently despised Sheffield*. [We can provide the terse emails from

him at any time, upon request.] Did Mr. Perry even forward this glowing report to

ALL others who were a part of the authoring process of 8900.1? If so, who? If not,

why not, since its dissemination could have lead to more effective and fair policy?
9

*Mr. Perry seemed disgruntled with Sheffield for asking a series of ETOPS questions

following ETOPS rule changes a few years ago. We waited 3 months for a reply,

rewrote our request, and were eventually replied with a terse statement complaining

that the ETOPS expert required over 8 hours of research, and that “my instructors

should do more of their own homework.” He also had issue with me requesting an

investigation of a local school allegedly instructing in Spanish. Since I was informed of

this by a South American airline, and I’ve lost business because of this, I decided to

ask the FAA to investigate. Only terse unprofessional responses resulted, including

“this matter is now closed.”

From a source within AFS-220, Mr. Perry was terminated. Did the reason for his

termination have anything to do with his ability to author policy fairly? We are

deciding whether to pursue this matter as well. It does not matter if he is alive or

dead. If his attitude toward Sheffield, which appeared to break multiple rules of

ethics and conduct codes for inspectors, as evidenced in emails I possess, had

ANYTHING to do with current policy that was initiated by him (as indicated by 

 verbally in a Fall 2009 meeting in my office), or if he influenced those who

followed him, then we will pursue legal action or a thorough investigation, if

required.

Another statement below from of CMO-29:

“The 8900.1 policy came from few currently in AFS-220 – it was more from

the time Ted Perry was still in the FAA.”

Things appear to add up to validate my points – that policy was authored with intent

to harm Sheffield School even after vindication, further local approval, further

oversight of our exams and school operation.

5. Since the policy rewrite was either initiated by, or included this person and others

who may or may not have disseminated the Bonatti report, coupled with the fact that

my sources within the FAA claim that Mr. Perry was terminated from his position, I

would like to know the reason for his demotion or termination since it may

affect the validity of how this entire Order 8900.1 rewrite came about.

Inspection report excerpts - Bonatti quotes July 14, 2003

“A review of the course materials, handouts, exercises, and course

examinations showed that the school has spent a lot of time and effort to

prepare affective and efficient training and testing materials. The course

materials used are current and up to date with the industry, and far exceed

the needs of the course. In many cases Sheffield School of Aeronautics has

produced materials that the student can use throughout their industry

employment.”

“The Procedures used by Sheffield School of Aeronautics and the Designated

Aircraft Dispatch Examiners (DADEs) to conduct Area of Operation 1

“Dispatch Exercise” Task A “Flight Planning” is not commonly found, however

it does meet the requirements of the Aircraft Dispatcher Practical Test

Standards (FAA-S-8081-10A). The applicants are all given their Flight

Planning Exercise at the same time. All applicants are required to remain in

the testing room the entire time while being observed by one of the DADEs.

This portion of the examination is commonly conducted on a one on

one basis by other designees, however they are normally only
10

working with one applicant at a time. In the environment that

Sheffield is conducting this portion of the Dispatcher Practical, it is as

secure and allows the designee the ability to test the specific areas in

which knowledge and skills must be demonstrated by the applicant

before the issuance of an Aircraft Dispatcher Certificate with more

efficiency and less time consumption. The security measures used to

assure that each applicant does his own work are different exercises

for each applicant and the exercise is observed by the DADE.”

[Every note in bold above shall no longer hold true for large schools with a

high number of graduates, due to the 8900.1 rewrite barring simultaneous

examinations. It makes ZERO sense, is illogical, and offers ZERO test

security. If all FAA offices agree to deny our appeal as AFS-200 has, for our

previous, more secure and time efficient method of flight plan testing, then

we shall assume that the FAA will go on record advocating the reduction of

FAA Practical examination test security.]

“The methods and procedures used by the DADEs while conducting the oral

portion to 2 applicants at the same time were also found acceptable. The

DADEs were very effective in their questioning process and in directing

specific questions to each applicant to assure that both applicants were

questioned to an adequate level.”

[Although this does not disturb us as much as other sections we shall

assume that the FAA will bar ALL FAA simultaneous oral testing, regardless

of the TYPE of certificate sought.]

“The DADEs did not allow personal prejudices to interfere with objective

evaluation of an applicant, and the oral portion of the practical test was

conducted in a private area free from distractions.”

[If we were objective back then, why after another 7 years following Mr.

Bonatti’s report, including our 62nd year of continuous operation, would we

now decide to become unobjective with our examinations? Why would we

fail more students that other schools enroll if we were unobjective? Why

would we issue more pro rata refunds that exceed the gross or net income

at most or all other schools, if we were unobjective? I’m sure none of the

above were considered by the authors of Order 8900.1. Anybody could have

contacted the local FAA and dozens of Sheffield graduates at airlines to

verify every word of the aforementioned.]
11

Why VENDETTA?

Middle East “FAA-approved” Dispatcher School operation

Some people probably weren’t happy with my demands to force a shutdown of an

illegally authorized school set up to operate in the Middle East during the

period prior to and shortly after 9-11. My apologies, but when Sheffield had

requested FAA certification ability outside the USA since 1971 and were politely

denied, we accepted it; however, I refused to allow the FAA to create an uneven

playing field regarding my business. It was disgraceful for a Dallas district office in

combination with a New York International field office to pull an end-around on the

Washington FAA group, according to Mr. Jim Gardner. I could have had my people

subpoena the American Airlines’ dispatchers working at that time who were

displeased with AA flight and operations manuals possibly floating around the Middle

East, but I did not, because Mr. Jim Gardner, who understood the seriousness of this

seriously flawed decision, respected my viewpoint and took action. To my

knowledge, Congress is still unaware of this “incident.” I would like to know what the

final disposition was following this matter – were the FBI or others contacted?

Who were the persons within the Dallas office and NY IFO responsible for

this “approval”, are they still employed by the FAA? Did any of these

individuals directly or indirectly affect the Order 8900.1 policy suspiciously

aimed at Sheffield School and its examiners? Obviously, certain individuals were

reprimanded for these actions and likely harbored resentment against Sheffield

School.

Imagine my thoughts and others within AA on December 23, 2001, the day after

Richard Reid’s eventful American Airlines flight. We politely moved forward. So if

anybody thinks I do not try to cooperate with the FAA, they are sadly mistaken – I

have done quite the opposite. My father still recalls telling the FAA their own rules

regarding this Middle East matter.

A reply that “aircraft performance manuals aren’t that bad,” or the like, is

not only feeble, but cannot refute the issue of pre-911 SECURITY

PROCEDURES that are also found within various operating manuals. Where

are these manuals now? All accounted for? What were the exact contents?

Sheffield has never instructed students in (or allowed them access to) security-based

airline procedures. Hopefully, nobody else has.

Past “Sting” Operation

It happened before resulting in an ASI surprise visit to our school during exams.

Bogus exaggerated reports floated around the FAA personnel resulting in a plan to

“sting” Sheffield School according to information obtained via FOIA. Unfortunately,

for those trying “to get Sheffield”, the high praising FOIA-obtained report (See

Appendix K) backfired. I can provide all reports and names of those who tossed the

word “sting operation” around and are still employed by the FAA.

FOIA Revelations – See Appendix R

Perhaps certain authors of policy weren’t pleased with my past FOIA requests (made

due to false allegations about my operation), which resulted in a few past

embarrassing situations. See Appendix R for excerpts from FOIA’d communications

within the FAA leading up to the “Sting operation” on my school. Included are

numerous rumors, exaggerated hearsay from 2nd-hand sources who witnessed

nothing. Appendix R details in chronological order how the FAA decided that sneaky
12

tactics would be the method of operation. Despite our vindication (Appendix K),

Appendix R’s contents indicate how future 8900.1 policy emanated.

Leaks

When I receive reports from current ASIs and other sources, of rumors during

FAA Safety Inspectors’ meetings (such as one held at the Marriot-Hollywood Beach

hotel, in south Florida during the week of April 18-25, 2009), regarding me or my

school or my exams, without ANYBODY officially notifying me for

confirmation, verification, or observation requests, it appears that policy was

authored based on hearsay, rumor, and/or vendetta.

Implications from past inspectors

When I’ve had past local inspectors imply certain ASIs within AFS-220 have made

disparaging remarks about me or my school, I note this for future slander and/or

libel-based lawsuits. I expect denials across the board, but I will have people

investigated and subpoenaed, if required. Ron Morris had to admonish one inspector

working at a major airline for spreading falsehoods regarding why students fail on

occasion at Sheffield. The inspector had no reply, knew he erred, BUT now works

within AFS-220.

Order 8900.1 issues & stories:

Order 8900.1 policy written without any Sheffield input even though our inspector

claimed to us verbally “long-time DADEs were contacted.”

Too many DADE test procedures changes targeted at Sheffield.

Ted Perry, who was uncooperative with Sheffield on Spanish issues, ETOPS

issues, and helped instigate the past Sheffield “sting” operation was,

according to Mr. , “likely part of the working group who put the

8900.1 changes together”, or words to that effect.

Prior questions apparently upsetting people

I’ve always posed questions to AFS-220 and individual inspectors as to how other

schools can give open note open book tests, guarantee jobs, guarantee certification

– yet never receive replies except from inspectors’ personal email addresses, but

never an answer. These questions are for the sole purpose of leveling the playing

field – since it is unlawful for a Federal Agency to unfairly act against a small

business, I simply wanted to look out for the school and protect the public interest

by continuing to serve the greatest number of students annually in the world.

IRONY

How ironic is it now to be forced to endure restrictive policy implemented by Aviation

Safety Inspectors, WHO WE OFFERED TO TRAIN FOR FREE, but were politely

declined. When told years ago by one inspector currently within the AFS-220, that

training could not be free, we offered a prep-based course for $1.00 - evidence that

we tried to work with and assist the FAA. Ron Morris also offered certification training

in the 90’s to FAA personnel for free, including an offer to pay their transportation

and hotel costs – we knew then that proper training from those who had the

unmatched expertise in this field could help those formulating test standards, course

approval standards, etc.. in the future. [see Mr. Babbit’s statement on the

opening page – his statement reflects our objective.] We certainly understood

the FAA’s position to decline for whatever official reasons existed, but WE TRIED.
13

We also find DADE restricting policy from inspectors ironic considering the

“interview” or “oral” exam for the hiring of Aviation Safety Inspectors appears to be

suspect. According to one former ASI, his “interview was non-existent.” According to

another ASI, his oral consisted of “(ASI name), you know this s---, right?” His

“telephone practical” ended within 30-60 seconds or less – open notes, open book as

well, from my recollection.

Order 8900.1 Sequence:

In early April 2003, our local FAA office received a telephone call from Mr. Theodore

A. Perry, AFS-200, Washington, D.C. concerning a complaint lodged by an

unidentified source regarding the conduct of our training and the method by which

our FAA Designated Examiners conducted the FAA Practical Examination for the FAA

Aircraft Dispatcher certificate. It was also clearly stated to Mr. Perry by me, via

telephone that same week, that we were being accused by an unidentified individual,

or parties, for violating a non-existent FAA regulation. ALLEGATIONS WERE NOT

ONLY proven false, we received a complimentary report from FAA inspector William

Bonatti – See Appendix K.

Because the ASI sting operation backfired and resulted in FAA praise by the inspector

to the dismay of those apparently anxious to bring Sheffield down, coupled with the

absolutely ludicrous rumors heard by us then and currently, it appears painfully

obvious that certain individuals do not like us even though Sheffield School has done

more for aviation than any other dispatch school in history. Whether it is jealousy,

our inquisitive nature regarding Middle East schools, questionable ETOPS rules,

Spanish replacing English at certain schools, claims of FAA certification outside the

U.S. in a variety of countries, pointing out diploma mill practices, or protecting my

graduates from ignorance on the job, I must protect myself and the reputation of my

business. I could not stand by and allow advertised claims of FAA certification by

schools in the Middle East or elsewhere outside the U.S.. I also have a problem with

reports or implications from FAA inspectors of other inspectors’ disdain for Sheffield

School, whether due to rumor, hearsay, jealousy, etc.. When I think of that

unprofessionalism, coupled with the number of FAA personnel who have praised us

online and to others, including one assistant manager within AFS-900 who has sent 2

family members here (one in my CURRENT class), the irony of all this in

unfathomable to me. Therefore, I must assume that AFS-200/220 and others

apparently authored the rewrite of Order 8900.1, including how Designated Dispatch

Examiners (DADEs) are to conduct examinations, to hamper us.

The Order was altered in 2008, yet no long-time DADEs appear to have been

consulted, including those of Sheffield School – DADEs who have collectively, as

well as in 2-3 individual cases, conducted more FAA Aircraft Dispatcher examinations

than any other examiners in the world combined.

Policy appears to also be written to prevent the unscrupulous from profiting

from administering easy exams. Was any consideration provided to the FAA

from existing DADEs regarding what they charge per exam? We charge

$0.00. We provide a service to our graduates to allow them an “in-house”

exam requiring no outlay of funds or travel issues AND we provide relief for

local CMOs/FSDOs.

What if we resign? As you know, the district offices are held responsible for

this task of either finding new DADES and training them or conducting the

exams themselves with the paperwork processing, OR BOTH. We would like
14

to continue providing this service, but to continually be cut down at the

knees with denials, non-answers, or inconsistent answers regarding policy,

coupled lately with threats or harassment; well, there really is no point in

trying to help those who do not realize who is actually relieving whom...

Selected Order 8900.1 Policy with suggested future amendments:

Current policy in question as of January 20, 2010 4:15pm ET is below with our notes

in bold/brackets:

Order 8900.1, Volume 13, Chapter 3, Section 2, Paragraph 13-175

13-175 LIMITATIONS. A DADE will not:

A. Test Outside the Certificate_Holding District Office. Conduct practical tests at

locations outside their supervising certificate_holding district office (CHDO) unless

approved and coordinated between the supervising CHDOs.

NOTE: DADE designation should be limited to one CHDO area of responsibility. If

additional areas of responsibility are added the action must be coordinated between

both CHDOs and their FAA specialists.

[We find the above paragraph fair and reasonable for all types of DADEs,

whether operating individually or in conjunction with a school.]

B. Administer More than One Test at a Time. Except as provided in 307(c),

administer more than one practical test at a time, to include no more than two full

practical tests per day. In addition to the two full tests, a retest may be administered

on the same day depending on the amount of material that must be covered.

[We DO NOT find the above paragraph fair and reasonable for DADEs,

affiliated with a large school with 15-30+ graduates, many of whom are

required by airlines to return to work in a matter of a few days. It is also

contrary to public interest. Even with the 2 current DADES at Sheffield, and

“only” 18 potential graduates in our most recent graduating class, it took

both DADEs 5 consecutive 11 to 12-hour days. Since one phase of the

practical examination is a written Flight Plan, we have in the past been

authorized by the FAA to test the entire class of graduates in that phase at

the same time, in a controlled environment, completely monitored by the

examiner, with each person having a different flight plan from the adjacent

graduates. Our method worked flawlessly, effectively, and has been

approved and inspected by the FAA resulting in a glowing ASI report a few

years ago. The origin of this technique rests with the FAA in Miami who

conducted Flight Engineering practicals with 2 applicants at a time. Ron

Morris, then operator of the school, inquired about this technique and was

granted the ok, based on the large number of graduates to be processed

efficiently. YOU (the Miami FAA) taught us how to do this! Additionally,

nobody from the FAA intending to rewrite policy EVER asked us why

simultaneous oral exams were used. Did anyone consider it a method of

protection – one witness for the other? This technique used among

compatible applicants of the same level of ability is actually a validation

method that no single person was treated unfairly by a DADE.]
15

[Also, the reference to 307c appears to be obsolete and invalid.]

Our proposal:

Administer More than One Test at a Time, unless approved by the FAA

specialist. The decision should be made based on historical past performance

results, and shall not exceed two applicants tested simultaneously for the

oral/verbal portion of the examination, with flight plan portion not to exceed

the approved student-to-instructor ratio approved by for the course operator

of a Part 65 school. If approved as stated above, no more than 4 full practical

examinations can be conducted per day by a single examiner.

Except as provided above, administer more than one practical test at a time,

to include no more than two full practical tests per day. In addition to the two

full tests, a retest may be administered on the same day depending on the

amount of material that must be covered. No retests may be given if 3 or

more full practical examinations are scheduled in a single day.

Sheffield note: This allows an ethical school to conduct 2 orals exams at a time, if

busy schedules dictate, along with the entire simultaneous, time efficient, and more

secure testing of the Flight Plan portion.

In the least, we KNOW there is NOTHING insecure or unsafe with the

allowance of a group of students doing a flight plan simultaneously – NONE.

Even if oral exams can no longer be held simultaneously using compatible

applicants, the flight plan portion of the practical exam should be able to be

observed and approved on a DADE-by-DADE or school location/capacity

basis.

C. Test More Than One Simultaneous Applicant. Conduct any portion of the

practical test with more than one applicant at the same time. The option to “stagger”

the tests (start the oral portion of the first test, and start the practical portion of the

second test in conjunction with first test) will be allowed only if approved by the

specialist.

[Same comments as in “B”. Additionally, since being denied any flexibility to

what has always been an FAA allowance for Sheffield, we submitted a

SEPARATE “stagger” request (see Appendix L) to our local CMO-29 office on

January 11, 2010 in an attempt to reduce our EXAM workday to under 10-12

hours, and possibly eliminate one day from a 5-8+ consecutive day period of

testing, all in the name of FATIGUE. One current school operator in

Kentucky HAS WITNESSED THE FAA CONDUCTING STAGGERED EXAMS. We

expected the usual legalese reciting of policy or simply no answer unless

provoked multiple times. Instead, the CMO-29 office claimed multiple

stories regarding the staggered request: “we sent you an answer a week

ago,” and the answer was “no”, reasons of which could not be given, which

preceded a story that the December 16, 2009 denial of our 8900.1 relief

request was basically the denial for staggering as well. The Appendix has

the denial letter from AFS-200 WITH a pasted clause stating an exception

for “staggered” exams may be allowed by the FAA Specialist” – it is IN THE

POLICY! Yet I hear from the local office that it is not or I’m asking for a

“deviation from National Policy” which I’m not because the words are IN

THE 8900.1 POLICY! Also relayed to me from CMO-29 is that policy is being
16

rewritten to exclude those terms – whether Mr. meant the

“staggering” allowance or the “approved by the FAA specialist” phrase, it

still appears to be amended guidance to avoid tough questioning. To rewrite

policy hurriedly, behind closed doors, as a RESPONSE to my concerns, is a

disgrace. Even if I’m incorrect, the fact that the FAA does not even wish to

explain their motivation behind any of the policy changes, the non-answers,

and the alleged quick rewrites is NOT reflective of the Mission statements or

objectives of the FAA. It produces a wall of distrust between entities that

should work together in the interest of safety. Any responsible FAA official

would NEVER debate this point.

The irony of this “staggered exams” request is that the FAA apparently has

no problem with an applicant being tested in one room, while another

unmonitored applicant is taking a flight plan test in another room - yet will

not allow Sheffield to group 15-25 applicants together in a quiet, controlled,

non-verbal, secure environment monitored by a DADE. So we resorted to a

stagger request due to all denials – we are in essence requesting a less

secure testing environment for flight planning than what we have conducted

for over 35 years which the FAA ALSO APPROVED AND OBSERVED! We all

know what will happen once the first 2 flight planners have seen 2 of the

scenarios and meet outside with the next group. After 2-3 more individual

testing sessions, the entire remaining group to be tested (remember 15-40

people at times) will know the basic scheme of all required flight plan

scenarios. It is absolutely a less secure method than our previous method of

testing all at once with different flight plans, but same ENDING times, and

no cheating, resulting in more legitimate certification. The FAA already set a

precedent with simultaneous testing of Airmen knowledge tests. Whether

taking a test on a computer or on paper with other applicants at the same

time, both have been conducted securely at Sheffield School for decades.

[The staggered exams allowance would never have been written if the

authors of Order 8900.1 would have contacted Sheffield School for our

opinion. After 4500+ exams and a stellar reputation among airlines around

the world, you’d think perhaps we could have assisted, and exemplified Mr.

Babbit’s words to Congress.]

We also initially asked for this “relief” from our FAA Specialist within CMO29 via email on December 9, 2009, who promptly responded that this is an

AFS-200 issue, while specifically avoiding the term “FAA Specialist.” It took

a request to the Southern Region to prompt the CMO-29 office to admit that

 is the FAA specialist. Why he did not want to admit what was

on a hand-delivered letter from the CMO-29 office during our initial meeting

in October 2009 is beyond me, other than perhaps he did not feel

comfortable exercising the authority allowed in these paragraphs and

stated, “as approved by the FAA Specialist.” Is this a problem with all

Dispatch ASIs?

[Mr. will claim, as he did during a January 29, 2010 phone call,

which is documented in the Appendix, that I “confuse the 2 different

specialist authorities”: one overseeing DADEs and the other authority of

overseeing a school. Although I’ve explained repeatedly that if I ask him to

exercise authority as an FAA specialist to allow me, as a DADE, to conduct

“staggered” exams, or eventually, to conduct exams, as an owner (which
17

current policy still permits), then I’m asking a DADE-based question due to

the absence of the word SCHOOL. 8900.1 policy is also likely being rewritten

because the FAA wants to bar me from having ANY possibility of getting

ANY approval to CONTINUE TO DO WHAT I’VE DONE EFFECTIVELY,

SECURELY, EFFICIENTLY, AND OBJECTIVELY FOR A LONG, LONG TIME. Any

FAA official rewriting policy to avoid answering to the public, including their

own DADES, should be terminated on the spot. Congress, based on the past,

most likely would concur.]

The FAA has not been able to explain in writing why they are not answering

questions or if policy is being rewritten. They simply choose not to

communicate for the record. What is the harm in writing, “Mr. Morris,

regarding your questions, they may become moot in the near future due to

policy changes, hence the reason for not directly granting your requests for

approval per FAA specialist, etc..” Is that difficult? Is that against policy?

D. Be Employed in a Part 65 Dispatcher Course. Be employed as an instructor,

owner, or contractor of an approved Title 14 of the Code of Federal Regulations (14

CFR) part 65 dispatcher course in his/her district unless approved by the FAA

specialist.

[We DO NOT find the above paragraph fair and reasonable for DADEs,

affiliated with a large school with 15-30+ graduates required by airlines to

return to work in a matter of a few days. It is also contrary to public

interest and damaging to small business owners. In addition to all

aforementioned bold notes, how is nullifying a DADE currently leading the

world among active DADEs in FAA AD exams conducted helping the public

interest or relieving local FSDO/CMO’s future workload? If a DADE is also an

owner and has been proven to administer substandard exams, then he/she

must be advised, observed, and perhaps have their DADE authority revoked

or suspended until further notice. If a DADE is also an owner and has

repeatedly proven his ability to administer excellent exams, produce

outstanding graduates and been virtually flawless in their submission of

FAA certification paperwork, then he/she should be allowed to continue

operating as normal without restriction or penalty. We believe policy was

written based on vendetta or unverified allegations of suspicious testing

activity. To corral the innocent with the guilty and effectively remove

inspector authority (“if approved by the FAA Specialist”), is just lazy policy.

Any inspector even slightly suspicious of my objectivity as a course operator

or owner, should have contacted my local office, sought records of students

failed, or who did not even graduate. Why would I apparently be objective,

as a business owner, regarding course graduation rate, but not regarding

exam pass rates? I RETURN $$$ when people discontinue the course per the

pro rata refund policy. I DO NOT REFUND $$ for failing a practical exam.

E. Test Non_Graduated Applicants. Conduct tests for applicants who have not

graduated from an approved 14 CFR part 65 dispatcher course, unless approved by

the specialist.
18

[We find the above paragraph fair and reasonable for all types of DADEs,

whether operating individually or in conjunction with a school, ALTHOUGH

little or no thought appears to have been given for the typical ATP or other

qualified airmen who meets all knowledge and experience requirements for

a Dispatcher practical examination. Since no DADE can examine this

applicant per NEW 8900.1 policy, the responsibility falls on the district

office/CMO, designated to conduct exams by the respective regional office.

According to all local offices I have dealt with in the past and present, they

prefer not to perform this task due to their demanding workload; however,

they appear reluctant to even admit their ability to administer exams. Any

pilot or other qualified individual who possesses a valid Aircraft Dispatcher

(ADX) Knowledge Test Airmen report along with FAR 65.57 experience

requirements MUST BE EXAMINED BY AN FAA INSPECTOR – NOT A DADE. If

these people are told they must wait weeks or months for an exam (as I

was recently informed), then they will be writing the FAA headquarters,

AFS-1, the Administrator, or Congress. Personally, I do not ever give exams

to applicants unless they passed SHEFFIELD’s FAA certification course. We

tried many years ago only to discover that most non-Sheffield “graduates”

or “qualified applicants” were less than qualified to pass our exam;

therefore, we could not care less about this DADE restriction. The local

FSDO/CMOs, however, should care. Those are the offices that I will now

refer all applicants to for testing that are not graduates of a Part 65 course.

It is not my intent to burden my local office, but I cannot lie to these

applicants seeking examiners – we receive 1-2 calls every 2-3 weeks

regarding this matter. I hope all Dispatch ASIs are prepared.]

Please see Appendix N regarding the local office’ stance of large airline

groups of FAR Part 65.57 applicants. A sincere question from me was not

only misunderstood, but then resulted in a threat toward me.

There seems to be an ignorance of ASIs in their ability to distinguish

between Part 121 air carriers they are accustomed to overseeing and the

Part 65 certification schools that they were recently assigned to oversee as

a new task. We have been asked questions that have nothing to do with

Part 65. “Are your Jeppesen charts up to date?” We’re not flying the line –

they are current anyway, and most schools can’t even afford a Jeppesen

subscription which we have; therefore, we DO have access to current

Jeppesen charts, but are NOT required to use such a format in a certification

class. We DO because that is what real-life presents most graduates after

leaving here. (Many more examples within Appendices.

“I’m not experienced at this task” - our FAA Specialist (verbally at initial

meeting).

It also appears that waivers have been granted allowing untrained ASIs to

perform a new task; i.e. train/oversee DADES and Part 65 schools. The FAA

can waive policy to help themselves due to an ASI shortage or lack of

Federal funds, but the small business owner is not afforded any waivers or

any approvals AS ALLOWED IN CURRENT POLICY.
19

F. Conduct Competency Checks. Conduct competency checks for a 14 CFR part

121 Dispatcher Training Program, unless employed as an Air Transportation

supervisor or qualified ground instructor for that operator.

[We find the above paragraph fair and reasonable for all types of DADEs,

whether operating individually or in conjunction with a school.]

New Order 8900.1 Policy

Basically, this document now severely restricts how designated examiners are to

conduct exams. I heard the following from a few FAA personnel “Order 8900.1 is just

guidance for inspectors.” Wrong – it is more than that – it dictates specific DADEs

qualifications, test procedures, etc.. and often conflicts with the Practical Test

Standards Guide, which poses another issue regarding statements from the FAA such

as “there is only one test standard.” Some of the content appears to be written for

the less busy examiner working with only a few individuals every month or two, and

NOT for a large certification school working with 15-35 graduates every 5-8 weeks.

Our school falls under the latter category, but is under the oversight of an

understaffed and apparently overworked office of inspectors too busy with air carrier

oversight. There have been two missed opportunities for the oversight by the local

CMO of our practical examinations, the last being from February 6-10, 2010, for 10-

12 hours each day - hours due to large number of graduates coupled with illogical

time-wasting less secure 8900.1 exam policy.

“Why is CMO-29 overseeing you? They are air carrier – that’s why I was

removed from you.”

Inspector via phone call with Sheffield School, 2009.

Objectivity (as owners, directors, instructors)

Are Part 141/142 schools more objective by the allowance of staff examiners, than

Part 65 school operators? If policy is to change, as rumored, then apparently, ALL

schools (including Part 141/142) must change examiner-on-staff policy or it will be

seen as disparate treatment. See Appendix P for our complete statement regarding

the rumored-to-be complete prohibition of dispatch staff examiners.

February 2, 2010, 3:00pm at offices of Sheffield School:

A student received an oral check to see if a signoff for the AD practical exam would occur. He

failed. He also possesses a Commercial Pilot certificate along with other experience, but it did

not matter – he failed. I, Eric Morris, as an owner, could have been unethical for the 1st time

in my life, and ordered my instructor to sign him off, then directed my DADE to give him a

freebie certificate in order to make his airline, a Sheffield customer, happy. Well, I did not,

and I never have done such a thing – a 62-year reputation worldwide is typically built on

ethics, quality, and customer service, with no compromises. We do not operate unethically and

never have. Will the airline be upset and take their business elsewhere? I do not know and do

not care. Other students exit earlier in the course or do not come close to passing the course,

and therefore, receive no FAA practical exam. Why would I, as an owner now, after all the

aforementioned grief, decide to pamper my graduates through their exams? The local FAA is

supposed to have all of this on record to verify ANY and ALL claims made by me. More

students drop our course or fail before a practical exam, than pass other schools. HOW IS

THAT BEING UNOBJECTIVE AS AN OWNER?? Why fail anybody on the practical exam? Why not

sign off everyone for the exam, make everyone happy, and increase profits? Those operators

are the types the FAA should target - not the oldest most reputable dispatcher school in the

world.
20

Lack of customer service towards DADEs

Since October 2009, when the FAA decided to enforce policy that was not previously

enforced under the concept of the Dispatch ASI, I have been inundated with

inconsistent information, bad information, position-changing information from all

levels of the FAA and it has stymied my productivity and affected my small business,

established in 1948.

The FAA appears to be damning the people who have taken up the task to assist

them as DADEs. By authoring policy restricting DADE activity due to the indiscretions

of a few, you are in essence lumping the good with the bad, and handcuffing the

most experienced and busiest examiners in the world – Sheffield’s DADEs. By

continuing this agenda, you are not only harming the DADE program, but the District

and Certificate Management offices who will now be tasked with performing DADE

activities, or in other words – one of their responsibilities as designated by their

respective Regional Office. To act as a DADE is a privilege – I know; however, it

appears that the authors of Order 8900.1, all of whom have virtually no experience

operating a Part 65 School and/or have given few, if any, FAA Aircraft Dispatcher

practical examinations to large groups of Part 65 school graduates over consecutive

days, believe it is their job to severely restrict the testing activities of examiners who

have been tasked with doing the FAA’s certification work because the inspectors are

overloaded, have no time, and/or have no resources to hire additional inspectors.

To be clear, I make ZERO money as a DADE. I perform the task in the interest of the

public and to assist my local FAA office, which have never given me a difficult time,

until recently.

CMO-29

To summarize, I am working with an inexperienced (with FAR Part 65

schools oversight) office, with ever-changing positions and directives, who

will not approve parts of Order 8900.1 as approved by the FAA Specialist to

assist me, will not seek outside DADEs applicants to train and approve to

assist me, and will not give the FAA exams themselves to assist me. They

also will not efficiently and effectively answer questions that are not in their

self-interest. When combined with threats, insults, classroom disruption

(Appendix O) by the FAA, an unsalvageable relationship between my school

and the local FAA office has developed.

My local office seems to have difficulty answering my questions unless prompted

multiple times by the Southern Regional office, or me and continues to be reticent in

replying to our needs and inquiries. Often-changing CMO-29 management appears

to be in a state of flux or confusion. I mailed a copy of my petition to former CMO-29

Manager, with a request to send me an email confirming receipt. He

did not – I was told, “he only replies by certified mail” to “he’s retiring” to “send me

the email to me and I’ll forward to him, but he’s retired.”

I sent an email asking for a list of INSPECTORS who are authorized to conduct

Aircraft Dispatcher exams, with a statement that I DO NOT NEED A DADE LIST. The

Southern Region prompted CMO-29 to answer (following December 21, 2009 email

to from me). Naturally, CMO-29 replied with a vague reference to

“limited number of inspectors...” along with, of course, a DADE list.
21

I can try to accommodate their recommendations and contact the closest DADEs

possible to my school’s location. I emailed the FAA specialist (email on

January 29, 2010) for the email addresses of 2 DADEs he oversees, to expedite

communication, only to receive no answer. Other details are found throughout this

report and in the Appendices. This was an inspector who we actually assisted on

another matter recently, and very quickly, so I assume he was since directed not to

assist us.

Regarding policy, the CMO’s “I/We don’t write policy” statements lose their luster

after a while – they do not appear concerned with my workload and subsequently

their potential workload. It took a minor battle to have the CMO office finally admit

that was not only the FAA Specialist for Brett Bories and myself, as

DADEs, but also the FAA specialist for the school. As a FAA specialist, he has the

authority to make decisions independent of upper AFS management. That authority

has yet to be used, apparently out of some fear of wrongdoing or because of AFS200/220 edicts. I do not believe it is my job to point out to FAA offices what a

particular person’s authority is so that he/she can logically apply it to assist my

school or myself. I also do not enjoy taking the Southern Regional office’s time to

have them force an official answer from a district office.

During a phone call on January 29, 2010, with our FAA specialist, 

informed me that my “staggered exams” request (Appendix L), which is currently in

the Order 8900.1 policy, was not approved; however, he waffled on answers to my

questions about the so-called “denial.” He disregarded my workload concern and

FATIGUE issues (Appendices L/M) with an insulting statement, and launched a

veiled threat during an answer to a sincere question. See (Appendix N) for all

details regarding this phone conversation. He told me on the phone that I should

determine if my school would require outside DADEs, and if so, to use those already

approved even if out of district, out of county, and even as far as Orlando, to assist

me. If no DADEs could assist me, he said, only then would he solicit for more DADEs.

At that point, Mr. Miles was emailed (to no avail), for DADE email contact assistance

– still no answer received, no “out of office” reply, only silence. I simply wanted to

inquire whether these DADEs can assist me, and how often. Email is most efficient.

So it appears to me that the CMO-29 office now questions my motives for seeking

DADE contact information. This general distrust of each other is why we, as

DADES, and as a school, must request a different inspection office. Previous

inspectors should be contacted as to what type of relationship existed with

Sheffield School in the past. Whether acting as a DADE or course operator,

I’ve never had to endure incessant abuse, ignorance, and harassment.

Neither has Sheffield School of Aeronautics, established in 1948.

On Monday, February 1, 2010, the frontline manager of CMO-29 telephoned our

school. He was told by an assistant that email is preferred, and was offered my email

address. He has not emailed yet; therefore, we believe it was likely a threat-planned

call since the last call went poorly with Mr. That phone call of January 29,

2010, which included insults toward me, was followed by an email from me to Mr.

 cc’d to the managers, admonishing him from making derogatory comments

regarding my workload.

This office may still be upset that I pushed for an answer to the following question:

Who oversees Sheffield School officially? An FAA link indicated (and likely still

indicates) as our POI. Mr. denied being our POI. So at one

point, we had no letter from CMO-29 as to who oversees Sheffield SCHOOL, in
22

addition to DADE oversight, and nobody claiming to do so. I’m unsure why seeking

these answers upsets people. Perhaps the office should understand that when I

spend 1-2 hours attempting to determine which higher office to seek assistance from

and who directly to email, I lose time and money.

Recent exam schedule/local FAA office

Recently, I prepared the upcoming FAA practical exam schedule including the time

blocks reserved for each day of testing – see Appendix I. Based on the new policy

within the Order 8900.1, I and one fellow DADE of Sheffield School of Aeronautics

were forced to work 5 consecutive 11-12+ hour days, that could EASILY have been

reduced to less than 10 hours per day with a simple, more secure authorization

allowing the simultaneous testing of the written portion of the practical exercise,

specifically, the flight plan portion. See Appendix J for an example of a more test

secure, efficient, less time-consuming schedule - a method that has been proven

to work according to the FAA – Appendix K. It is unreasonable to change policy

which affects my school the most, without any allegations of impropriety, yet

NOBODY WITHIN THE LOCAL CMO OR AFS-200 OR AFS-220 is even willing

to address my concern or reply to me as to the reasons preventing its

approval, or why it was authored in the first place. As a long-time examiner,

currently leading the world in FAA Aircraft Dispatcher examinations, I

expected more collaboration, and advice. Our recent class had approximately 20

graduates – past sessions have reached over 35 (double our current average load)

when simultaneous classes have been held. The future classes, once the economy

recovers, will reach those levels again for our institution. Therefore, for the future,

do you feel that 10 consecutive 12+ hour days is fair and reasonable? Is this

the official stance of the FAA? To force large schools and their DADEs into a

tiring exam schedule based on untested policy? All for the purpose of

HELPING leverage the FAA’s workload?!

If the FAA response, exemplified by our local CMO, is simply to “add more DADES”,

that idea has been considered, but they do not offer a long-term solution to this

problem – details are within this report and Appendices. Seeking assistance from the

local FAA office appears to be out of the question based on the cumulative

statements from them. (See Appendix N and below.) This also does not solve the

problem effectively if my associate or me either retire, are summoned for jury duty,

must instruct a class due to instructor issue/sickness, or become ill or incapacitated.

Who will give these exams in a timely manner based on current policy within Order

8900.1? Too many variables can adversely affect the testing schedule if prolonged by

50% or more, which is what the new policy produces at Sheffield School. The CMO29 office does not feel the need for a backup plan or to ask upper offices for

assistance on our behalf to revisit Order 8900.1 policy. The CMO-29 office has

verbally said “we cannot do exams.” This verbal statement, of course, will be denied,

but it occurred multiple times during meetings in 2009 with ASI It

also contradicts what the Southern Region apparently designated the CMO-29 office

to do. Asking outside DADES within a 20-30 mile vicinity to show up for long multiple

days poses many obstacles including conflict of interest, and reliability – if there is

any personal history between myself or my school and another individual asked to

examine my students, obviously, that will not work. The local office also claimed that

I must seek assistance for outside DADE relief from as far away as Daytona Beach

and Orlando. I was told to use DADEs out of district, before they will even attempt to

locate local DADE applicants or assist us themselves, as designated per 8900.1

(regional office). First, many students are unable to drive to these remote locations

because many (including airlines) do not rent cars in order to save money. Second,
23

even if outside DADEs would travel to Sheffield, for 4-5 or more consecutive days,

what will they charge for test fees, transportation, and hotel? This simply is not

feasible, and is not a reasonable plan, all for the CMO-29 office to avoid doing some

work - whether administering exams themselves or soliciting the industry for a

LOCAL DADE, or two.

Mr. Bories and myself, work FULL weekends and holidays during practical

examinations in order to accommodate the large number of graduates to be

tested. If we are banned from giving exams, which outside DADEs or FAA

inspectors will guarantee Sheffield School that they will do exactly the

same? NONE!

To summarize why outside exam help is suspect:

• Our graduates work with a specific large airplane with a very advanced flight

plan format – this would not be able to be accommodated efficiently by

outside DADEs unfamiliar with our methods, which creates testing difficulties

for the applicant, and inequity among exams taken by students within the

same class.

• No outside DADE will arrive at our school at 5:30am to conduct practicals to

assist Asians or Europeans to make their flight. [Yes, we have a large

international student demographic, and yes, it has happened.]

• Will they show up for 5-10 consecutive days, including full weekends and

most holidays when we need them? No.

• Paying outside DADEs may also be a problem for students with little extra

money, who were expecting to be examined from a Sheffield School DADE, as

we have for decades.

• Outside DADEs must be acceptable to this owner/operators of the school. It is

unacceptable to have outside DADEs who were a past competitor or are a

current business competitor, to give exams. School feedback from a DADE*

could be suspicious or vindictive.

*8900.1 - 13-207 RECURRENT TRAINING. The FAA specialist is

responsible for providing the DADE with recurrent training every 12 months.

The recurrent training will include at least the following topics:

· DADE’s roles and responsibilities,

· Paperwork discrepancies,

· Applicable changes to 14 CFR,

· New FAA policy and procedures,

· Conducting the practical test,

· Review and updating test scenarios,

· Feedback on approved 14 CFR part 65 dispatch courses, and

· Foreign student applicants.

By the way, the bold statement above appears to contradict FAR Part 183 regarding

the responsibilities of the DADE. Evaluating Part 65 courses via “feedback” exceeds

the regulatory scope of FAR 183.1 – “for the purpose of....” Also, Order 8080.6

violates FAR 183.25(f)(1) – “written.”
24

If a school’s renewal is partially based on DADEs’ 1st take pass rates, how is this fair

to a small business? If your reply is that DADEs must be found to be trustworthy,

etc.., then you might as well rescind all DADE-restricting policy as it now stands,

because it is obviously based on a general distrust of DADEs, whether or not they are

owners, instructors, etc.. Policy should be written to capture the mal-offenders, but

NOT severely hamper ALL small business owners and other examiners.

Aside from lack of reliability, lack of familiarity with Sheffield’s course airplane, and

other factors, outside poorly-trained or ineffective DADEs is not an option. Locating

DADE candidates at local airlines may also be interesting – one local airline with

multiple FAA violations enlisted Sheffield for a “refresher” type of dispatcher training.

I have no interest in having some of these locals who could NOT determine the

ceiling and visibility on a TAF to become an examiner for my students. For one, I

believe the graduate should not be more knowledgeable than the examiner. I work

full weekends for examinations, and most holidays. For me to find an outside DADE

for assistance and to determine reliability quotient, I’ll need to quiz them on their

ability to work long days, full weekends, and most holidays – NOBODY WILL AGREE

TO THAT, which pushes for a local FAA office to NOT limit the available DADEs in an

area. There MUST be a backup plan – telling 12 Germans, Brits, Asians, or Americans

that, “well, I can’t examine you because I’m an owner, my other DADE had to step in

to teach a portion of the certification course (which now disqualifies him from

conducting exams), and of the 2 outside DADEs in the next county, one is attending

church, or doesn’t feel like coming in on Sunday due to football while the other guy

is in Europe on vacation.” This will not sit well with airlines trying to get their

employees back home for airline training in less than a week.

Planning ahead and warning all future applicants IS BEING TAKEN CARE OF BY US

already, but there is NO SOLUTION FOR VERY REAL CONTINGENCIES THAT

SHALL ARISE. Nobody wants to believe this fact! When the AFS-200 writes back

with “no justification for a rewrite” without addressing specific questions we posed,

or AFS-220 says “we can’t help you – AFS-200 can” and have ZERO CONCERN FOR

MY QUESTIONS, then the local office replies to applicants’ exam delays due to new

test policy restrictions with “it’s their problem”, or accuse me of “wanting my cake

and eat it too”, it is appalling, does not work in the public interest, and does not

exemplify a harmonious working relationship. I know how to operate a school with

many applicants, and have experience with airline managers - who do not want to

hear from me that their 5-week class is now 7-8 weeks due to “policy.”

An AFS-900 Assistant Manager is sending a 2nd family member through my

course. Should they be warned that it might take 6-7 weeks before

certification?

NOBODY WITHIN AFS-200, AFS-220, OR ANY LOCAL OFFICE EVER APPROACHED ME

FOR ANY ADVICE OR CONCERN OR INPUT REGARDING THE ORDER 8900.1 POLICY.

To solicit no assistance or opinion whatsoever does not quite fit Mr. Babbit’s words

below to Congress in December, 2009:

“There is no substitute for learning at the hands of someone who has

already been there.”

Again, we examine anywhere from 15-35+ applicants every 5-7 weeks, 6-7

times per year. Check our class pictures online over the past 10 years as
25

proof. This cannot be efficiently accomplished per current policy with 2

DADEs for larger classes. This is virtually IMPOSSIBLE if one of Sheffield’s

DADEs is not renewed, dies, becomes ill, or resigns.

Fatigue:

I realize that airlines which are governed by the FAA are exempt from the Fair Labor

Standards Act of 1938; however, we are all aware of duty-time limitations and the

effects of fatigue on mental alertness and effectiveness, whether piloting an airplane

or planning the operation of a flight or conducting certification examinations.

Unfortunately, in the case of examiner fatigue, this does not seem to be an issue

with the FAA, particularly my local office as seen in the Appendix N. If 8900.1 policy

effectively elongates my testing day AND halves my exam limit per day, then my

overall workload doubles, complete test security for the flight plan portion is virtually

non-existent, and I no longer have the ability to help my fellow DADE if he becomes

incapacitated or unavailable for some reason, which has happened. No outside DADE

will come in a 6:00am on a Sunday to sub for an ailing examiner to help an applicant

meet their flight by later afternoon. If Mr. Bories has a throat infection or some other

issue arises for him or me, PER CURRENT 8900.1 POLICY, neither DADE can help the

other, and conduct 3 or 4 exams instead of 2, or have 3-4 students sit in 4 corners

of a classroom with 4 different flight plans while monitored to save 9 HOURS of work

in a day – IT HAS HAPPENED!

Perhaps outside DADE relief can work but...

I have no problem if Sheffield graduates who were trustworthy, excellent students,

contact us or the FAA directly for advice regarding becoming a DADE, then to let the

local office decide if they qualify. Citing conflict of interest against these particular

DADE candidates is invalid since the FAA already permits ASIs to oversee their alma

mater (as in our case and which I oppose), and dispatch ASIs who oversee schools

operated by their former co-workers or bosses, something I also disagree with. If the

DADE candidate can successfully pass initial training provided by our FAA specialist,

and poses no conflict of interest, then I do not object. Sheffield graduates are

permitted free refresher training anyway, so it would be the perfect solution to

bringing someone up to speed on our airplane runway analysis and performance,

instead of having on outside person bumble through an inefficient exam, assuming

they show up. I still believe this will not be a simple task since our FAA specialist who

(understandably) claims to be very busy with other tasks, who is (understandably)

frequently out of the office based on automated email replies I receive, appears to

have little time to perform these training DADE tasks. Locating legitimate DADEs in a

time-efficient manner to assist us is nice in theory, but I would need more than a few

to use since not all of them will be ready, willing, and able to conduct 5-10

consecutive days of 10-12+ hours of exams, based on new restrictive policy.

What if outside DADEs are employed by an airline. Will they be able to assist us for

3, 4, 5+ days for 5-10 hours or more each day? If so, how is that possible without

being on vacation or on a leave of absence?

What if an outside DADE is incompetent or resigns suddenly? It won’t affect a small

school in Arizona, which had one DADE quit, and is now retraining another

DADE, according to a February 1, 2010 email from them to me. But that WOULD

AFFECT SHEFFIELD, with 15-25 or more students 6 times every year.
26

The CMO overseeing me, as a DADE:

1. Does not see a problem.

2. Won’t conduct exams.

3. Won’t solicit for new DADEs.

Am I to accept this as a DADE leveraging FAA workload? Am I now forced to ask

higher offices to take action against inaction? As of a few days ago (and weeks

AFTER this report was initiated), not only have Mr. Bories and myself been

deleted from the FAA’s database, but also the two closest outside DADEs.

What is going on now??

Simple solution to this matter:

Allow Sheffield School to conduct it’s practical examinations as it has for the past 3+

decades, as authorized, observed, approved, and reported on by every local

inspector including one Dispatch ASI (See Appendix). This includes inspectors

providing oversight of Sheffield School AFTER the 8900.1 rewrite date of September

20, 2008, and prior to our new ASI/FAA specialist. Our pre-8900.1 methodology was

more efficient and more test secure than what we are currently being forced to do.

The local CMO-29 office refuses to acknowledge or accept this logic – their continual

stance is “we don’t write policy.” Unfortunately, I believe very few district offices and

their ASIs fully realize that DADEs exist to help them, TO LEVERAGE THEIR

WORKLOAD, to quote the FAA. Local ASIs are more than welcome to administer

these exams as prescribed per Order 8900.1. How many of these ASIs already have

their Flight Plan scenarios prepared?

Appendices M & N detail questionable issues and statements from ASI 

Southern Regional Office – only bright spot so far

Although the Southern Regional office has an acting manager, they referred my

queries to an inspector with very little Part 65 experience, in his own words, to try to

answer my questions that the local office avoided. He helped, but could not directly

answer my question “Which district offices in South Florida have been designated to

administer FAA Aircraft Dispatcher exams?” Mr. provided a name within a

single office, which is better than nothing, but it took two emails over 4 days, to

prompt a response from CMO-29 to finally admit “there are a limited number of

inspectors” within the office able to give exams. Again, they provided no names, yet

provided a list of DADEs for me – a list that I earlier told them was NOT needed. I

know the list. I have the list already. I am ON the list.

On February 12, 2010, I sent Mr. an email requesting different oversight for

myself, as a DADE, as well as the school I operate. On February 16, 2010, I emailed

Mr. a copy of my response (Appendix Q) to a certified letter sent to me from

 of CMO-29. (See Appendices N & Q for specific reasons for my

request.)
27

AFS-200

We also wonder why most ASIs typically do not reply to, or acknowledge most

questions or concerns emailed by us in the past. Are they too busy? Have they been

gag-ordered? Based on their lack of replies, I assume that the FAA does not care

about:

• Schools guaranteeing certification and jobs,

• Open note/book online tests,

• Unqualified Nigerians and others fleeing one school for another after

failure, including related visa issues (which nowadays poses security

questions.)

I received NO RESPONSE, other than the private emails from a few inspectors

affirming that my concern is valid, regarding these issues. At least some of the prePerry era would have responded directly and addressed the issues – not anymore.

From his era and thereafter, silence seems to be the preferred method of response.

AFS-220/AFS-200

Both AFS-200 and AFS-220 seem to excel at referrals and denials, but prefer not to

answer or even reply to apparently difficult questions. Other schools have reported

to me that AFS-220 personnel do not reply to their emails or return phone calls. I

suggest that all course operators be contacted to confirm a potential

universal problem.

It appears to us that this Order 8900.1 policy change has either been based on the

typical DADE who may conduct a small number of individual exams that are spread

out throughout the year, not a large Part 65 School who graduates 15-25, or

more students every 5-6 weeks, even during a global recession. If the latter

is not the case, then this policy rewrite, based on how it was conducted, and how it

is being enforced, including the non-replies to questions posed, appears to be

vendetta-based towards Sheffield School of Aeronautics. This would be ironic since

we were established in 1948, pre-date the FAA by 10 years, and have produced the

world’s most qualified dispatch graduates on a consistent basis for 62 CONSECUTIVE

years. The quality of customer service from nearly every CMO/AFS level has been

less than upfront and courteous. Especially ironic is the fact that Sheffield School was

sought early on for assistance in providing ASI course materials.

We firmly believe that the late Ted Perry, who had no affinity for Sheffield School,

has influenced current AFS-200/220 personnel. He likely influenced the Order 8900.1

policy contributors and others currently rewriting it now. Another 

statement in a 2009 meeting to the effect of “policy originated when Ted Perry was

around” seems to validate this claim.

We are now calling for an investigation into the reasons for Mr. Perry’s apparent

termination or resignation from his position. If he assisted, contributed, or initiated

the authoring of Order 8900.1, in addition to already having proven his dislike for

Sheffield School, I believe the validity of Order 8900.1, as it pertains to DADEs, may

be in question based on reasons for his dismissal, if termination or resignation,

occurred. “Mr. Perry is can no longer be contacted...” is not an acceptable response

because the Order, 8900.1, is alive.
28

Petition

Included in this mailed packet (Appendices F/G) is our nearly 5,000-word request

mailed to AFS-200, dated November 13, 2009, for an exemption to applicable DADE

policy based on previous FAA local approvals, already-existing exemptions, and

inspections (inspection report included) with a request for any reasons for denial

AND a request for future coordination of future policy in order to work in harmony

with the FAA.

Our petition was denied (Appendix H) by John S. Duncan, Manager Air Transport

Division, on December 16, 2009 with the general reason stated as “no substantive

reasons exist to change current policy.” Our 2nd item in the request was completely

disregarded. Additionally, I was emailed a consolation-type email by Leo Hollis of

AFS-220, referring me to 14 CFR Part 11 to address processes available to request

exemptions from specific regulations; unfortunately, 14 CFR Part 11 has nothing to

do with policy exemption rewrites or requests, which is what we were seeking. I

replied with a “thank you, I don’t agree but will follow” answer. Unfortunately, my

questions asked of Mr. Hollis (AFS-220) and Mr. Kirkland (AFS-200) on December

10, 2009 and followed up on January 4, 2010 have gone unanswered, which is a

contributing reason for this appeal to you. The questions were regarding the 2

or 3 paragraphs which include the phrase “if approved by the (FAA) Specialist.” The

questions arose from my local FAA specialist’s refusal to act as the specialist to grant

us certain approvals, based on the wording directly in the Order 8900.1.

The 3 questions are below. They have not been answered or replied to....twice.

I question this lack of customer service, regardless of whether my questions are

being debated by a legal team or not. Common courtesy would be to acknowledge

the email with a simple statement claiming that “we are seeking an answer.” If

questions are not being answered based on future pending policy changes

to eventually nullify my questions, then this will open an entirely different

can of worms. We hope that is not the case.

---From: Eric Morris <morris@sheffield.com>

Date: Thu, 10 Dec 2009 18:12:08 -0500

To: <Greg.Kirkland@faa.gov>, <Leo.D.Hollis@faa.gov>

Subject: Sheffield School question

Mr. Kirkland and/or Mr. Hollis,

My apologies, but I’m unsure who to address this to. I appreciate any help you can

offer me.

Q1: Who is the official FAA Specialist for the DADE program under/used by/approved

for Sheffield School of Aeronautics? I do not require a citation of 8900.1 CHG 35 Vol.

13, Chapter 3, Section 1, Paragraph 13-140 – I know the definition/description. The

issue is that my local CMO prefers not to confirm the answer, and I’m seeking an

answer in writing.

Q2: If my assigned ASI is in fact, the FAA Specialist, may that person approve on

his/her own, per the wording “if approved by the specialist” or “approved by the FAA

specialist”, without consultation or coordination with AFS-200, any

provisos/exceptions/exemptions, within 8900.1 CHG 35 Vol. 13, Chapter 3, Section 2,

Paragraph 13-175c and 13-175d, for the DADE(s) under their supervision?

Q3: If the answer is “no” to Q2, then what reference mandates that the FAA Specialist

shall never exercise such authority?
29

Thank you for your interest in aviation safety.

Best Regards,

Eric Morris

President

Sheffield School of Aeronautics (est. 1948)

---Date: Mon, 04 Jan 2010 12:38:33 -0500

To: <Greg.Kirkland@faa.gov>, <Leo.D.Hollis@faa.gov>

Subject: Sheffield School question - 2nd request

Mr. Kirkland and/or Mr. Hollis,

I am still seeking the answers (based on current policy) to Questions 2 & 3 below. The

local CMO was able to answer #1 in writing.

Thank you.

Eric Morris

President

Sheffield School of Aeronautics (est. 1948)

Q1: Who is the official FAA Specialist for the DADE program under/used by/approved

for Sheffield School of Aeronautics? I do not require a citation of 8900.1 CHG 35 Vol.

13, Chapter 3, Section 1, Paragraph 13-140 – I know the definition/description. The

issue is that my local CMO prefers not to confirm the answer, and I’m seeking an

answer in writing.

Q2: If my assigned ASI is in fact, the FAA Specialist, may that person approve on

his/her own, per the wording “if approved by the specialist” or “approved by the FAA

specialist”, without consultation or coordination with AFS-200, any

provisos/exceptions/exemptions, within 8900.1 CHG 35 Vol. 13, Chapter 3, Section 2,

Paragraph 13-175c and 13-175d, for the DADE(s) under their supervision?

Q3: If the answer is “no” to Q2, then what reference mandates that the FAA Specialist

shall never exercise such authority?

Thank you for your interest in aviation safety.

Best Regards,

Eric Morris

President

Sheffield School of Aeronautics (est. 1948)

We did not receive a reply when resent on January 4, 2010. That coupled

with statements made by our local inspector on Dec. 23, 2009 lead me to

believe that policy is being hurriedly rewritten to nullify any remaining

questions I, or others, may have and to further restrict our operation.
30

We sought assistance and relief

During our initial introduction and meeting in October 2009, with the assigned ASI of

CMO-29, we were informed of policy changes to be enforced. We presented our

objections and reasons for objections, and were simply met with “I don’t write

policy” from At a subsequent meeting, Mr. informed us that

he called Leo Hollis at AFS-220, who allegedly mentioned that there was no relief

allowed or something to that effect. We then sought a solution – exemption or

possible rewrite of policy which was submitted to AFS-220, who claimed that AFS200 was to be contacted instead. We did so on November 13, 2009. AFS-200 turned

down our request on December 16, 2009 without specific reasoning. Additionally, we

asked to be informed of future policy and hence FAA compliance with Order 8900.1,

Vol. 1, Chapter 3, Section 2, Par. 1-177. The latter was completely ignored and

not acknowledged or replied to. For that reason along with how the policy was

authored behind closed doors, with no understanding of WHY these policies required

a rewrite along with the fact that we, as DADEs were not consulted - (our local ASI

claimed “long-time DADEs were consulted in this rewrite”), we have come to the

conclusion that this action appears vendetta-based or ignorance-based, or both.

Additionally, Mr. who read our appeal, contacted AFS-220 or AFS-200, and

claimed part of our appeal’s statements were inaccurate. He told Mr. Bories and me

that he mentioned to AFS-200 that he “did not write AFS-220” asking about relief for

Sheffield. This is an early example of how stories change – he told 2 witnesses at

Sheffield School that he CALLED/phoned. Our appeal mentioned the word CALLED. I

don’t know if he forgot what he told us or made one of many future misstatements,

but if our denial from AFS-200 (John Duncan) was based on any input from

Mr. then there is a problem and I’m asking for another review. (see

Appendix H for AFS-200 denial letter.)

Also, RE: FAA Compliance with Order 8900.1, Volume 1, Chapter 3,

Section 2, Par. 1-177) – not addressed correctly.

We asked for the FAA to comply with Order 8900.1, Volume 1,

Chapter 3, Section 2, Par. 1-177, it’s own “Standards of

Professionalism for Flight Standards (AFS).” In the first paragraph in

the denial letter found within appendix H, Mr. Duncan states that I

asked for relief from YOUR OWN ETHICS AND CONDUCT CODES, which

makes no sense. This indicates that major portions of our original

requests in Appendices F & G were not even read or understood.

We are requesting an investigation into this matter, if our original 

requests for policy relief are not approved.
31

Regarding the authoring of Order 8900.1, were the following factors

considered? If so, how?

1. Who were the contributors to the DADE-related policy changes made to the Order

8900.1? “Contributors” means “names of individuals” or “names of individuals

within working groups.” “The FAA or the Administrator wrote it”, is not what I’m

asking.

2. Does Order 8900.1 rewrite account for large schools? [Appears to have been

produced based on isolated examiners giving limited number of exams.]

3. Consider how a small business would be affected?

4. Consideration toward the lack of a CMO backup plan? (I have sent a planned

practical exam schedule for 2010 totaling over 50 possible days. The math

speaks for itself.) If an instructor or DADE becomes ill or is unavailable, what

happens then? Are we to inform the 10-20 students, many of who have flights,

employer demands, and visa time limitations, to just “hang out an extra week or

3?”

5. Consider public interest? Were airlines trained by Sheffield School ever contacted

as to how this new policy would affect their airline initial training scheduling

requirements?

6. Was policy authored based on rumors verbally passed around inspector

conferences, emails, text messages, phone calls, etc..?

7. Was any consideration given to the ASI William Bonatti’s report of Sheffield

School? If it was disregarded and considered of no importance to the modus

operandi of Sheffield School, then why not? Was the report disseminated from

Ted Perry to any significant inspectors who were a part of the Order 8900.1

rewrite? If yes, to whom? If not, why not?

8. Was any consideration given to the airline industry and how it universally agrees

that Sheffield School sets the standard of Aircraft Dispatcher certification

training? [“Sheffield School is the platinum standard for dispatcher training” –

Dispatch ASI David Porter.] Why are quotes like these found in my email box and

online over the years, but now I supposedly compromise the integrity of practical

exam testing as an owner?

9. Any consideration based on statements or viewpoints from your own ASIs within

AFS-220, whether they are a Sheffield graduate or not? Is there a fear from AFS220 personnel to speak up in Sheffield’s defense? [Question arises from virtual

silence from many who know us personally and what our school represents, yet

will not apparently defend us or even answer us.]

10. Why the differences between the Practical Test Standards and Order 8900.1? Am

I to follow both including different procedures? Am I to disregard parts of the

8900.1 because of the statements within the PTS? Why are the authors of the

PTS and 8900.1 different groups? One is authored by AFS-200-220, the other

AFS-630. PTS is recommended to test takers and test givers as guidelines yet

how many applicants are even aware of the Order 8900.1, let alone the

differences between the 2 documents??
32

11. What were the reasons behind not contacting Sheffield School’s DADEs or other

“long-time DADEs” affected by the new policy? Sheffield DADEs were NOT

contacted, including Ron Morris (over 2500 exams), Leon Jansen (over 500

exams), Eric Morris (over 850 exams), and Brett Bories (over 300 exams).

12. What was the proposed plan for airlines that send groups for 4 or more to

Sheffield School (large schools), with strict policies on return trips within 2-3

days to begin airline basic indoctrination or initial training?

13. Were any questions raised as to why or how Sheffield, having overwhelmingly the

highest enrollment in history, would be affected?

14. Was any consideration given to contacting us with any alleged rumors,

complaints, or hearsay, in order to substantiate, verify, or confirm all claims?

15. Was the local district office ever contacted prior to the September 2008, Order

8900.1 rewrite, regarding complaints about Sheffield School’s testing

procedures? [If so, we received no information.]

16. Why wasn’t the local FAA office instructed to guide us regarding any upcoming

future policy changes? Specifically, before the appearance of a new untrained

ASI, and after the amendment date of 8900.1 CHG 35?

17. Was any consideration given towards the sickness, death, unavailability of a

DADE, and what the backup plan would be now that new policy effectively halved

our testing flexibility and doubled at a minimum, the time required to complete

examinations.

18. Was Sheffield’s local FAA office contacted regarding their historical DADE

requirements in formulating new policy?

19. Did anyone within the FAA consider the fact that Sheffield School once had 4

simultaneous DADES due the certification boom of the late 90’s and many other

recent years as well? Or that due to ADX testing requirements, we had to reduce

the DADES to 3, and eventually 2 due to retirement, sickness, and death? Did

anyone subpoena our historical exam logs from our district office to verify the

aforementioned, including that we currently spend 2-6 consecutive day periods

completing a multitude of graduates – and this is the time required BEFORE the

Order 8900-1 rewrite. Since that required time effectively doubles, and delays

the public’s return home, a greater need for relief by FAA offices to administer

exams is required.

20. Any consideration for the fatigue factor for DADEs of large schools – see our

“smaller class” exam schedule of 5 consecutive 12-hour days. [See Appendix.]

21. Anyone consider asking our local office for our DADE – practical exam passing

rate?

22. If so, or if hearsay spread that our pass rate exceeds 90%, was our local office

asked to supply the class graduation pass/fail rates, which we indicate by listing

EVERY student who begins our course, but does not complete the course within

the specific reason provided? Provided immediately following a class – we do not
33

wait 12 months to report it. These are lists of students who do not even meet the

qualifications to take the FAA practical examination.

23. In case school objectivity was questioned, was any consideration given to the fact

that Sheffield signs off a lower percentage than probably every other school in

the country – were those numbers requested from each school’s district office,

compared, analyzed, and studied for trends prior to policy rewrite?

24. Any consideration for increased workload among district offices designated to

administer practical examinations when DADEs are unavailable or resign?

25. Any consideration given that regional offices may be unaware that they SHALL be

required to designate a district office to conduct examinations, and therefore,

complete all FAA certification paperwork?

26. Any consideration to the fact that although being a DADE is a privilege, and not a

right, this does not equate to requiring DADEs to beg for assistance or relief from

untested policy, as I have been for the past 3 months? As we all know, the

concept of the DADE is to assist the FAA local offices. Current AFS-220 and CMO29 behavior is to treat us like they’re doing us a favor, not the other way around.

27. Any consideration given to what each DADE, whether an owner or not, charges

for each exam? Any consideration given towards each DADE’s motivation? Is it

for profit or the public interest? [Sheffield charges $0 for a practical exam.]

28. Any consideration as to how the policy affects owners who have provided over

800+ practical examinations within a school with a history of conducting over 4-

5000 exams, and what the quality of the graduates has consistently been?

29. Any consideration given towards interviewing ASIs or others with any affiliation

with Sheffield School? Were comments positive or negative? And were any

negative comments, if any, allowed to stand or was the school or DADE allowed

to defend themselves?

30. Any consideration given towards how policy will affect one small business many

more times than others and what that perception may lead to?

31. Any consideration given to extra required workload for inspectors needing to

train, authorize, and oversee multiple DADES required to assist large schools with

current DADEs who will eventually be phased out due to policy restrictions

regarding ownership, employees, etc?

32. Any consideration given for the fact that many, if not all inspectors overseeing

schools or DADEs have little or no experience overseeing Part 65 schools. [We

can provide specific examples of ignorance upon request.]

33. Any consideration for a school’s longevity, DADE error paperwork rate, FAA

problems?

34. Anyone subpoena or directly question ASIs regarding rumors prior to authoring

new policy?
34

35. Did any previous Sheffield-initiated FOIA requests affect the development of

certain procedures aimed at large schools, owners of schools, or schools

authorized to conduct simultaneous exams? Could such actions be construed?

36. Any policy considered for schools advertising 100% pass rates, 100% job

placement rates? [It appears that DADEs and ASIs testing such “mills” should be

observed and reviewed.]

37. Consideration towards the greatly reduced practical exam phase I (flight plan)

test security by disallowing a controlled observation of the conduct of

simultaneous flight plans with 3-6 different scenarios all begun at the same time

and ended at the same time, with no chance for applicants to discuss destination

alternate selections, burn values, no-go questions asked, etc.. Based on newly

enforced policy, giving 1 flight plan at a time, with the other 20-25 applicants

simply waiting in the wings, whether outside the office building, back in student

housing, or hotels, any information may be communicated to others directly or

electronically. Since I can only advise, recommend, and warn against cheating, I

do NOT have the ability to violate constitutional amendments and ban free

speech, etc.. Our previous more secure test methods – REQUIRED for large

classes - seemed to suit all previous inspectors, including Mr. Bonatti – see

report Appendix K. Please explain how the FAA sees equivalent or improved test

security with the new policy, requiring each flight plan conducted separately and

at different times and days.

38. Any consideration towards the apparent non-uniform application of authority

regarding the phrase “if approved by the FAA specialist?” [FAA specialists who

fear application of the phrase “if approved by the FAA specialist.”] Why do certain

ASIs fear decision-making based on policy? Why can’t AFS-200/AFS-220 answer

(or even respond to) my questions posed on Dec. 10, 2009 and followed up on

January 4, 2010 (posted earlier.)?

39. Is there a policy that permits these inspectors to avoid questions while rewriting

policy? And if policy is NOT being rewritten as you read this, why did 

 ASI at CMO-29 verbally state to me on December 23, 2009 at a meeting

in my office that certain rules are being rewritten such as instructor restrictions

to testing applicants, etc.?

40. Any understanding that U.S.-based graduates, who may be pushed to the end of

a long practical exam schedule due to international student flight commitments

for airlines, will be unwilling to wait 2 weeks for an oral exam, choose to go

home, only to repeatedly contact the nearest ASI/district office for assistance?

[For those individuals/airlines qualifying for an exam per FAR Part 65.57, I have

no choice but to publish all ASI/CMO contact names and addresses for all

students to contact for an exam if they are not pleased with Sheffield’s

4-8+ day plans, if policy is not repaired.]

41. Referring to #40, what happens if a local FAA office (not designated to provide

exams) with no DADEs available is contacted for an FAA AD exam? (See

Appendix B email). Will that office contact the applicable Regional office to

execute an emergency designation. If all of this cannot be accomplished within

the 90-day time frame following the graduation certificate date from our school,

is Sheffield now required to force this student to return to Sheffield for a reevaluation to receive a 30-day extension to their graduation certificate?
35

42. Any consideration made for the number of international students enrolled at large

schools who attend on a time-limited student visa?

43. How many of the authors or contributors of the FAA Order 8900.1 rewrite/chg

have actually given FAA practical exams to FAR Part 65 certification school

graduates? I’m sure it pales in comparison to what Sheffield’s DADEs have

historically given (over 4,500 exams). Have any inspectors ever operated a Part

65 school and understand what the effects of this rewrite would be to an FAAapproved institution that pre-dates the FAA by 10 years - a company that has

never conducted operations unethically, who has only reaped the praises of many

of your own inspectors, and were NEVER consulted regarding any of our

experiences, recommendations, etc.. [This was written with either a lack of

understanding of the effects to Sheffield School, the most populous dispatch

certification school in the world, or with vendetta in mind.]

44. Was the economic impact on extremely busy small businesses by new policy

studied?

45. Which ASIs have conducted over 10-12 hours of practical exams in a single day?

And if any, for how many consecutive days? Have any current ASIs reprimanded

airlines working dispatchers over 10 hours per day? If so, then why are DADEs’

fatigue issues (forced upon by new policy) being ignored or discounted?

46. Does the public know that DADEs can charge exam fees, but ASIs cannot charge,

(to the best of my knowledge)? They may learn that the ASIs are limited yet will

knock on their door first for an exam, especially in today’s economy.

47. Was any consideration given to the large number of pilot layoffs that may (have)

occurred? My estimate is that over 8,000 pilots have been furloughed over the

past 2 years, all meeting FAR Part 65.57 experience requirements. How many

inspectors have their scenarios prepared for the 400-1500 who may want to pay

$100 for an ADX test, then contact an inspector for an exam? Per new 8900.1

policy, DADEs cannot give those exams.

48. Ref. Vol 5 - ch5 sect 10 5-1365

C. Development of Practical Test Scenarios.

1) Each district office designated to conduct aircraft dispatcher certification shall

develop at least three practical test scenarios and acquire the materials

necessary for their presentation. The scenarios and materials shall be revised

when necessary to ensure they reflect contemporary practices.

Does CMO-29 or any other office for that matter, have the required 3

scenarios that match the particular large airplane used by our students?

Nobody from the local office has contacted me about attaining or

developing the required performance tables and graphs, etc.. yet they

claimed via phone on January 29, 2010, to have their 3 scenarios ready.

(But interestingly enough, without our aircraft performance data.)
36

49. Ref. Vol. 1 GENERAL INSPECTOR GUIDANCE AND INFORMATION

CHAPTER 3 INSPECTOR RESPONSIBILITIES, ADMINISTRATION, ETHICS AND 

CONDUCT

Section 2 Personal Ethics and Conduct

-Informs customers of guidance material.

-Through their conduct, ASIs working in direct contact with operators and

with the public bear great responsibility in the determination of public

perception of the FAA.

-Do not make irresponsible, false, or defamatory statements that attack,

without foundation, the integrity of other individuals or organizations (ASIs

are accountable for the statements they make and the views they express).

Regarding policy above, was any thought given during the authoring

of Order 8900.1 as to the number of inspectors who may or may not

follow these guidelines – see Appendices M/N/O.

50. Any consideration for the possible deterioration of working relationships 

between the FAA and those designated to:

1- HELP the FAA?

2- Serve the public interest?
37

SUMMARY

As stated in the introduction, the solution is very simple: allow Sheffield School the

option to continue to conduct FAA examinations as it has for the past 3+ decades, as

previously approved by the FAA, conducted with the FAA’s stamp of approval,

INSPECTED and PRAISED by the FAA during a “sting operation” inspection (FAA’s

words according to emails received via the FOIA). We welcome competent and

capable additional oversight at any time.

I would like to finalize this issue successfully at your level, and no others within or

outside the FAA.

I have been patient. I’ve endured the rudeness of past and present inspectors. I’ve

endured the implications of slander from members of AFS-220 and potentiallylibelous statements received via the FOIA. I’ve lost business to an illegal Middle

Eastern school approved by the FAA. I wondered who my POI was for nearly 10

months during 2006. I did not complain to the regional office regarding the local

office losing entire groups of certification paperwork (only to be found by ME during a

visit to their office). I’ve been patient with local offices making certification

paperwork errors. I’ve been patient with the Airmen Branch and their inconsistent

application of policies regarding certification paperwork – I even rewrote portions of

Order 8400.10 to assist them. I never complained that one local office lost all of the

historical documentation pertaining to Sheffield School. I’ve been patient with a

countless number of inspectors calling my office over the years with dispatcher

certification paperwork questions, which I assisted them with.

Therefore, I believe I am owed consideration at this point.

If you approve our requests stated within this report and summarized on the

following page, then I thank you very much for your time, consideration, and

understanding. Please forward your decision to all involved or affected, and please

remind them of all “retaliation policies.”

I am sure that the FAA is a proponent of efficient certification testing, increased test

security, reducing fatigue, and increasing customer service towards the public, longstanding DADEs and long-time educational institutions; however, if your office still

feels differently and cannot see the reason and logic behind our appeal, and chooses

not to assist us, please inform me soon. We will continue this appeal through the

DOT, Congress, and other channels.

If you cannot or will not approve this request, then we respectfully request that all

questions be answered to help our understanding of the motivation behind these

policy changes. If questions cannot be answered, we shall locate others outside the

FAA, to assist us.

I will understand that any denial of our request followed by unsuccessful appeals

mandates that I follow ALL applicable Order 8900.1 policy. In so doing, I understand

that ALL inspectors will also be required to follow ALL of Order 8900.1 as well.

The irony here is that I’m requesting relief from the people I relieve, who also have

no interest in working with me to solve the problems AFFECTING US COLLECTIVELY.

If the FAA can’t relieve me and my daily workload resulting from new closed-door

policy, how am I supposed to continue to relieve you – the FAA.
38

I’m kindly requesting:

1. A complete review of Order 8900.1, Volume 13, a freeze on all policy rewrites pending

further investigation, with the ability to return to the testing procedures our large

school has used for years, as previously approved and observed by the FAA. A reply of

“but current/new policy mandates...” is not acceptable since the policy itself (or what

may be hurriedly rewritten now) and/or the authors’ motivation appears suspect at

best. We also request a guarantee of immediate termination of any FAA

employees found guilty of any retaliatory acts towards Sheffield School,

whether in the past, present, or future.

2. A statement that future policy changes will be considerate of the innocent, especially

when aimed at the guilty, and will be void of secrecy or vendetta; and that

accusations, hearsay, and rumor will not be ANY motivation behind policy or

regulatory changes until first investigated and confirmed.

3. A complete review of our local CMO-29 office to determine if anyone within, including

management, has the ability to be objective and work with Sheffield School and any

DADEs attached to or affiliated with Sheffield School in the future. A change to a

different oversight office appears to be the best solution for all parties

involved, as it will prevent retaliatory acts by the FAA, and lawsuits with

Congressional hearings initiated by us, if those acts occur. Any unnecessary

delays or renewal denials, without cause, whether applicable to DADE or

school renewals, shall be construed as retaliatory. More reports will then

follow to your office, the Secretary of Transportation, and my advisors.

4. To allow a group testing of the written flight plan scenarios in a single sitting at one

time in a purely secure testing environment. EVERY other requirement established

within the 8900.1 and PTS shall be followed, but this is the only reasonable, efficient

method of testing large groups requiring written information and not verbal. Verbal

questioning, if still required, for portions of the flight plan would be asked separately

for each individual during their respective oral examination.

5. An allowance, under extreme conditions, or for large schools, for owners and staff to

continue as DADEs within their operation, with additional oversight, if the FAA deems

necessary. We welcome it.

6. Answers to all questions within this report, if any part of 1 though 5 above

cannot be accommodated.

Thank you for your time and assistance in these matters. If you need additional

names or any further information, we will provide them. If you need more details

regarding specific details about specific individuals who’ve shown to be anti-Sheffield

and why, we can provide the details.

VOLUME 13 FLIGHT STANDARDS DESIGNEES

CHAPTER 3 DESIGNATED AIRCRAFT DISPATCH EXAMINER

Section 2 Duties and Responsibilities of the Designee

13-173 GENERAL. DADEs leverage the Federal Aviation Administration’s (FAA)

workforce and provide certification services to the public. Designation is a privilege,

not a right, and designees are appointed by the Administrator to meet FAA needs.

DADEs are expected to exercise the privileges of their designation within the

limitations set forth in the DADE’s FAA Form 8430_9, Certificate of Authority, and the

DADE’s letter of authorization (LOA).

I cannot find anywhere in the above paragraph that the FAA has the right to harass,

threaten, insult, or ignore the Designated Examiner or the operator of an FAAapproved certification school.
39

You have been presented with a case of a small business being hounded by

government for no apparent reason, which runs 100% against the grain of

President Obama’s recent State of the Union address.

The contents within the Appendices clearly detail many problems.

All we are asking is to allow us to do our job and tell the local offices and above to do

theirs. I am willing to meet with anyone above AFS-200 to resolve these issues. As

stated earlier, I am willing to work WITH the FAA. We always have, and that is the

reason your office received this report from....me.

Respectfully,

Eric W. Morris

President

Sheffield School of Aeronautics (est. 1948)
APPENDICES
Sheffield School of Aeronautics (est. 1948)

Number of countries/airlines trained by Sheffield School during the past

12+ months

Jan 09

-U.S.A, United Arab Emirates, United Kingdom, Greece, Germany, India, Iceland, Italy,

Nigeria, Switzerland, Netherlands

-Air Berlin, Thomas Cook, FedEx, Comcast, Hapag-Lloyd, Quatar Airways, (TUI), DC Aviation,

Virgin Nigeria Airways, ABU DHABI AIRPORT SERVICES (ADAS)

Feb 09

-U.S.A., Bahamas, Germany, Croatia

-Air Berlin, System Airline Service, BahamasAir, Western Air, Croatia Airlines

April 09

-U.S.A., United Kingdom, India, Spain, Germany, Italy, Gambia, Nigeria, Kingdom of Saudi

Arabia, Qatar

-Air Evac, Air Italy, DC Aviation

June 09

-U.S.A., Germany, United Arab Emirates

-DC Aviation, Windrose, Abu Dhabi Aviation, American Eagle, Pentastar Aviation,

Executive Airlines

Aug-Sept 09

- Germany, UAE, Bahamas, and U.S.A

- Abu Dhabi Aviation, Pentastar Aviation, Sky Bahamas, DC Aviation, Executive Airlines,

Windrose Air

Oct 09

-Germany, Canada, The Gambia, China, Switzerland, Uganda, Singapore, Russia, Antigua,

Qatar, and U.S.A

- DC Aviation, Shanghai Airlines, LIAT, Swiss Private Aviation, Uganda Air Cargo Corp., Simco

Air Service

Jan 2010

-United Kingdom, Germany, Ghana, Switzerland, Spain, South Korea, U.S.A. and Cape Verde

- Thomas Cook, Air Berlin, CTK CityLink, Swiss International Airlines, European Air Ambulance,

and U.S. Department of Defense

2009 was a “slow” year. Click

http://www.sheffield.com/ourcustomers.html

for a full view of who we work with.

Appendix A-1
Name & email can be provided upon coordination:

From: xxx xxx <xxx@xxx.com>

Date: Thu, 3 Dec 2009 09:39:53 -0800 (PST)

To: morris@sheffield.com

Subject: Aircraft Dispatch Course

Good Afternoon,

I contacted your school this morning, and they suggested I contact you

directly regarding my situation. I decided to attend another dispatcher school

in California, and it has not been a great experience.

I have completed the entire course the 13-weekends, and I am not feeling

prepared for the practical exam. Another challenge is the school is not able

to find an examiner, which could take months, and I do not want to

wait that long. I just finished the course as of 11/29/09. I have already

taken and passed the ADX Written Exam.

I would like to know if I can attend a shorter course that you offer, instead of

the 5 week course. I would prefer the 5 week, unfortunately I can't afford the

cost.

I look forward to hearing from you soon.

Best Regards,

Xxx xxx

Appendix B-1
Below is either a case of school problems or FAA bullying, or a

combination of both. Either way, the comments are intriguing regarding

individuals who may be currently in positions of authority. The statements

below were simply relayed to me. I cannot vouch for their validity, and do

not proclaim them to be true or false; however, I recommend that the FAA

look into these issues, and question those involved. Eric Morris.

Sent from on 09/11/2002 to Sheffield School:

Hi Ron & Eric:

This might be a sign of things to come with the new PDI inspectors who are

running around out there who have probably less than 5 years experience as a

dispatcher and want to take over the school's ability to conduct practical exams.

There is an inspector in the Phoenix office, Leo Hollis, who I feel personally, is a

real loser as he has been fired from quite a few jobs, who would like to take the

school's ability to conduct practical exams. I questioned his ability to conduct the

exams as I know that he once was a designated examiner in the Phoenix area

and I know for a fact that he gave practical exams to two persons who did not

qualify for just a practical. He even said several things to and I that

were not correct and we called him on it and now he is going to teach us a

lesson.

I received a letter the other day from the Phoenix office that stated that when our

next class is completed on Oct. 21, all of our students will be tested by the FAA,

either Mr. Hollis or someone from the Los Angeles area named .

 Then after they test our students they are going to review Jim and I conducting

the practicals before they will renew our designated examiner status.

As far as I know, Mr. Hollis nor Mr. are designated examiners and I

wonder how they can conduct the practical without the designation.

Just wanted to let you know what is being passed around by the so-called new

"PDI's". 

I'll be with you if you want to take them to task but I sure hope this does not

happen to you.

Best Regards

Appendix C–1
OBJECTIVITY (as an Owner & Course Operator)

NOTE: 22 students over 6 classes, as seen in Appendix E were failed

or dropped out of our courses in 2009. Many of these people were

issued pro rata refunds, monies that we could have kept if we simply

pushed them through and passed them. We have always operated in

this manner, and not “handed out” tickets.

A school, it’s owner, and employees cannot exhibit a better example

of objectivity.

Appendix (E) includes specific examples pertaining to individual

classes over the past year. This data for EACH class has been

submitted to our local FAA BEFORE IT WAS EVEN REQUIRED.

Below is yet another example of school/owner/instructor objectivity:

February 2, 2010, 3:00pm at offices of Sheffield School:

A student received a oral check to see if a signoff for the AD practical exam

would occur. He failed. He also possesses a Commercial Pilot certificate along

with other experience, but it did not matter – he failed. I, Eric Morris, as an

owner, could have been unethical for the 1st time in my life, and ordered my

instructor to sign him off, then directed my DADE to give him a freebie

certificate in order to make his airline, a Sheffield customer, happy. Well, I

did not, and I never have done such a thing – a 62-year reputation

worldwide is typically built on ethics, quality, and customer service, with no

compromises. We do not operate that way. Will the airline be upset and take

their business elsewhere? I do not know and do not care. Other students exit

earlier in the course or do not come close to passing the course, and

therefore, receive no FAA practical exam. Why would I, as an owner now,

after all the aforementioned grief, decide to pamper my graduates through

their exams? The local FAA is supposed to have all of this on record to verify

ANY and ALL claims made by me. More students drop our course or fail

before a practical exam, than pass other schools. HOW IS THAT BEING

UNOBJECTIVE AS AN OWNER?? Why fail anybody on the practical exam?

Why not sign off everyone for the exam, make everyone happy, and make

more money? Those are the types to go after. Not the oldest most reputable

dispatcher school in the world.

Appendix D–1
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix E-1

December 23, 2009

To:

 – ASI

2895 SW 145 Ave

Suite 291

Miramar, FL 33027

Date Due: January 31, 2010

Date Submitted: December 23, 2009

In Compliance with 14 CFR Part 65.70 (a)(2) –

[Aircraft Dispatcher Certification Courses: Records]

Sheffield School of Aeronautics – 2009

Names of Students who failed or withdrew from Part 65 Course – 2009

&

Reasons for their Withdrawal

- See following pages which are the accumulation of individual reports for

each class which were previously submitted to, accepted by 

 Jr. – POI.

- Last group of names are from the latter 2009 classes as submitted to,

accepted by inspector – ASI/FAA Specialist.

Thank you for your attention in this matter. If there are any questions or concerns, please

contact me as soon as possible.

Thank you.

Eric W. Morris

President - Sheffield School of Aeronautics (est. 1948)

499 NW 70 Ave, Suite 110

Plantation, FL 33317

(954) 581-6022
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix E-2

February 18, 2009

Mr. Jr.

Federal Aviation Administration

Ft. Lauderdale Jet Center, Suite 201

1050 Lee Wagener Blvd.

Ft. Lauderdale, FL 33315

Dear Mr. 

Attached is the recent class paperwork for FAA Aircraft dispatcher Certification.

The following student(s) did not successfully graduate from our January-February, 2009 FAA Aircraft

Dispatcher Certification courses for the following reasons:

n Academic Standards at course conclusion:

Sickness/Death in Family - Family emergency:

None.

 show (during class – did not return to class):

Was passing course, but decided against pursuing dispatch profession:

none

Thank you for your attention in this matter.

Sincerely,

Eric Morris

President - Sheffield School of Aeronautics (est. 1948)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix E-3

April 6, 2009

Mr. Jr.

Federal Aviation Administration

Ft. Lauderdale Jet Center, Suite 201

1050 Lee Wagener Blvd.

Ft. Lauderdale, FL 33315

Dear Mr. 

Attached is the recent class paperwork for FAA Aircraft dispatcher Certification.

The following student(s) did not successfully graduate from our February-March, 2009 FAA Aircraft

Dispatcher Certification courses for the following reasons:

ntain Academic Standards at course conclusion:

Sickness/Death in Family - Family emergency:

None.

o show (during class – did not return to class):

Was passing course, but decided against pursuing dispatch profession:

none

Thank you for your attention in this matter.

Sincerely,

Eric Morris

President - Sheffield School of Aeronautics (est. 1948)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix E-4

June 4, 2009

Mr. Jr.

Federal Aviation Administration

Ft. Lauderdale Jet Center, Suite 201

1050 Lee Wagener Blvd.

Ft. Lauderdale, FL 33315

Dear Mr. 

Attached is the recent class paperwork for FAA Aircraft dispatcher Certification.

The following student(s) did not successfully graduate from our April-May, 2009 FAA Aircraft Dispatcher

Certification courses for the following reasons:

ntain Academic Standards at course conclusion:

Sickness/Death in Family - Family emergency:

None.

Resigned or No show (during class – did not return to class):

Was passing course, but decided against pursuing dispatch profession:

none

Thank you for your attention in this matter.

Sincerely,

Eric Morris

President - Sheffield School of Aeronautics (est. 1948)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix E-5

July 17, 2009

Mr. Jr.

Federal Aviation Administration

Ft. Lauderdale Jet Center, Suite 201

1050 Lee Wagener Blvd.

Ft. Lauderdale, FL 33315

Dear Mr. 

Attached is the recent class paperwork for FAA Aircraft dispatcher Certification.

The following student(s) did not successfully graduate from our June-July, 2009 FAA Aircraft Dispatcher

Certification courses for the following reasons:

aintain Academic Standards at course conclusion:

in Family - Family emergency:

Resigned or No show (during class – did not return to class):

None.

Thank you for your attention in this matter.

Sincerely,

Eric Morris

President - Sheffield School of Aeronautics (est. 1948)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix E-6

October 19, 2009

Mr. Jr.

Federal Aviation Administration

Ft. Lauderdale Jet Center, Suite 201

1050 Lee Wagener Blvd.

Ft. Lauderdale, FL 33315

Dear Mr. 

Attached is the recent class paperwork for FAA Aircraft dispatcher Certification.

The following student(s) did not successfully graduate from our September-October, 2009 FAA Aircraft

Dispatcher Certification courses for the following reasons:

ademic Standards at course conclusion:

class – did not return to class):

Thank you for your attention in this matter.

Sincerely,

Eric Morris

President - Sheffield School of Aeronautics (est. 1948)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix E-7

November 23, 2009

Federal Aviation Administration

Certificate Management Office - 29

Attn. or 

2895 SW 145 Avenue, Suite 291

Miramar, FL 33027

Dear /Mr. 

Attached is the recent class paperwork for FAA Aircraft Dispatcher Certification. The ratio of graduates

passing the practical examination in this submission of FAA certification paperwork was 23/24 = 96%.

The following student(s) did not successfully graduate from our October-November, 2009 FAA Aircraft

Dispatcher Certification courses for the following reasons:

ain Academic Standards at course conclusion:

Resigned (during class – did not return to class):

None.

Thank you for your attention in this matter.

Sincerely,

Eric Morris

President - Sheffield School of Aeronautics (est. 1948)
APPENDIX F

(Request for Relief from Requirements of

Order 8900.1, Volume 13, Chapter 3, Section 2,

Par. 13-175 and FAA Compliance with Order

8900.1, Volume 1, Chapter 3, Section 2, Par. 1-

177)
1

November 13, 2009

Request for Relief from Requirements of Order 8900.1, Volume 13, Chapter 3, 

Section 2, Para 13-175 and FAA Compliance with Order 8900.1, Volume 1, Chapter 

3, Section 2, Para 1-177.

Sheffield School of Aeronautics, and all Designated Aircraft Dispatcher Examiners 

(DADEs) attached to the school, are hereby requesting a continuation of an existing 

exemption from Paragraph 13-175 in the Flight Standards Information System. We are 

also requesting to be included as customers in future policy-making initiatives that may 

have an impact on us or in which we may be able to assist the Flight Standards Service, 

in accordance with requirements in Paragraph 1-177.

Paragraph 13-175 states, in pertinent part, that a DADE will not administer more than one 

aircraft dispatcher practical exam at a time. However, the practice of allowing for 

practical exams to be administered to a maximum of two applicants simultaneously has 

been allowed and even encouraged by the Administrator in the case of Sheffield School 

for decades.

Paragraph 1-177 outlines standards of professionalism and customer service requirements 

for all aviation safety inspectors.

Our petition is based on the following:

• The practice of administering practical examinations for not more than two

simultaneous applicants has been allowed for us and approved by numerous FAA 

inspectors, including a Dispatch ASI who approved of the practice in a formal 

report (included in Appendix);

• The exemption allowing us to continue this practice, if granted, does not reduce 

aviation safety (and may actually increase it, as detailed below);

• This exemption, if granted, serves the public interest, and not allowing the 

exemption would be contrary to the public interest;

• The process by which many restrictions on the conduct of aircraft dispatcher 

practical examinations were included in Order 8900.1, without the ability of those 

who would be affected by the changes to comment, was in violation of the 

customer service and professionalism standards required of all Aviation Safety 

Inspectors of the Federal Aviation Administration.

Background

The ability for DADEs at Sheffield School of Aeronautics to administer two 

simultaneous practical examinations was granted in the mid-1970s. It was noted that at 

the time, Flight Engineer practical examinations were given by FAA inspectors in pairs. 

Sheffield School inquired if this would be possible for aircraft dispatcher practical 

examinations as well, and the Miami Flight Standards District Office, which oversaw 

Sheffield School at the time, granted permission. The process has been allowed to 
2

continue without interruption and with full knowledge and approval of all principal 

operations inspectors assigned to Sheffield School since that time.

Sheffield School of Aeronautics has been in continuous operation for approximately 62 

years. Our founding predates the establishment of the Federal Aviation Administration. 

Over its lifetime, Sheffield School has gained a reputation for operating the world’s 

foremost ab initio aircraft dispatcher training program. Sheffield remains the school of 

choice for dispatcher training for many air carriers not only in the United States, but also 

internationally. A formal or informal poll of U.S. and international airlines’ operations 

offices would validate that claim 100%. We do not relax our certification standards or 

guarantee certification as others do. We do not utilize what has devolved into a memory 

exam (standardized “knowledge” exam) as the core of our certification course. Many 

inspectors receiving this report are Sheffield graduates or have worked for airlines 

utilizing our training. In March 2003, one of you complained in an email “that (my) 

company keeps hiring from "podunk schools" and they had 2 of the last 3 wash out.” 

Some airlines that some of you have worked for required that a Sheffield-passed Aircraft 

Dispatcher course (whether the student was already FAA-certified or not) was required 

before working in their ops department. This prerequisite was also, at one time, required 

by the United States Air Force. Some of you within the inspector list have openly 

admitted that Sheffield is the “Platinum Standard” of training.

We encourage those who would question our complete dedication to quality and safety to 

do research within the industry. There are also posts available on the internet from 

managers of dispatch and senior dispatchers at major airlines at the time, who have since 

gone on to become Dispatch ASIs. The industry does not question our desire to produce 

only those dispatchers who are properly qualified and knowledgeable. Sheffield School 

challenges its students and maintains high academic standards; it is not unusual for some 

students attending the school to fail to graduate because they could not demonstrate 

mastery of the desired skills by the end of the Part 65 course. Over the past 46 classes 

since summer 2002, there have been approximately 198 students who did not or could not 

complete our course – those who DID NOT EVEN GET TO THE PRACTICAL EXAM. 

Many of those students, who are not signed off to take practical exams, have gone to 

other institutions, been granted anywhere from 60-199 hours of credit for failing at 

Sheffield, and then taken and passed onsite rubber-stamp practical exams. I’m sure some 

of you are well-aware of how one still-in-business “operator” would grant massive credit 

to those who failed Sheffield – it turned out that a transcript from us was not even 

required, only a RECEIPT from the student. 

Sheffield School’s refusal to graduate unqualified individuals has had two consequences. 

First, it has generated a demand for sham course operators who will give quick sign-offs 

and softball practical exams. In one such case, a student who unsuccessfully completed 

the Sheffield program with a class average in the 40s – who could not even read a 

METAR -- went on to be certified by a “competitor” after less than 10 hours of further 

instruction and a so-called practical exam. 
3

To be clear: We do applaud the FAA for trying to reign in those individuals who 

seek to profit from this with no regard for the industry. We realize that it is not a 

simple task.

Second, it has established an understanding internationally that graduates of the Sheffield 

program ARE qualified, which has led to a greater demand from our program than any 

other. This means that it is not uncommon for Sheffield School to operate classes with 

enrollment in excess of 20 students, many of whom are attending from outside the USA. 

These students have to contend with limitations of student visas and must make their 

flight arrangements and preparations for accommodations often 2-12 months in advance.

Given the size of some of the classes that graduate from Sheffield School’s Part 65 

program, it becomes necessary to administer a large number of practical exams in a very 

short duration. When properly overseen by the Administrator, a single examiner 

administering not more than two practical exams simultaneously does not jeopardize 

safety, but does allow the Flight Standards Service to efficiently leverage its DADEs and 

maximize the time available to inspectors to oversee air carrier flight operations.

Basis for Request

On November 5, 2009, DADEs at Sheffield School of Aeronautics were advised that this 

established practice could not continue. There was no explanation offered other than that 

this was “national policy.” When pressed, Dispatch ASI mentioned that 

“another operator” had been accused of administering seven examinations simultaneously 

and implied that this policy that will affect our operations was a result of misconduct by a 

DADE attached to another Part 65 institution. However, Mr. mentioned no 

evidence or allegations of any wrongdoing or safety issues on the part of DADEs 

attached to Sheffield School of Aeronautics.

Mr. who is commended for trying his best to help us, also advised us that he had 

called Washington to ask for an exception to the national policy and that the request was 

immediately turned down – we were not a party to this request and in fact were unaware 

that Mr. had made the call until after the fact. Mr. has been very 

recently assigned to us and our first contact with him had been only a week before. 

Therefore, Mr. did not yet have the opportunity to gain familiarity with our 

operation and the reasons that the FAA had consistently allowed this exemption in the 

past. It is clear that whomever he spoke with in Washington made no further effort to 

understand why this policy had been in place. We are concerned about this because there 

was a breakdown somewhere in the process during which the concerns and needs of the 

customer were never sought and such questions were never asked – despite the fact that 

this is absolutely required by the personal ethics and conduct standards of all FAA 

inspectors that are clearly enumerated in Order 8900.1.

We are further concerned because this standing exemption that we have had for years 

actually helps the Flight Standards Service, but since we were not contacted as part of the 

process, we were not able to offer an explanation as to why. In denying this request out 
4

of hand, the headquarters has tied the hands of one of the Dispatch ASIs moving forward 

and created an additional workload concern for him. We are requesting this exemption in 

part to assist Mr. who, having not been around our operation until very recently, 

may not realize the additional difficulty that this answer from Washington is creating for 

him – and potentially for Dispatch ASIs everywhere when the economy improves. 

Since we are unaware of any established protocol or standard to be met in requesting an 

exemption from non-regulatory policy, we believe that a reasonable standard that we 

need to meet in our petition would be the same standard used for air carriers requesting 

relief from various portions of 14 CFR – that safety and the public interest allow for the 

exemption.

Effect on Aviation Safety

Although it initially seems reasonable to expect Sheffield School to offer proof that 

safety is not compromised by such an exemption, the Flight Standards Service has 

already done so. We defer to your judgment – as exercised by numerous inspectors 

already, including William Bonatti. During surveillance several years ago, Mr. Bonatti 

observed a practical exam in which two oral examinations were given simultaneously by 

the same DADE. This was in keeping with policy that had been established for years, 

and Mr. Bonatti concluded that the administration of the dispatcher practical exam in this 

fashion was consistent with safety. His written report is attached to our petition. Thus, it 

has already been established by the Administrator that this is safe and appropriate.

Given that there has been no reason provided to us to suggest that such practical exams 

would be less safe now than before, we have to assume that the Flight Standards Service 

does not see a safety issue.

However, we would like to offer additional reasons why this practice is valid.

First, we believe that the intent behind the rule to limit these examinations to one 

applicant at a time is to ensure that a DADE can properly assess each applicant in the 

performance of the required tasks. This can be done, as we have demonstrated 

historically, with alternating questions between applicants, covering similar tasks for both 

applicants at the same time. In setting the schedule for exams when this allowance has 

been used, the instructors have offered pairings based upon similar aptitude and 

communication styles with an eye toward minimizing any distractions or tension. 

Further, Sheffield DADEs that have used this allowance have, in rare cases where we 

have felt the pairing to be potentially distracting or have felt that it would be difficult to 

assess either applicant’s performance, split the pair and continued the examination oneon-one with each individual applicant. This strategy ensures that if one applicant is 

experiencing difficulty, the other will not be “dragged down” and can still be given a fair, 

objective assessment. Daily verbal questioning of students by the instructor during class 

helps determine ability and compatibility.
5

Working with two applicants at a time offers an advantage that working with one 

applicant at a time does not; it affords an examiner the opportunity to gauge interaction 

between two applicants and “exercise proper DRM competencies,” as stated in the 

Aircraft Dispatcher PTS. In a single applicant environment, the examiner can and should 

simulate a pilot-dispatcher interaction in which the examiner plays the role of a PIC. 

However, having two applicants at a time allows the examiner to view interaction 

between the applicants at a peer level – something that is much harder to do one-on-one. 

Given that competent dispatching is highly dependent upon interpersonal communication, 

that intangible skill can be evaluated more easily in a two-applicant scenario.

Since we have not been advised of any safety reasons requiring that we abandon this 

procedure and given that the FAA has already found it to be acceptable, we believe that 

this demonstrates that safety will not be jeopardized by allowing the exemption. We 

further believe that if there are safety concerns that have arisen from other schools’ 

DADEs having attempted to administer 5, 6, 10, or more daily exams, whether 

simultaneous or not, adding restrictions to our program for wrongdoing that we did not 

commit is capricious at best, and actionable at worst. 

We’ve all heard some of the stories: regulations-less orals, coaching during orals, openbook orals, meeting failed students to administer orals at airports, etc.. A gem from “up 

north” is a guy charging over $400 for a practical exam, but would only give a 15-minute 

oral one Friday “because I need to get home and you took too long on your flight plan.” 

Others “won’t come in for less than four people.” This information is fed to me all the 

time from current students, graduates, and prospective students.

THESE are examples that compromise airline safety in addition to being unethical. 

Certifying applicants in any manner stated above is a sin and spits in the face of a 

profession rooted in the concept of a “checks and balances” system. As you are all aware, 

many pilots view airline dispatchers as “clerks” which defeats the purpose and successful 

application of 121.533/535 and 121.601.

If our petition is denied on the basis of safety, we request an explanation as to the reasons 

that safety would no longer permit an established practice that the Administrator has 

already deemed to be safe.

Public Interest

The general public is not affected by this exemption. The greatest impact is on those who 

choose to attend not only Sheffield School of Aeronautics, but also any Part 65 aircraft 

dispatcher training facility that routinely enrolls large classes, or will occasionally enroll 

large classes following the next economic recovery.

As mentioned previously, a significant portion of the enrollment of a typical Sheffield 

School certification class are international students, who, out of necessity, must make 

their travel and visa arrangements far in advance. Under policies that have been in place 
6

until now, a single examiner could give two practical exams per day, with a maximum of 

two applicants at a time. Therefore, each DADE has had the capacity to evaluate a total 

of four applicants in a day. By limiting this to two exam sessions, this allowed DADEs 

to be efficient in their evaluation of a class of graduates, while at the same time avoiding 

the fatigue issues that would certainly arise from administering four consecutive exams.

This allows for a student who is planning to attend a dispatcher school to be able to plan 

for a minimal period of time after completion of the Part 65 course to allow for the 

scheduling of a practical examination. Even in the event of a large class of graduates 

waiting to take practical exams, the waiting period would still be a matter of several days. 

Some applicants are asked to interview at airlines THE DAY AFTER GRADUATION 

while others are (unfairly) requested to return to their workplace 1-3 days after the class 

graduation date. 

We believe that the public interest IS served by continuing to allow for this practice, and 

that the public interest is NOT served by disallowing the practice. In the event that only 

one DADE and no ASIs are available to examine a group of 25 individuals, even if twoa-day exams are given with no days off for that DADE, this means that two individuals 

would be examined fully 13 days after the completion of a course. This places a 

significant burden and expense upon those individuals.

We believe, therefore, that suddenly adding this restriction places additional hardships on 

those who are seeking certification, and therefore that removing the ability to conduct 

simultaneous practical exams for not more than two applicants is not in the public 

interest.

Before requesting this exemption, we considered alternative solutions to this problem, 

and found that all of them create additional difficulties not only for us, but also for the 

Flight Standards Service.

First, by disallowing an established practice, the FAA ostensibly assumes the 

responsibility to provide the practical examinations. It is clear to us from conversations 

with Mr. that the FLL CMO is experiencing a period of extreme workload in 

overseeing Part 121 operations, and that the CMO cannot provide inspectors on a regular 

basis to perform this task.

The other solution would be to secure the services of additional DADEs within the area. 

Although there are several Part 121 dispatch sections in the area, this proves problematic

for numerous reasons.

First, DADEs who are not affiliated with a school who are active Part 121 dispatchers 

cannot be expected to be available regularly, six, seven, or more times per year. Their 

primary responsibility and focus will be their “primary” job of Part 121 dispatch. Simply 

appointing additional DADEs does not guarantee that they will be available, and 

therefore does not reliably solve the problem. In order to ensure the necessary coverage 

for a school that graduates as many students as does Sheffield School even during a 
7

recession, numerous additional DADEs would need to be found. This is similar to the 

problem that a dispatch manager may face in covering open shifts; there may be 

numerous individuals qualified, but work rules, vacation and sick days and other 

obligations mean that even four or five potential candidates may not be available.

In addition, were the CMO to secure the services of additional DADEs, this would mean 

additional oversight. The CMO would be responsible for initial and recurrent training of 

the DADE, maintenance of records and a continuity book, scheduling of observation for 

that many additional examiners throughout the year, etc. Again, our CMO is already 

facing critical workload issues based upon the information provided by Mr. this 

option does not seem to be the best available from that perspective. (We note that in such 

a critical workload situation, appointing and managing additional DADEs might actually 

jeopardize aviation safety by requiring additional resources of the CMO.)

Finally, we have concerns about some of the operations from which Mr. might 

seek DADE candidates. Dispatch at one of the largest operators in this area was recently 

found to be deficient in multiple areas during a major inspection. With the knowledge 

and encouragement of the Dispatch ASI (and we believe it was Mr. Sheffield 

School was contracted to perform a rapid refresher course of general topics including 

aviation weather, aeronautical charting, regulations and OpSpecs, AIP specific to the area 

of operations and also DRM. During the conduct of this training, we were alarmed at 

some of the deficiencies that we witnessed, which included some of the dispatchers 

inability to consistently interpret visibility and ceiling information from TAFs during 

given ETA blocks or consistently apply 121.619; ironically, some of the more senior 

dispatchers had the most difficult time. Although graduates of any approved Part 65 

dispatcher certification course will be instructed and examined in large turbojet aircraft, 

this operator utilizes only turboprops; therefore, we would question whether their 

dispatchers would have sufficient knowledge of turbojet systems, limitations and 

characteristics to be a DADE for such a program; a graduating student who is applying 

for the practical exam would conceivably know the aircraft better than the examiner. 

This difference between the DADE’s experience and knowledge and the material to be 

covered in the practical exam would be grounds for additional oversight of the new 

DADE by the CMO.

The other large operator whose dispatch office is overseen by the FLL CMO is an air 

carrier for which both current DADEs assigned to Sheffield have been previously listed 

as ground instructors. Both DADEs, in that ground instructor capacity, have provided 

general topics instruction as part of that air carrier’s recurrent training program. We also 

found and expressed concerns about similar topics there. Although this operator does 

work with turbojets, theirs are from a different manufacturer with different systems and 

planning practices. 

This is not to state that there are no potentially qualified applicants in this area, but 

simply to point out that we have reasons to be concerned about a portion of the potential 

pool, and to highlight the challenges that the CMO would face in resolving the problem 

both short- and long-term by adding DADEs in this area.
8

In the end, we believe that the public interest would be better served by allowing the 

continuation of the existing practice, with due FAA oversight and surveillance. This 

would ensure reasonable scheduling of practical exams, while at the same time ensuring 

that the examiners are well versed in the aircraft and simulated company procedures with 

which the applicant is already familiar. It also seems to be the most expedient solution 

available to the CMO.

In the event that the Administrator determines that continuing this practice is not allowed 

by the public interest, we request a written explanation as to why a practice that has 

already been deemed to be consistent with the public interest, no longer serves that 

interest.

Concerns Regarding the Development of National Policy

In requesting this exemption, we would also like to protest the fashion in which this 

national policy was developed. We believe that the process used to create this new policy 

violated multiple standards of customer service and professionalism that are demanded 

by Order 8900.1 to be demonstrated by all ASI’s.

In general terms, Volume 1, Chapter 3, Section 2 states that professionalism is a set of 

behavioral traits that enhances mission effectiveness by, among others, fostering 

collaboration with others and focusing on customer service. We recognize that the FAA 

is charged with overseeing operators and has a very careful line to walk between 

oversight and customer service responsibilities. 

However, given the tasking to establish national policy regarding examiners, we believe 

that the customer service standards were overlooked. Among others, this section of the 

Order stipulates that the inspectors will:

• Understand customer requirements at the outset of assignments.

• Ask questions to assure understanding of customer expectations.

• Ensure that requirements are incorporated into final work products and designs.

• Explain recommendations and decisions in a manner appropriate for the audience

• Listen to, accept, and act on customer feedback.

• Work with the public and industry to achieve and maintain regulatory compliance 

and improve safety.

• Avoid action or inaction that contributes to the public perception of unfair or 

disparate treatment.

Sheffield School of Aeronautics has long tried to assist the FAA by requesting 

interpretations of regulations and national policy on behalf of our graduates who ask us, 

forwarding concerns from active dispatchers about their carriers who were afraid to do so 

directly, forwarding complaints about known and documented regulatory violations, and 

expressing opinions on existing policies. 
9

If you review the records of all DADEs attached to Sheffield School throughout its 

history, you will find that we have collectively administered over 3,000 practical 

examinations over a period spanning decades.

It is therefore inconceivable to us that when the Flight Standards Service decided to 

generate national policy to improve the administration of aircraft dispatcher practical 

examinations, we were not contacted until after the policy rewrite was completed. In an 

active dispatch environment, failing to approach a colleague who has years of experience 

when you are having a problem could be deemed to be a breakdown of DRM. Yet, the 

authors of this policy apparently made no attempt to contact those in the industry who 

could offer advice about best practices, what works, what does not work and any 

concerns going forward. 

This is all the more surprising to us in light of recent attempts to add policy in the 8900.1 

to allow for contract dispatching, which, as a concept, violates Flight Standards Policy. 

Nevertheless, there was closed-door authoring of procedures in Order 8900.1 to allow for 

that, with strong conflict-of-interest ties to a particular company that was already 

beginning their strategy to advertise and supply this service before this policy writing was 

completed. The outcry of the Airline Dispatcher’s Federation and indeed Congressional 

intervention prevented this closed-door rewrite of national policy from being enacted.

With this history in mind, we were positively stunned that we were not offered a chance 

to offer advice or concerns about any proposed improvements. Sheffield School would 

welcome the opportunity to work with the FAA to create sound policy; that we were 

excluded from this process in violation of customer service standards after the contract 

dispatch affair is inconceivable, unless the policy was crafted with the specific intent of 

tying our hands in mind.

Mr. in his visit on November 5, made the statement to us that “you guys are 

different,” in reference to the size of our program and the volume of applicants that we 

process. That is true, but it also means that the FAA is aware of this. If you are a 

Dispatch ASI reading this petition, then the chances are quite good that we know you 

personally or have had contacts with you at some point. All of you, having ties with the 

industry, are aware of the size and status of this school.

Therefore, our most grave concern is that this policy that was crafted outside the public 

view, was written in such a way to affect the operations of the one school that currently, 

even during a global recession, has sufficient size and volume to be affected. One of our 

DADEs noted in a recent discussion with an ASI, that the imposition of this policy that 

would affect our operations but not others when we are doing our best to uphold the 

standards seemed like disparate treatment. That Dispatch ASI did not disagree or debate 

that point; and therefore, we believe this is an admission that the ASI customer service 

standards were not followed.

In recent contacts, when we asked who authored the new policy, we were told by another 

Dispatch ASI that is was “the Administrator,” which is of course legally correct. 
10

However, neither Mr. Babbitt himself nor AFS-1 has the technical expertise to author 

these standards. Therefore, we have to assume that this was collective work by the 39 

Dispatch ASIs in the name of the Administrator. We cannot believe that all 39 ASIs 

were actually involved with this project, but it is difficult to believe that not one of the 

ASIs who did work on this saw the ethical and customer service standards violation –

particularly so soon after the contract dispatch affair.

It is not our intent to excoriate the ASI cadre, as we understand that you are all severely 

overworked at the moment. We realize that involving customers in these changes would 

delay the process. We would like to believe that this was simply a rush to bring a 

difficult project to completion. But in so doing, we believe that a violation occurred, and 

we would like to request for the record that we have the ability to participate as a 

collaborative partner in the future.
11

Summary

In summary, we request the following:

• Sheffield School of Aeronautics, and the DADEs attached thereto, request an 

exemption from national policy to conduct practical examinations for not more 

than two applicants simultaneously. Under such exemption, DADEs would still 

adhere to the two-full-exam-per-day criterion; but would be able to examine a 

maximum of two applicants during each exam, for a total of maximum four 

applicants daily.

• If there is a concern about examiner fatigue, Sheffield School would agree to 

waive the DADE’s allowance to also conduct a retest in the same day.

• We understand that such an exemption would mean that additional oversight and 

surveillance could be warranted. We welcome that, and we encourage Dispatch 

ASIs to observe and offer any feedback which may result in better exam practices.

• We recognize that one-applicant-at-a-time is still the preferred method of 

administering the practical examination and would utilize the two-at-a-time 

exemption only when class size and student travel requirements demand it. We 

also agree that it is appropriate to notify the inspector having jurisdiction over the 

DADEs when such exemption is required to be used, if so requested by the ASI.

• We encourage a revision to the relevant parts of Order 8900.1 to allow this 

exemption to be granted by local inspectors who are responsible for the approval 

and maintenance of DADEs, as the needs of the local inspector require. We 

understand that it is conceivable that other Part 65 programs could face 

unexpected, unusually large classes that would similarly exceed the ability of the 

inspectors and existing DADEs to manage. This exemption, if allowed, 

nationally, will allow the Dispatch ASIs to rapidly accommodate a sudden 

increase in demand for practical examinations without any decrease in the quality 

of service offered to the public.

Finally, we request that we be included in the process of drafting any additional policy 

regarding Part 65 courses or DADEs. We understand that we are a customer and that the 

final policy-making rests with the FAA, but we would like to assist in any way we can. 

To quote one ASI, we need to “raise the bar” on dispatcher certification, and we at 

Sheffield School would welcome any opportunity we have to assist you in that end. 

Attached is a quick-view comparison table along with an official school evaluation 

from....you.

Respectfully,

Eric W. Morris - President

Sheffield School of Aeronautics (est. 1948)
12

APPENDIX

Why using DADEs outside of legitimate Part 65 schools diminishes airline safety & 

overburdens FAA FSDOs and their respective safety inspectors, and why DADES 

attached to a school better serve public interest.

Sheffield DADEs ASIs & Non-Sheffield DADEs

Employees or officials of 62-year institution. Overworked ASIs with primary responsibility of 

overseeing a multitude of Part 121 air carriers or 

airline employees working shifts.

DADEs have the ability to conduct, complete all 

practical exams AND required FAA certification 

paperwork for 25+ POTENTIAL APPLICANTS, up to 

6 times per year, within a reasonable period of 

time. Also, have the time and expertise to deal with 

a multitude of certification paperwork issues 

ranging from lost certificates to rectifying errors 

committed by others. We also are willing to spend 

the time on the telephone on hold with the FAA 

Airman Branch for technical issues, questions, and 

other matters.

DADEs will NOT have the ability to conduct, 

complete all practical exams AND required FAA 

certification paperwork for 25+ POTENTIAL 

APPLICANTS within a reasonable period of time. A 

currently buggy IACRA system will provide no relief 

from checking, rechecking for errors, and calling 

tech support at the FAA Airman Branch for lost 

paperwork, missing or lost permanent certificates.

Will the ASI trying to run to the local 121 airline or 

the assigned DADE trying to make his shift have 

time to call the Airman Branch to explain why the 

ADX test is not to be included on a newly-turned 

23-yr old applicant’s paperwork or how to rectify 

his/her South Korean’s applicants’ address on the 

permanent certificates? - the ones with ‘North 

Korea’ typed in. [true story.]

Tech support: We answer all questions ranging 

from “how do I change my address?” to “I lied –

my eyes aren’t blue-what now?” to “now I’m a girl 

– do I need to tell the FAA?”

Tech support?

Desire or time to do this? 

DADEs will have no problem submitting all 

paperwork within required 7-day period.

DADEs will be UNABLE to consistently submit all 

paperwork within required 7-day period for any 

reasonably-sized class.

Work at school full-time. Work at FSDO or airline.

Available everyday including weekends. May not be available or limited consecutive days.

Can conduct exams at ANY time of day to help 

meet applicants’ travel schedules.

Cannot or will not always conduct exams at ANY 

time of day to help meet applicants’ travel 

schedules.

Requires no travel by applicant. May require travel and appointment by applicant.

DADE familiar with ALL SPECIFIC subject matter 

instructed at school.

DADE NOT familiar with ALL SPECIFIC subject 

matter instructed at school.

DADE familiar with LARGE TURBOJET subject 

matter instructed at school.

DADE MAY NOT BE familiar with LARGE TURBOJET 

subject matter instructed at school.

DADE familiar with FLAG OPS subject matter 

instructed at school.

DADE MAY NOT BE familiar with FLAG OPS subject 

matter instructed at school.

DADEs have proven track record of email requests 

on interpretation of current and proposed subject 

matter.

DADE MAY be employed by an airline and may not 

be well-versed on recent material required by FAA 

that is not found within their OPS manuals.

DADE familiar with ALL TYPES of approaches 

instructed at school.

DADE may not be familiar with ALL TYPES (i.e. LPV) 

subject matter instructed at school.

DADE requires no additional airplane manual 

references studied at school.

DADE must provide or request additional airplane 

manual references from applicant that were studied 

at school.

DADEs welcome any and all inspectors to observe 

FAA practical exams at any time.

DADEs may not have FAA practical exams 

monitored.

Sheffield DADEs have cumulatively conducted 

1000s of FAA practical exams.

DADEs will likely have very little or zero experience 

conducting FAA practical exams.

Sheffield DADEs have proven continuously that the 

conduct of our practical examinations is exemplary, 

including detailed ASI report from July 2003.

Newly qualified ASIs’ and newly qualified DADEs’ 

experience will be minimal or nil; that, coupled with 

being already assigned other tasks, or other jobs, 

may raise safety concerns.
Memorandum

Orlando Flight Standards District Office

5950 Hazeltine National Drive

Citadel International, Suite 500

Orlando, Florida 32822

Subject: INFORMATION: Findings from Special Inspection of 

Sheffield School of Aeronautics 14 CFR Part 65 

Aircraft Dispatcher School

Date: July 14, 2003

From: Aviation Safety Inspector Reply to

Attn. of:

William L. Bonatti:

(407) 812-7763

FAX: (407) 812-7710

To: Theodore A. Perry, AFS-200

THRU: Dawn Veatch, ASO-201

This memo outlines the inspection that was conducted, per your request, at the Sheffield School 

of Aeronautics 14 CFR Part 65 Aircraft Dispatcher School.

The Inspection started on 07/09/2003 with a briefing with Mr. Eric W. Morris, President, and Mr. 

Ronald L. Morris Owner of Sheffield School of Aeronautics. In this briefing I informed them that 

I was conducting a special inspection of their facilities, program, training materials, and Practical 

Examination procedures. During this briefing Mr. Eric Morris gave me a full briefing as to the 

policies and procedure used by the school in conducting training, testing, and the Practical 

Examinations conducted. I was also given a copy of all the course materials, handouts, exercises, 

and course examinations for my review. At the completion of the briefing I was given a tour of 

the training facilities, which were found to be in compliance with 14 CFR Part 65.65.

A review of the course materials, handouts, exercises, and course examinations showed that the 

school has spent a lot of time and effort to prepare affective and efficient training and testing 

materials. The course materials used are current and up to date with the industry, and far exceed 

the needs of the course. In many cases Sheffield School of Aeronautics have produced materials 

that the student can use throughout their industry employment.

The Procedures used by Sheffield School of Aeronautics and the Designated Aircraft Dispatch 

Examiners (DADE’s) to conduct Area of Operation 1 “Dispatch Exercise” Task A “Flight 

Planning” is not commonly found, however it does meet the requirements of the Aircraft 

Dispatcher Practical Test Standards (FAA-S-8081-10A). The applicants are all given their Flight 

Planning Exercise at the same time. All applicants are required to remain in the testing room the 

entire time while being observed by one of the DADE’s. This portion of the examination is 

commonly conducted on a one on one basis by other designees, however they are normally only 

working with one applicant at a time. In the environment that Sheffield is conducting this portion 

of the Dispatcher Practical, it is as secure and allows the designee the ability to test the specific 

areas in which knowledge and skills must be demonstrated by the applicant before the issuance of 

an Aircraft Dispatcher Certificate with more efficiency and less time consumption. The security 
2

measures used to assure that each applicant does his own work are different exercises for each 

applicant and the exercise is observed by the DADE.

I physically observed this graduating class of 9 applicants complete this portion of the 

examination on 07/10/2003. The briefing was conducted by one of the DADE’s Mr. Brett J. 

Bories. The briefing was very detailed and covered everything that the applicants required to be 

able to conduct the exercise. Applicants were given 2 hours and 10 minutes to complete the 

exercise. Each applicant had his own desk, materials, and no sharing or talking was permitted. 

This allowed the applicant ample room to work within a comfortable environmental. Out of the 9 

applicants the first finished the exercise in 1 hour and 28 minutes and received a score of 93%. 

The last applicant to finish the exercise completed it in 2 hours and 10 minutes and received a 

score of 100%. The average time for all applicants was 1 hour and 55 minutes with an average 

score of 87%.

The remaining Areas of Operations requiring examination are conducted by oral questioning. 

Sheffield’s DADE’s conduct the oral portion of the examination in two different formats. One of 

the formats is with the DADE conducting oral questioning on a one-on-one basis with an 

applicant, while the other format is with the DADE conducting oral questioning with 2 applicants 

at the same time. The methods and procedures used by the DADE’s while conducting the one-onone type oral were found to be acceptable and in accordance with normal practical test procedures 

and the Aircraft Dispatcher Practical Test Standards. The methods and procedures used by the 

DADE’s while conducting the oral portion to 2 applicants at the same time were also found 

acceptable. The DADE’s were very effective in their questioning process and in directing specific 

questions to each applicant to assure that both applicants were questioned to an adequate level. 

The procedures and methods used were in accordance with the Aircraft Dispatcher Practical Test 

Standards, 8700.1 Volume 2 Section 3 paragraph 5(B), and the 8710.3C Chapter 5 paragraph 

19(C). 

The oral portions of the examination averaged 2 hours and 30 minutes for a one-on-one type oral, 

and 3 hours and 50 minutes for an oral conducted with 2 applicants. With these times, and the 

times from the flight planning exercise, the average practical examination time was 4 hours and 

25 minutes for a one-on-one exam and 5 hours and 45 minutes for group testing.

To summarize, the DADE’s conducted all practical tests in accordance with regulations, the 

Practical Test Standards, and procedures found in FAA guidance. The DADE’s did not allow 

personal prejudices to interfere with objective evaluation of an applicant, and the oral portion of 

the practical test was conducted in a private area free from distractions. The DADE’s gave the 

applicants their undivided attention during the test and ensured that any discussion of test results 

with the applicants was done in private unless, by mutual agreement, a person other than the 

applicants were present. 

William L. Bonatti

File: 

WP: Q:\TYPING\UNIT3\Bonatti\Sheffield.doc

ASO-FSDO-15:W Bonatti:WLB:(407) 812-7763:07/14/2003
APPENDIX G

(Request for Revision to Order 8900.1, Volume

13, Chapter 3, Section 2, Par. 13-175 and FAA

Compliance with Order 8900.1, Volume 1,

Chapter 3, Section 2, Par. 1-177)
1

November 18, 2009

[note: some wording is based on that fact that this document was originally sent to 

all ASIs and our local CMO as an exemption request.]

REQUEST FOR REVISION TO ORDER 8900.1, VOLUME 13, CHAPTER 3, 

SECTION 2, PARAGRAPH 13-175(C) and FAA Compliance with Order 8900.1, 

Volume 1, Chapter 3, Section 2, Para 1-177.

We request that the above mentioned paragraph be amended to read as follows:

“C. Test More Than One Simultaneous Applicant. Conduct any portion of the 

practical test with more than one applicant at the same time, unless approved by the FAA 

specialist. 

The specialist may grant approval for a DADE to conduct practical tests with not more 

than two simultaneous applicants, when the volume of practical tests required in a short 

period exceeds the ability of available DADEs and ASIs to conduct the practical tests 

within a reasonable amount of time. (For example, approved Part 65 Aircraft Dispatcher 

courses may graduate 25 applicants per class, and may conduct simultaneous classes. In 

such cases, applicants for the practical test could conceivably be scheduled weeks after 

the course completion, placing an undue burden upon those applicants who have traveled 

from outside the area to attend the course.)

When this approval is granted, the DADE will be limited to two full practical tests per 

day, with a maximum of two simultaneous applicants per practical test. The DADE 

should notify the specialist in advance when it is anticipated that this approval must be 

used, and the FAA specialist is encouraged to monitor practical tests with two 

simultaneous applicants in order to ensure that each applicant is thoroughly evaluated. 

The DADE should be discouraged from administering retests on dates when this approval 

is used.”

Sheffield School of Aeronautics, and all Designated Aircraft Dispatcher Examiners 

(DADEs) attached to the school, are hereby requesting either a continuation of an 

existing exemption from Paragraph 13-175 in the Flight Standards Information System or 

if not possible, a Request For Revision To Order 8900.1, Volume 13, Chapter 3, Section 

2, Paragraph 13-175(C). We are also requesting to be included as customers in future 

policy-making initiatives that may have an impact on us or in which we may be able to

assist the Flight Standards Service, in accordance with requirements in Paragraph 1-177.

Paragraph 13-175 states, in pertinent part, that a DADE will not administer more than one 

aircraft dispatcher practical exam at a time. However, the practice of allowing for 

practical exams to be administered to a maximum of two applicants simultaneously has 

been allowed and even encouraged by the Administrator in the case of Sheffield School 

for decades.
2

Paragraph 1-177 outlines standards of professionalism and customer service requirements 

for all aviation safety inspectors.

Our petition is based on the following:

• The practice of administering practical examinations for not more than two

simultaneous applicants has been allowed for us and approved by numerous FAA 

inspectors, including a Dispatch ASI who approved of the practice in a formal 

report (included in Appendix);

• The exemption or an approved revision request to Order 8900.1, allowing us to 

continue this practice, if granted, does not reduce aviation safety (and may 

actually increase it, as detailed below);

• This exemption, if granted, serves the public interest, and not allowing the 

exemption would be contrary to the public interest;

• The process by which many restrictions on the conduct of aircraft dispatcher 

practical examinations were included in Order 8900.1, without the ability of those 

who would be affected by the changes to comment, was in violation of the 

customer service and professionalism standards required of all Aviation Safety 

Inspectors of the Federal Aviation Administration.

Background

The ability for DADEs at Sheffield School of Aeronautics to administer two 

simultaneous practical examinations was granted in the mid-1970s. It was noted that at 

the time, Flight Engineer practical examinations were given by FAA inspectors in pairs. 

Sheffield School inquired if this would be possible for aircraft dispatcher practical 

examinations as well, and the Miami Flight Standards District Office, which oversaw 

Sheffield School at the time, granted permission. The process has been allowed to 

continue without interruption and with full knowledge and approval of all principal 

operations inspectors assigned to Sheffield School since that time.

Sheffield School of Aeronautics has been in continuous operation for approximately 62 

years. Our founding predates the establishment of the Federal Aviation Administration. 

Over its lifetime, Sheffield School has gained a reputation for operating the world’s 

foremost ab initio aircraft dispatcher training program. Sheffield remains the school of 

choice for dispatcher training for many air carriers not only in the United States, but also 

internationally. A formal or informal poll of U.S. and international airlines’ operations 

offices would validate that claim 100%. We do not relax our certification standards or 

guarantee certification as others do. We do not utilize what has devolved into a memory 

exam (standardized “knowledge” exam) as the core of our certification course. Many 

inspectors receiving this report are Sheffield graduates or have worked for airlines 

utilizing our training. In March 2003, one of you complained in an email “that (my) 

company keeps hiring from "podunk schools" and they had 2 of the last 3 wash out.” 

Some airlines that some of you have worked for required that a Sheffield-passed Aircraft 

Dispatcher course (whether the student was already FAA-certified or not) was required 

before working in their ops department. This prerequisite was also, at one time, required 
3

by the United States Air Force. Some of you within the inspector list have openly 

admitted that Sheffield is the “Platinum Standard” of training.

We encourage those who would question our complete dedication to quality and safety to 

do research within the industry. There are also posts available on the internet from 

managers of dispatch and senior dispatchers at major airlines at the time, who have since 

gone on to become Dispatch ASIs. The industry does not question our desire to produce 

only those dispatchers who are properly qualified and knowledgeable. Sheffield School 

challenges its students and maintains high academic standards; it is not unusual for some 

students attending the school to fail to graduate because they could not demonstrate 

mastery of the desired skills by the end of the Part 65 course. Over the past 46 classes 

since summer 2002, there have been approximately 198 students who did not or could not 

complete our course – those who DID NOT EVEN GET TO THE PRACTICAL EXAM. 

Many of those students, who are not signed off to take practical exams, have gone to 

other institutions, been granted anywhere from 60-199 hours of credit for failing at 

Sheffield, and then taken and passed onsite rubber-stamp practical exams. I’m sure some 

of you are well-aware of how one still-in-business “operator” would grant massive credit 

to those who failed Sheffield – it turned out that a transcript from us was not even 

required, only a RECEIPT from the student. 

Sheffield School’s refusal to graduate unqualified individuals has had two consequences. 

First, it has generated a demand for sham course operators who will give quick sign-offs 

and softball practical exams. In one such case, a student who unsuccessfully completed 

the Sheffield program with a class average in the 40s – who could not even read a 

METAR -- went on to be certified by a “competitor” after less than 10 hours of further 

instruction and a so-called practical exam. 

To be clear: We do applaud the FAA for trying to reign in those individuals who 

seek to profit from this with no regard for the industry. We realize that it is not a 

simple task.

Second, it has established an understanding internationally that graduates of the Sheffield 

program ARE qualified, which has led to a greater demand from our program than any 

other. This means that it is not uncommon for Sheffield School to operate classes with 

enrollment in excess of 20 students, many of whom are attending from outside the USA. 

These students have to contend with limitations of student visas and must make their 

flight arrangements and preparations for accommodations often 2-12 months in advance.

Given the size of some of the classes that graduate from Sheffield School’s Part 65 

program, it becomes necessary to administer a large number of practical exams in a very 

short duration. When properly overseen by the Administrator, a single examiner 

administering not more than two practical exams simultaneously does not jeopardize 

safety, but does allow the Flight Standards Service to efficiently leverage its DADEs and 

maximize the time available to inspectors to oversee air carrier flight operations.
4

Basis for Request

On November 5, 2009, DADEs at Sheffield School of Aeronautics were advised that this 

established practice could not continue. There was no explanation offered other than that 

this was “national policy.” When pressed, Dispatch ASI mentioned that 

“another operator” had been accused of administering seven examinations simultaneously 

and implied that this policy that will affect our operations was a result of misconduct by a 

DADE attached to another Part 65 institution. However, Mr. mentioned no 

evidence or allegations of any wrongdoing or safety issues on the part of DADEs 

attached to Sheffield School of Aeronautics.

Mr. who is commended for trying his best to help us, also advised us that he had 

called Washington to ask for an exception to the national policy and that the request was 

immediately turned down – we were not a party to this request and in fact were unaware 

that Mr. had made the call until after the fact. Mr. has been very 

recently assigned to us and our first contact with him had been only a week before. 

Therefore, Mr. did not yet have the opportunity to gain familiarity with our 

operation and the reasons that the FAA had consistently allowed this exemption in the 

past. It is clear that whomever he spoke with in Washington made no further effort to 

understand why this policy had been in place. We are concerned about this because there 

was a breakdown somewhere in the process during which the concerns and needs of the 

customer were never sought and such questions were never asked – despite the fact that 

this is absolutely required by the personal ethics and conduct standards of all FAA 

inspectors that are clearly enumerated in Order 8900.1.

We are further concerned because this standing exemption that we have had for years 

actually helps the Flight Standards Service, but since we were not contacted as part of the 

process, we were not able to offer an explanation as to why. In denying this request out 

of hand, the headquarters has tied the hands of one of the Dispatch ASIs moving forward 

and created an additional workload concern for him. We are requesting this exemption or 

an approved revision request to Order 8900.1, in part to assist Mr. who, having 

not been around our operation until very recently, may not realize the additional difficulty 

that this answer from Washington is creating for him – and potentially for Dispatch ASIs 

everywhere when the economy improves. 

Since we are unaware of any established protocol or standard to be met in requesting an 

exemption or revision to Order 8900.1, we believe that a reasonable standard that we 

need to meet in our petition would be the same standard used for air carriers requesting 

relief from various portions of 14 CFR – that safety and the public interest allow for the 

exemption or Order 8900.1 revision.

Effect on Aviation Safety

Although it initially seems reasonable to expect Sheffield School to offer proof that 

safety is not compromised by such an exemption or Order 8900.1 revision, the Flight 

Standards Service has already done so. We defer to your judgment – as exercised by
5

numerous inspectors already, including William Bonatti. During surveillance several 

years ago, Mr. Bonatti observed a practical exam in which two oral examinations were 

given simultaneously by the same DADE. This was in keeping with policy that had been 

established for years, and Mr. Bonatti concluded that the administration of the dispatcher 

practical exam in this fashion was consistent with safety. His written report is attached to 

our petition. Thus, it has already been established by the Administrator that this is 

safe and appropriate.

Given that there has been no reason provided to us to suggest that such practical exams 

would be less safe now than before, we have to assume that the Flight Standards Service 

does not see a safety issue.

However, we would like to offer additional reasons why this practice is valid.

First, we believe that the intent behind the rule to limit these examinations to one 

applicant at a time is to ensure that a DADE can properly assess each applicant in the 

performance of the required tasks. This can be done, as we have demonstrated 

historically, with alternating questions between applicants, covering similar tasks for both 

applicants at the same time. In setting the schedule for exams when this allowance has 

been used, the instructors have offered pairings based upon similar aptitude and 

communication styles with an eye toward minimizing any distractions or tension. 

Further, Sheffield DADEs that have used this allowance have, in rare cases where we 

have felt the pairing to be potentially distracting or have felt that it would be difficult to 

assess either applicant’s performance, split the pair and continued the examination oneon-one with each individual applicant. This strategy ensures that if one applicant is 

experiencing difficulty, the other will not be “dragged down” and can still be given a fair, 

objective assessment. Daily verbal questioning of students by the instructor during class 

helps determine ability and compatibility.

Working with two applicants at a time offers an advantage that working with one 

applicant at a time does not; it affords an examiner the opportunity to gauge interaction 

between two applicants and “exercise proper DRM competencies,” as stated in the 

Aircraft Dispatcher PTS. In a single applicant environment, the examiner can and should 

simulate a pilot-dispatcher interaction in which the examiner plays the role of a PIC. 

However, having two applicants at a time allows the examiner to view interaction 

between the applicants at a peer level – something that is much harder to do one-on-one. 

Given that competent dispatching is highly dependent upon interpersonal communication, 

that intangible skill can be evaluated more easily in a two-applicant scenario.

Since we have not been advised of any safety reasons requiring that we abandon this 

procedure and given that the FAA has already found it to be acceptable, we believe that 

this demonstrates that safety will not be jeopardized by allowing the exemption or Order 

8900.1 revision. We further believe that if there are safety concerns that have arisen from 

other schools’ DADEs having attempted to administer 5, 6, 10, or more daily exams, 

whether simultaneous or not, adding restrictions to our program for wrongdoing that we 

did not commit is capricious at best, and actionable at worst. 
6

We’ve all heard some of the stories: regulations-less orals, coaching during orals, openbook orals, meeting failed students to administer orals at airports, etc.. A gem from “up 

north” is a guy charging over $400 for a practical exam, but would only give a 15-minute 

oral one Friday “because I need to get home and you took too long on your flight plan.” 

Others “won’t come in for less than four people.” This information is fed to me all the 

time from current students, graduates, and prospective students.

THESE are examples that compromise airline safety in addition to being unethical. 

Certifying applicants in any manner stated above is a sin and spits in the face of a 

profession rooted in the concept of a “checks and balances” system. As you are all aware, 

many pilots view airline dispatchers as “clerks” which defeats the purpose and successful 

application of 121.533/535 and 121.601.

If our petition is denied on the basis of safety, we request an explanation as to the reasons 

that safety would no longer permit an established practice that the Administrator has 

already deemed to be safe.

Public Interest

The general public is not affected by this exemption or Order 8900.1 revision. The 

greatest impact is on those who choose to attend not only Sheffield School of 

Aeronautics, but also any Part 65 aircraft dispatcher training facility that routinely enrolls

large classes, or will occasionally enroll large classes following the next economic 

recovery.

As mentioned previously, a significant portion of the enrollment of a typical Sheffield 

School certification class are international students, who, out of necessity, must make 

their travel and visa arrangements far in advance. Under policies that have been in place 

until now, a single examiner could give two practical exams per day, with a maximum of 

two applicants at a time. Therefore, each DADE has had the capacity to evaluate a total 

of four applicants in a day. By limiting this to two exam sessions, this allowed DADEs 

to be efficient in their evaluation of a class of graduates, while at the same time avoiding 

the fatigue issues that would certainly arise from administering four consecutive exams.

This allows for a student who is planning to attend a dispatcher school to be able to plan 

for a minimal period of time after completion of the Part 65 course to allow for the 

scheduling of a practical examination. Even in the event of a large class of graduates 

waiting to take practical exams, the waiting period would still be a matter of several days. 

Some applicants are asked to interview at airlines THE DAY AFTER GRADUATION 

while others are (unfairly) requested to return to their workplace 1-3 days after the class 

graduation date. 

We believe that the public interest IS served by continuing to allow for this practice, and 

that the public interest is NOT served by disallowing the practice. In the event that only 
7

one DADE and no ASIs are available to examine a group of 25 individuals, even if twoa-day exams are given with no days off for that DADE, this means that two individuals 

would be examined fully 13 days after the completion of a course. This places a 

significant burden and expense upon those individuals.

We believe, therefore, that suddenly adding this restriction places additional hardships on 

those who are seeking certification, and therefore that removing the ability to conduct 

simultaneous practical exams for not more than two applicants is not in the public 

interest.

Before requesting this exemption or Order 8900.1 revision, we considered alternative 

solutions to this problem, and found that all of them create additional difficulties not only 

for us, but also for the Flight Standards Service.

First, by disallowing an established practice, the FAA ostensibly assumes the 

responsibility to provide the practical examinations. It is clear to us from conversations 

with Mr. that the FLL CMO is experiencing a period of extreme workload in 

overseeing Part 121 operations, and that the CMO cannot provide inspectors on a regular 

basis to perform this task.

The other solution would be to secure the services of additional DADEs within the area. 

Although there are several Part 121 dispatch sections in the area, this proves problematic 

for numerous reasons.

First, DADEs who are not affiliated with a school who are active Part 121 dispatchers 

cannot be expected to be available regularly, six, seven, or more times per year. Their 

primary responsibility and focus will be their “primary” job of Part 121 dispatch. Simply 

appointing additional DADEs does not guarantee that they will be available, and 

therefore does not reliably solve the problem. In order to ensure the necessary coverage 

for a school that graduates as many students as does Sheffield School even during a 

recession, numerous additional DADEs would need to be found. This is similar to the 

problem that a dispatch manager may face in covering open shifts; there may be 

numerous individuals qualified, but work rules, vacation and sick days and other 

obligations mean that even four or five potential candidates may not be available.

In addition, were the CMO to secure the services of additional DADEs, this would mean 

additional oversight. The CMO would be responsible for initial and recurrent training of 

the DADE, maintenance of records and a continuity book, scheduling of observation for 

that many additional examiners throughout the year, etc. Again, our CMO is already 

facing critical workload issues based upon the information provided by Mr. this 

option does not seem to be the best available from that perspective. (We note that in such 

a critical workload situation, appointing and managing additional DADEs might actually 

jeopardize aviation safety by requiring additional resources of the CMO.)

Finally, we have concerns about some of the operations from which Mr. might 

seek DADE candidates. Dispatch at one of the largest operators in this area was recently 
8

found to be deficient in multiple areas during a major inspection. With the knowledge 

and encouragement of the Dispatch ASI (and we believe it was Mr. Sheffield 

School was contracted to perform a rapid refresher course of general topics including 

aviation weather, aeronautical charting, regulations and OpSpecs, AIP specific to the area 

of operations and also DRM. During the conduct of this training, we were alarmed at 

some of the deficiencies that we witnessed, which included some of the dispatchers 

inability to consistently interpret visibility and ceiling information from TAFs during 

given ETA blocks or consistently apply 121.619; ironically, some of the more senior 

dispatchers had the most difficult time. Although graduates of any approved Part 65 

dispatcher certification course will be instructed and examined in large turbojet aircraft, 

this operator utilizes only turboprops; therefore, we would question whether their 

dispatchers would have sufficient knowledge of turbojet systems, limitations and 

characteristics to be a DADE for such a program; a graduating student who is applying 

for the practical exam would conceivably know the aircraft better than the examiner. 

This difference between the DADE’s experience and knowledge and the material to be 

covered in the practical exam would be grounds for additional oversight of the new 

DADE by the CMO.

The other large operator whose dispatch office is overseen by the FLL CMO is an air 

carrier for which both current DADEs assigned to Sheffield have been previously listed 

as ground instructors. Both DADEs, in that ground instructor capacity, have provided 

general topics instruction as part of that air carrier’s recurrent training program. We also 

found and expressed concerns about similar topics there. Although this operator does 

work with turbojets, theirs are from a different manufacturer with different systems and 

planning practices. 

This is not to state that there are no potentially qualified applicants in this area, but 

simply to point out that we have reasons to be concerned about a portion of the potential 

pool, and to highlight the challenges that the CMO would face in resolving the problem 

both short- and long-term by adding DADEs in this area.

In the end, we believe that the public interest would be better served by allowing the 

continuation of the existing practice, with due FAA oversight and surveillance. This 

would ensure reasonable scheduling of practical exams, while at the same time ensuring 

that the examiners are well versed in the aircraft and simulated company procedures with 

which the applicant is already familiar. It also seems to be the most expedient solution 

available to the CMO.

In the event that the Administrator determines that continuing this practice is not allowed 

by the public interest, we request a written explanation as to why a practice that has 

already been deemed to be consistent with the public interest, no longer serves that 

interest.
9

Concerns Regarding the Development of National Policy

In requesting this exemption or Order 8900.1 revision, we would also like to protest the 

fashion in which this national policy was developed. We believe that the process used to

create this new policy violated multiple standards of customer service and 

professionalism that are demanded by Order 8900.1 to be demonstrated by all ASI’s.

In general terms, Volume 1, Chapter 3, Section 2 states that professionalism is a set of 

behavioral traits that enhances mission effectiveness by, among others, fostering 

collaboration with others and focusing on customer service. We recognize that the FAA 

is charged with overseeing operators and has a very careful line to walk between 

oversight and customer service responsibilities. 

However, given the tasking to establish national policy regarding examiners, we believe 

that the customer service standards were overlooked. Among others, this section of the 

Order stipulates that the inspectors will:

• Understand customer requirements at the outset of assignments.

• Ask questions to assure understanding of customer expectations.

• Ensure that requirements are incorporated into final work products and designs.

• Explain recommendations and decisions in a manner appropriate for the audience

• Listen to, accept, and act on customer feedback.

• Work with the public and industry to achieve and maintain regulatory compliance 

and improve safety.

• Avoid action or inaction that contributes to the public perception of unfair or 

disparate treatment.

Sheffield School of Aeronautics has long tried to assist the FAA by requesting 

interpretations of regulations and national policy on behalf of our graduates who ask us, 

forwarding concerns from active dispatchers about their carriers who were afraid to do so

directly, forwarding complaints about known and documented regulatory violations, and 

expressing opinions on existing policies. 

If you review the records of all DADEs attached to Sheffield School throughout its 

history, you will find that we have collectively administered over 3,000 practical 

examinations over a period spanning decades.

It is therefore inconceivable to us that when the Flight Standards Service decided to 

generate national policy to improve the administration of aircraft dispatcher practical 

examinations, we were not contacted until after the policy rewrite was completed. In an 

active dispatch environment, failing to approach a colleague who has years of experience 

when you are having a problem could be deemed to be a breakdown of DRM. Yet, the 

authors of this policy apparently made no attempt to contact those in the industry who 

could offer advice about best practices, what works, what does not work and any 

concerns going forward. 
10

This is all the more surprising to us in light of recent attempts to add policy in the 8900.1 

to allow for contract dispatching, which, as a concept, violates Flight Standards Policy. 

Nevertheless, there was closed-door authoring of procedures in Order 8900.1 to allow for 

that, with strong conflict-of-interest ties to a particular company that was already 

beginning their strategy to advertise and supply this service before this policy writing was 

completed. The outcry of the Airline Dispatcher’s Federation and indeed Congressional 

intervention prevented this closed-door rewrite of national policy from being enacted.

With this history in mind, we were positively stunned that we were not offered a chance 

to offer advice or concerns about any proposed improvements. Sheffield School would 

welcome the opportunity to work with the FAA to create sound policy; that we were 

excluded from this process in violation of customer service standards after the contract 

dispatch affair is inconceivable, unless the policy was crafted with the specific intent of 

tying our hands in mind.

Mr. in his visit on November 5, made the statement to us that “you guys are 

different,” in reference to the size of our program and the volume of applicants that we 

process. That is true, but it also means that the FAA is aware of this. If you are a 

Dispatch ASI reading this petition, then the chances are quite good that we know you 

personally or have had contacts with you at some point. All of you, having ties with the 

industry, are aware of the size and status of this school.

Therefore, our most grave concern is that this policy that was crafted outside the public 

view, was written in such a way to affect the operations of the one school that currently, 

even during a global recession, has sufficient size and volume to be affected. One of our 

DADEs noted in a recent discussion with an ASI, that the imposition of this policy that 

would affect our operations but not others when we are doing our best to uphold the 

standards seemed like disparate treatment. That Dispatch ASI did not disagree or debate 

that point; and therefore, we believe this is an admission that the ASI customer service 

standards were not followed.

In recent contacts, when we asked who authored the new policy, we were told by another 

Dispatch ASI that is was “the Administrator,” which is of course legally correct. 

However, neither Mr. Babbitt himself nor AFS-1 has the technical expertise to author 

these standards. Therefore, we have to assume that this was collective work by the 39 

Dispatch ASIs in the name of the Administrator. We cannot believe that all 39 ASIs 

were actually involved with this project, but it is difficult to believe that not one of the 

ASIs who did work on this saw the ethical and customer service standards violation –

particularly so soon after the contract dispatch affair.

It is not our intent to excoriate the ASI cadre, as we understand that you are all severely 

overworked at the moment. We realize that involving customers in these changes would 

delay the process. We would like to believe that this was simply a rush to bring a 

difficult project to completion. But in so doing, we believe that a violation occurred, and 

we would like to request for the record that we have the ability to participate as a 

collaborative partner in the future.
11

Summary

In summary, we request the following:

• Sheffield School of Aeronautics, and the DADEs attached thereto, request an 

exemption or Order 8900.1 revision from national policy to conduct practical 

examinations for not more than two applicants simultaneously. Under such 

exemption or Order 8900.1 revision, DADEs would still adhere to the two-fullexam-per-day criterion; but would be able to examine a maximum of two 

applicants during each exam, for a total of maximum four applicants daily.

• If there is a concern about examiner fatigue, Sheffield School would agree to 

waive the DADE’s allowance to also conduct a retest in the same day.

• We understand that such an exemption or Order 8900.1 revision would mean that 

additional oversight and surveillance could be warranted. We welcome that, and 

we encourage Dispatch ASIs to observe and offer any feedback which may result 

in better exam practices.

• We recognize that one-applicant-at-a-time is still the preferred method of 

administering the practical examination and would utilize the two-at-a-time 

exemption or follow the Order 8900.1 revision only when class size and student 

travel requirements demand it. We also agree that it is appropriate to notify the 

FAA specialist having jurisdiction over the DADEs as required.

• We encourage a revision to the relevant parts of Order 8900.1 to allow this 

exemption or approval to be granted by local inspectors who are responsible for 

the approval and maintenance of DADEs, as the needs of the local inspector 

require. We understand that it is conceivable that other Part 65 programs could 

face unexpected, unusually large classes that would similarly exceed the ability of 

the inspectors and existing DADEs to manage. This exemption or Order 8900.1 

revision, if allowed, nationally, will allow the Dispatch ASIs to rapidly 

accommodate a sudden increase in demand for practical examinations without any 

decrease in the quality of service offered to the public.

Finally, we request that we be included in the process of drafting any additional policy 

regarding Part 65 courses or DADEs. We understand that we are a customer and that the 

final policy-making rests with the FAA, but we would like to assist in any way we can. 

To quote one ASI, we need to “raise the bar” on dispatcher certification, and we at 

Sheffield School would welcome any opportunity we have to assist you in that end. 

Attached is a quick-view comparison table along with an official school evaluation from 

the FAA.

Respectfully,

Eric W. Morris - President

Sheffield School of Aeronautics (est. 1948)
12

APPENDIX

Why using DADEs outside of legitimate Part 65 schools diminishes airline safety & 

overburdens FAA FSDOs and their respective safety inspectors, and why DADES 

attached to a school better serve public interest.

Sheffield DADEs ASIs & Non-Sheffield DADEs

Employees or officials of 62-year institution. Overworked ASIs with primary responsibility of 

overseeing a multitude of Part 121 air carriers or 

airline employees working shifts.

DADEs have the ability to conduct, complete all 

practical exams AND required FAA certification 

paperwork for 25+ POTENTIAL APPLICANTS, up to 

6 times per year, within a reasonable period of 

time. Also, have the time and expertise to deal with 

a multitude of certification paperwork issues 

ranging from lost certificates to rectifying errors 

committed by others. We also are willing to spend 

the time on the telephone on hold with the FAA 

Airman Branch for technical issues, questions, and 

other matters.

DADEs will NOT have the ability to conduct, 

complete all practical exams AND required FAA 

certification paperwork for 25+ POTENTIAL 

APPLICANTS within a reasonable period of time. A 

currently buggy IACRA system will provide no relief 

from checking, rechecking for errors, and calling 

tech support at the FAA Airman Branch for lost 

paperwork, missing or lost permanent certificates.

Will the ASI trying to run to the local 121 airline or 

the assigned DADE trying to make his shift have 

time to call the Airman Branch to explain why the 

ADX test is not to be included on a newly-turned 

23-yr old applicant’s paperwork or how to rectify 

his/her South Korean’s applicants’ address on the 

permanent certificates? - the ones with ‘North 

Korea’ typed in. [true story.]

Tech support: We answer all questions ranging 

from “how do I change my address?” to “I lied –

my eyes aren’t blue-what now?” to “now I’m a girl 

– do I need to tell the FAA?”

Tech support?

Desire or time to do this? 

DADEs will have no problem submitting all 

paperwork within required 7-day period.

DADEs will be UNABLE to consistently submit all 

paperwork within required 7-day period for any 

reasonably-sized class.

Work at school full-time. Work at FSDO or airline.

Available everyday including weekends. May not be available or limited consecutive days.

Can conduct exams at ANY time of day to help 

meet applicants’ travel schedules.

Cannot or will not always conduct exams at ANY 

time of day to help meet applicants’ travel 

schedules.

Requires no travel by applicant. May require travel and appointment by applicant.

DADE familiar with ALL SPECIFIC subject matter 

instructed at school.

DADE NOT familiar with ALL SPECIFIC subject 

matter instructed at school.

DADE familiar with LARGE TURBOJET subject 

matter instructed at school.

DADE MAY NOT BE familiar with LARGE TURBOJET 

subject matter instructed at school.

DADE familiar with FLAG OPS subject matter 

instructed at school.

DADE MAY NOT BE familiar with FLAG OPS subject 

matter instructed at school.

DADEs have proven track record of email requests 

on interpretation of current and proposed subject 

matter.

DADE MAY be employed by an airline and may not 

be well-versed on recent material required by FAA 

that is not found within their OPS manuals.

DADE familiar with ALL TYPES of approaches 

instructed at school.

DADE may not be familiar with ALL TYPES (i.e. LPV) 

subject matter instructed at school.

DADE requires no additional airplane manual 

references studied at school.

DADE must provide or request additional airplane 

manual references from applicant that were studied 

at school.

DADEs welcome any and all inspectors to observe 

FAA practical exams at any time.

DADEs may not have FAA practical exams 

monitored.

Sheffield DADEs have cumulatively conducted 

1000s of FAA practical exams.

DADEs will likely have very little or zero experience 

conducting FAA practical exams.

Sheffield DADEs have proven continuously that the 

conduct of our practical examinations is exemplary, 

including detailed ASI report from July 2003.

Newly qualified ASIs’ and newly qualified DADEs’ 

experience will be minimal or nil; that, coupled with 

being already assigned other tasks, or other jobs, 

may raise safety concerns.
Memorandum

Orlando Flight Standards District Office

5950 Hazeltine National Drive

Citadel International, Suite 500

Orlando, Florida 32822

Subject: INFORMATION: Findings from Special Inspection of 

Sheffield School of Aeronautics 14 CFR Part 65 

Aircraft Dispatcher School

Date: July 14, 2003

From: Aviation Safety Inspector Reply to

Attn. of:

William L. Bonatti:

(407) 812-7763

FAX: (407) 812-7710

To: Theodore A. Perry, AFS-200

THRU: Dawn Veatch, ASO-201

This memo outlines the inspection that was conducted, per your request, at the Sheffield School 

of Aeronautics 14 CFR Part 65 Aircraft Dispatcher School.

The Inspection started on 07/09/2003 with a briefing with Mr. Eric W. Morris, President, and Mr. 

Ronald L. Morris Owner of Sheffield School of Aeronautics. In this briefing I informed them that 

I was conducting a special inspection of their facilities, program, training materials, and Practical 

Examination procedures. During this briefing Mr. Eric Morris gave me a full briefing as to the 

policies and procedure used by the school in conducting training, testing, and the Practical 

Examinations conducted. I was also given a copy of all the course materials, handouts, exercises, 

and course examinations for my review. At the completion of the briefing I was given a tour of 

the training facilities, which were found to be in compliance with 14 CFR Part 65.65.

A review of the course materials, handouts, exercises, and course examinations showed that the 

school has spent a lot of time and effort to prepare affective and efficient training and testing 

materials. The course materials used are current and up to date with the industry, and far exceed 

the needs of the course. In many cases Sheffield School of Aeronautics have produced materials 

that the student can use throughout their industry employment.

The Procedures used by Sheffield School of Aeronautics and the Designated Aircraft Dispatch 

Examiners (DADE’s) to conduct Area of Operation 1 “Dispatch Exercise” Task A “Flight 

Planning” is not commonly found, however it does meet the requirements of the Aircraft 

Dispatcher Practical Test Standards (FAA-S-8081-10A). The applicants are all given their Flight 

Planning Exercise at the same time. All applicants are required to remain in the testing room the 

entire time while being observed by one of the DADE’s. This portion of the examination is 

commonly conducted on a one on one basis by other designees, however they are normally only 

working with one applicant at a time. In the environment that Sheffield is conducting this portion 

of the Dispatcher Practical, it is as secure and allows the designee the ability to test the specific 

areas in which knowledge and skills must be demonstrated by the applicant before the issuance of 

an Aircraft Dispatcher Certificate with more efficiency and less time consumption. The security 
2

measures used to assure that each applicant does his own work are different exercises for each 

applicant and the exercise is observed by the DADE.

I physically observed this graduating class of 9 applicants complete this portion of the 

examination on 07/10/2003. The briefing was conducted by one of the DADE’s Mr. Brett J. 

Bories. The briefing was very detailed and covered everything that the applicants required to be 

able to conduct the exercise. Applicants were given 2 hours and 10 minutes to complete the 

exercise. Each applicant had his own desk, materials, and no sharing or talking was permitted. 

This allowed the applicant ample room to work within a comfortable environmental. Out of the 9 

applicants the first finished the exercise in 1 hour and 28 minutes and received a score of 93%. 

The last applicant to finish the exercise completed it in 2 hours and 10 minutes and received a 

score of 100%. The average time for all applicants was 1 hour and 55 minutes with an average 

score of 87%.

The remaining Areas of Operations requiring examination are conducted by oral questioning. 

Sheffield’s DADE’s conduct the oral portion of the examination in two different formats. One of 

the formats is with the DADE conducting oral questioning on a one-on-one basis with an 

applicant, while the other format is with the DADE conducting oral questioning with 2 applicants 

at the same time. The methods and procedures used by the DADE’s while conducting the one-onone type oral were found to be acceptable and in accordance with normal practical test procedures 

and the Aircraft Dispatcher Practical Test Standards. The methods and procedures used by the 

DADE’s while conducting the oral portion to 2 applicants at the same time were also found 

acceptable. The DADE’s were very effective in their questioning process and in directing specific 

questions to each applicant to assure that both applicants were questioned to an adequate level. 

The procedures and methods used were in accordance with the Aircraft Dispatcher Practical Test 

Standards, 8700.1 Volume 2 Section 3 paragraph 5(B), and the 8710.3C Chapter 5 paragraph 

19(C). 

The oral portions of the examination averaged 2 hours and 30 minutes for a one-on-one type oral, 

and 3 hours and 50 minutes for an oral conducted with 2 applicants. With these times, and the 

times from the flight planning exercise, the average practical examination time was 4 hours and 

25 minutes for a one-on-one exam and 5 hours and 45 minutes for group testing.

To summarize, the DADE’s conducted all practical tests in accordance with regulations, the 

Practical Test Standards, and procedures found in FAA guidance. The DADE’s did not allow 

personal prejudices to interfere with objective evaluation of an applicant, and the oral portion of 

the practical test was conducted in a private area free from distractions. The DADE’s gave the 

applicants their undivided attention during the test and ensured that any discussion of test results 

with the applicants was done in private unless, by mutual agreement, a person other than the 

applicants were present. 

William L. Bonatti

File: 

WP: Q:\TYPING\UNIT3\Bonatti\Sheffield.doc

ASO-FSDO-15:W Bonatti:WLB:(407) 812-7763:07/14/2003
APPENDIX H

(Denial: Request for Relief from

Requirements of Order 8900.1, Volume 13,

Chapter 3, Section 2, Par. 13-175)

(Denial: Request for Revision to Order

8900.1, Volume 13, Chapter 3, Section 2,

Par. 13-175)

RE: FAA Compliance with Order 8900.1,

Volume 1, Chapter 3, Section 2, Par. 1-177)

– not addressed correctly.

We asked for the FAA to comply with Order

8900.1, Volume 1, Chapter 3, Section 2, Par. 1-

177, it’s own “Standards of Professionalism for

Flight Standards (AFS).” In the first paragraph in

the denial letter that follows, Mr. Duncan states

that I asked for relief from YOUR OWN ETHICS

AND CONDUCT CODES. This indicates that major

portions of our original requests in Appendices F

& G were not even read or understood.

We are requesting an investigation into this matter.


APPENDIX I

Practical exam schedule per Order 8900.1

policy (~60 hours and based on LESS test

security)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980 –

www.sheffield.com

January 22, 2010

To:

– ASI

2895 SW 145 Ave, Suite 291

Miramar, FL 33027

Date Submitted: January 22, 2010

In Compliance with CMO-29 request for exam TIMES for:

[Jan-Feb Aircraft Dispatcher Certification Courses: FAA Aircraft Dispatcher Practical 

Examinations.]

Sheffield School of Aeronautics – February 2010

Note - FAA Aircraft Dispatcher Practical Examination Schedule/times – below 

are the only dates/presumed block times that can be confirmed at this point due to 

all aforementioned reasons stated in December 28, 2009 submission of test dates 

to your office. 

Eric W. Morris – 12 hours

Saturday, February 6, 2010 – 7:00 – 10:00 am – Flight Plan

Saturday, February 6, 2010 – 10:30am – 1:30 pm – Oral

Saturday, February 6, 2010 – 2:00pm – 5:00 pm – Flight Plan

Saturday, February 6, 2010 – 5:30pm – 8:30 pm – Oral

Brett J. Bories – 12 hours

Saturday, February 6, 2010 – 7:00 – 10:00 am – Flight Plan

Saturday, February 6, 2010 – 10:30am – 1:30 pm – Oral

Saturday, February 6, 2010 – 2:00pm – 5:00 pm – Flight Plan

Saturday, February 6, 2010 – 5:30pm – 8:30 pm – Oral

Eric W. Morris – 12 hours

Sunday, February 7, 2010 – 7:00 – 10:00 am – Flight Plan

Sunday, February 7, 2010 – 10:30am – 1:30 pm – Oral

Sunday, February 7, 2010 – 2:00pm – 5:00 pm – Flight Plan

Sunday, February 7, 2010 – 5:30pm – 8:30 pm – Oral

Brett J. Bories – 12 hours

Sunday, February 7, 2010 – 8:00 – 11:00 am – Flight Plan

Sunday, February 7, 2010 – 11:30am – 2:30 pm – Oral

Sunday, February 7, 2010 – 3:00pm – 6:00 pm – Flight Plan

Sunday, February 7, 2010 – 6:30pm – 9:30 pm – Oral
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980 –

www.sheffield.com

Eric W. Morris – 12 hours

Monday, February 8, 2010 – 7:00 – 10:00 am – Flight Plan

Monday, February 8, 2010 – 10:30am – 1:30 pm – Oral

Monday, February 8, 2010 – 2:00pm – 5:00 pm – Flight Plan

Monday, February 8, 2010 – 5:30pm – 8:30 pm – Oral

Brett J. Bories – 12 hours

Monday, February 8, 2010 – 8:00 – 11:00 am – Flight Plan

Monday, February 8, 2010 – 11:30am – 2:30 pm – Oral

Monday, February 8, 2010 – 3:00pm – 6:00 pm – Flight Plan

Monday, February 8, 2010 – 6:30pm – 9:30 pm – Oral

Eric W. Morris – 12 hours

Tuesday, February 9, 2010 – 7:00 – 10:00 am – Flight Plan

Tuesday, February 9, 2010 – 10:30am – 1:30 pm – Oral

Tuesday, February 9, 2010 – 2:00pm – 5:00 pm – Flight Plan

Tuesday, February 9, 2010 – 5:30pm – 8:30 pm – Oral

Brett J. Bories – 12 hours

Tuesday, February 9, 2010 – 8:00 – 11:00 am – Flight Plan

Tuesday, February 9, 2010 – 11:30am – 2:30 pm – Oral

Tuesday, February 9, 2010 – 3:00pm – 6:00 pm – Flight Plan

Tuesday, February 9, 2010 – 6:30pm – 9:30 pm – Oral

Eric W. Morris – 12 hours

Wednesday, February 10, 2010 – 7:00 – 10:00 am – Flight Plan

Wednesday, February 10, 2010 – 10:30am – 1:30 pm – Oral

Wednesday, February 10, 2010 – 2:00pm – 5:00 pm – Flight Plan

Wednesday, February 10, 2010 – 5:30pm – 8:30 pm – Oral

Brett J. Bories – 12 hours

Wednesday, February 10, 2010 – 8:00 – 11:00 am – Flight Plan

Wednesday, February 10, 2010 – 11:30am – 2:30 pm – Oral

Wednesday, February 10, 2010 – 3:00pm – 6:00 pm – Flight Plan

Wednesday, February 10, 2010 – 6:30pm – 9:30 pm – Oral

Thank you for your attention in this matter. If there are any questions or concerns, please 

contact me as soon as possible. I will assume that you do not require this schedule to be 

mailed since it is printable. 

Eric W. Morris - President - Sheffield School of Aeronautics (est. 1948)
APPENDIX J

Practical exam schedule following Order

8900.1 policy if approved for simultaneous

flight plan exercise (~33 hours-based with

COMPLETE TEST SECURITY)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980 –

www.sheffield.com

How these 5 days SHOULD be conducted to avoid fatigue, be time efficient, enable 

complete flight plan test security, and remain in the public interest of individuals and 

airlines. This maintains the 2 full exams per day limit requirement, but permits the flight 

plan to be given at one time, with different versions in a 100% controlled secure testing 

environment.

Sheffield School of Aeronautics – February 2010

Eric W. Morris & Brett J. Bories – 9 hours 

Saturday, February 6, 2010 – 8:00 – 11:00 am – Flight Plan 

Eric W. Morris

Saturday, February 6, 2010 – 11:30am – 2:30 pm – Oral

Saturday, February 6, 2010 – 3:00pm – 6:00 pm – Oral

Brett J. Bories 

Saturday, February 6, 2010 – 11:30am – 2:30 pm – Oral

Saturday, February 6, 2010 – 3:00pm – 6:00 pm – Oral

Eric W. Morris – 6 hours

Sunday, February 7, 2010 – 8:00 – 11:00 am – Oral 

Sunday, February 7, 2010 – 11:30am – 2:30 pm – Oral

Brett J. Bories – 6 hours

Sunday, February 7, 2010 – 8:00 – 11:00 am – Oral 

Sunday, February 7, 2010 – 11:30am – 2:30 pm – Oral

Etc....

For approximately ~33 hours over 5 days would be required to examine 20 students, 

instead of 60 hours in the same period. Remember, these times EXCLUDE retests, 

and assumes both DADES will be available, and will not rely on the local office for 

assistance.

Eric W. Morris - President - Sheffield School of Aeronautics (est. 1948)
APPENDIX K

Findings from Special Inspection of Sheffield

School of Aeronautics 14 CFR Part 65 Aircraft

Dispatcher School – July 14, 2003

William L. Bonatti

Aviation Safety Inspector
Memorandum

Orlando Flight Standards District Office

5950 Hazeltine National Drive

Citadel International, Suite 500

Orlando, Florida 32822

Subject: INFORMATION: Findings from Special Inspection of 

Sheffield School of Aeronautics 14 CFR Part 65 

Aircraft Dispatcher School

Date: July 14, 2003

From: Aviation Safety Inspector Reply to

Attn. of:

William L. Bonatti:

(407) 812-7763

FAX: (407) 812-7710

To: Theodore A. Perry, AFS-200

THRU: Dawn Veatch, ASO-201

This memo outlines the inspection that was conducted, per your request, at the Sheffield School 

of Aeronautics 14 CFR Part 65 Aircraft Dispatcher School.

The Inspection started on 07/09/2003 with a briefing with Mr. Eric W. Morris, President, and Mr. 

Ronald L. Morris Owner of Sheffield School of Aeronautics. In this briefing I informed them that 

I was conducting a special inspection of their facilities, program, training materials, and Practical 

Examination procedures. During this briefing Mr. Eric Morris gave me a full briefing as to the 

policies and procedure used by the school in conducting training, testing, and the Practical 

Examinations conducted. I was also given a copy of all the course materials, handouts, exercises, 

and course examinations for my review. At the completion of the briefing I was given a tour of 

the training facilities, which were found to be in compliance with 14 CFR Part 65.65.

A review of the course materials, handouts, exercises, and course examinations showed that the 

school has spent a lot of time and effort to prepare affective and efficient training and testing 

materials. The course materials used are current and up to date with the industry, and far exceed 

the needs of the course. In many cases Sheffield School of Aeronautics have produced materials 

that the student can use throughout their industry employment.

The Procedures used by Sheffield School of Aeronautics and the Designated Aircraft Dispatch 

Examiners (DADE’s) to conduct Area of Operation 1 “Dispatch Exercise” Task A “Flight 

Planning” is not commonly found, however it does meet the requirements of the Aircraft 

Dispatcher Practical Test Standards (FAA-S-8081-10A). The applicants are all given their Flight 

Planning Exercise at the same time. All applicants are required to remain in the testing room the 

entire time while being observed by one of the DADE’s. This portion of the examination is 

commonly conducted on a one on one basis by other designees, however they are normally only 

working with one applicant at a time. In the environment that Sheffield is conducting this portion 

of the Dispatcher Practical, it is as secure and allows the designee the ability to test the specific 

areas in which knowledge and skills must be demonstrated by the applicant before the issuance of 

an Aircraft Dispatcher Certificate with more efficiency and less time consumption. The security 
2

measures used to assure that each applicant does his own work are different exercises for each 

applicant and the exercise is observed by the DADE.

I physically observed this graduating class of 9 applicants complete this portion of the 

examination on 07/10/2003. The briefing was conducted by one of the DADE’s Mr. Brett J. 

Bories. The briefing was very detailed and covered everything that the applicants required to be 

able to conduct the exercise. Applicants were given 2 hours and 10 minutes to complete the 

exercise. Each applicant had his own desk, materials, and no sharing or talking was permitted. 

This allowed the applicant ample room to work within a comfortable environmental. Out of the 9 

applicants the first finished the exercise in 1 hour and 28 minutes and received a score of 93%. 

The last applicant to finish the exercise completed it in 2 hours and 10 minutes and received a 

score of 100%. The average time for all applicants was 1 hour and 55 minutes with an average 

score of 87%.

The remaining Areas of Operations requiring examination are conducted by oral questioning. 

Sheffield’s DADE’s conduct the oral portion of the examination in two different formats. One of 

the formats is with the DADE conducting oral questioning on a one-on-one basis with an 

applicant, while the other format is with the DADE conducting oral questioning with 2 applicants 

at the same time. The methods and procedures used by the DADE’s while conducting the one-onone type oral were found to be acceptable and in accordance with normal practical test procedures 

and the Aircraft Dispatcher Practical Test Standards. The methods and procedures used by the 

DADE’s while conducting the oral portion to 2 applicants at the same time were also found 

acceptable. The DADE’s were very effective in their questioning process and in directing specific 

questions to each applicant to assure that both applicants were questioned to an adequate level. 

The procedures and methods used were in accordance with the Aircraft Dispatcher Practical Test 

Standards, 8700.1 Volume 2 Section 3 paragraph 5(B), and the 8710.3C Chapter 5 paragraph 

19(C). 

The oral portions of the examination averaged 2 hours and 30 minutes for a one-on-one type oral, 

and 3 hours and 50 minutes for an oral conducted with 2 applicants. With these times, and the 

times from the flight planning exercise, the average practical examination time was 4 hours and 

25 minutes for a one-on-one exam and 5 hours and 45 minutes for group testing.

To summarize, the DADE’s conducted all practical tests in accordance with regulations, the 

Practical Test Standards, and procedures found in FAA guidance. The DADE’s did not allow 

personal prejudices to interfere with objective evaluation of an applicant, and the oral portion of 

the practical test was conducted in a private area free from distractions. The DADE’s gave the 

applicants their undivided attention during the test and ensured that any discussion of test results 

with the applicants was done in private unless, by mutual agreement, a person other than the 

applicants were present. 

William L. Bonatti

File: 

WP: Q:\TYPING\UNIT3\Bonatti\Sheffield.doc

ASO-FSDO-15:W Bonatti:WLB:(407) 812-7763:07/14/2003
APPENDIX L

Staggered exams request – to prevent FATIGUE
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980 –

www.sheffield.com

January 7, 2010

To:

Federal Aviation Administration

Certificate Management Office - 29

Attn. ASI

2895 SW 145 Avenue, Suite 291

Miramar, FL 33027

Mr. 

Request

Due to the recent denial of our request to continue conducting simultaneous FAA 

practical examinations as approved by the FAA for the past 3+ decades, as per the 

relatively new Order 8900.1, we are now kindly requesting the approval by our 

assigned FAA Specialist, to allow the DADEs of Sheffield School (Eric 

Morris and Brett Bories) the flexibility of “staggered” practical examinations per 

Order 8900.1 Volume 13, Chapter 3, Section 2, Paragraph 13-175c and Order 

8900.1 Volume 13, Chapter 3, Section 4, Paragraph 13-223-(General note). We 

would not plan “staggering” of examinations during any FAA observation time unless 

authorized to do so.

Background

Sheffield School has historically had such a large quantity of students and graduates 

that we have, at any one time, had anywhere from 2-4 DADEs prepared to cover all 

FAA Aircraft Dispatcher practical examinations. The Sheffield School historical 

records within your office will verify that statement.

The FAA Aircraft dispatcher practical exam consists of two portions or

phases - the flight plan exercise and oral portion. Since we have

demonstrable proof of larger than typical class sizes, including the current

class enrollment of 21 students, we will require many consecutive days of testing. 

We plan to conduct the practical exams based on newly enforced policy using the two 

DADEs for as long as 4-8 consecutive days. If one of the DADEs becomes 

unavailable, the possible exam days double without assistance.

The flight plan portion could conceivably take 3 hours for an applicant to

complete as it is based on manual planning. The oral portion usually takes

anywhere from 2-4 hours, and as stated in Order 8900.1, there is no mandatory

maximum time limit, only a suggested cumulative limit of 6 hours. Since short 

breaks may be required periodically for human functions along with the

non-predictable average pause length between questions and answers, one

single applicant may take as long as 6-7 hours for a FULL practical. Since we now 

should document the correctness of EVERY question per one recommendation within 

Order 8900.1, this will add time to the oral portion. Since we are only allowed 2 full 

practical exams per day and have received no flexibility from AFS-200, AFS-220, or 

CMO-29, to conduct more exams per day, we need many consecutive days of exams. 

Since we cannot limit ourselves to only one exam per day and keep graduates 

around for over 2 weeks, we are in a potential position to need to conduct two 
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980 –

www.sheffield.com

practical exams per examiner, per day, for conceivably 12-14 hours per day for 4-8 

consecutive days in order to serve the public interest and airline employee 

scheduling requirements. Staggering exams would help alleviate this problem.

To conduct 2 non-staggered practical exams per day may extend our working

day to over 12 hours. We consider this a fatigue issue. As evidenced in a variety of 

FAR duty-time limitations, fatigue appears to be a regulatory concern after 8-10 

consecutive hours of duty or work; by not allowing us the opportunity and flexibility 

to stagger our practical examinations we would conceivably be exceeding the duty 

time limitations of a working Part 121 aircraft dispatcher. To avoid having a 10-14 

hour day for a string of 4-8 days, we kindly ask for approval to permit a “staggering” 

of practical exams per wording in the aforementioned Order 8900.1 paragraphs. This 

should not be considered as an exemption request from National Policy. The FAA 

Specialist assigned to us has the ability, per current policy, to approve this request. 

We can locate no policy prohibiting the FAA Specialist from making an informed 

decision. If there is such a policy, please let us know so that we can forward/copy all 

requests directly with AFS-200, and possibly AFS-1 from now on.

Other complicating factors without “staggering” authorized:

Many students depart in the late afternoon, especially the high percentage of 

European students enrolled at Sheffield – they will not be able to be scheduled for 

the 2nd test of the day since they cannot complete the exam by their departure time. 

This leaves them only able to take the exam in the early AM. If most flights are 

scheduled this way, and we have no control over how individuals or airlines schedule 

their flights even with specific warnings from us regarding exam delays, this could in 

fact double the days needed to accomplish this task without the ability to stagger 

and complete the 2nd full practical of the day before late evening to midnight.

Assigning additional DADEs to perform these duties outside of their normal hours of 

employment is counterproductive to their own fatigue issues based on the referenced 

duty time limitations in FAR 121.465 or any other related duty time limitations within 

the regulations. Although conducting practical examinations may not count toward 

their company’s duty time limitations, repeated days of 10-hour shifts plus 6-7 hour 

practical exam sessions will render those dispatchers fatigued while on duty.

Using outside DADEs is not a viable option since they are to be located, trained, 

authorized, be familiar with our aircraft used, and be properly overseen outside their 

district, all by early February – when our first 2010 practical exams commence. They 

would also need to be available outside of normal business hours and during 

weekends and holidays.
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980 –

www.sheffield.com

Conclusion

Approval of this request may prevent the local District Offices from having to relieve 

Sheffield DADEs due to fatigue. If this request is denied, please state clearly the 

reasons for the denial, as this is NOT a request to deviate from National policy based 

on the wording of Order 8900.1.

If any instructor resigns or is terminated from employment, Mr. Bories shall become 

the instructor, leaving a single DADE to handle and process 15-30 graduates at a 

time; therefore, if this scenario arises, a “staggering” allowance would greatly assist 

us.

As your records must show, Sheffield School has had 5 DADEs over the past 34 

years. For approximately 2 years, we used and needed 4 DADEs at the same time. 

For a 6-year period, we were approved and utilized 3 DADEs. For the past 5 years, 

we’ve reduced the number of DADEs to 2 due to retirement, DADE resignation, and 

death. We believe that since we have had our previously FAA-approved method of 

flexible operation greatly restricted due to policy change and denial of rewrite or 

exemption, it is a reasonable request to ask for “staggering” of exams. To reduce a 

10-14 hour workday to 6-9 hours and/or reduce the total number of consecutive 

days of exams by one over a week’s period is more than reasonable, safe, and in the 

public interest.

This request is based on policy checked online via FSIMS and current as of January 

4, 2010. 

Thank you for your time and understanding.

Eric W. Morris

President

Sheffield School of Aeronautics (est. 1948)

Brett J. Bories

Assistant Director of Training

Sheffield School of Aeronautics (est. 1948)
Appendix M-1

Appendix M – ASI statements

RE: CMO-29 office, ASI 

We feel that Mr. is either unqualified for this task or is trying to be difficult,

or both. We are seeking that this matter be resolved so that Sheffield School of

Aeronautics, established in 1948, without a blemish on it’s record, can continue to

work harmoniously with the FAA and proceed forward. We suggest assigning an

ASI/FAA Specialist to myself and Brett Bories, as DADE oversight, and to Sheffield

School as a school inspector, who is both capable and competent, and has the time

to assist us effectively and efficiently. We have NEVER had oversight issues,

apparent conflicts, and lack of timely assistance from any inspectors, until recently.

Likely rebuttal: “Sheffield and others are finally getting true oversight.”

Our counter argument to this supposedly “better oversight” is below:

Oversight questions:

We were handed a letter from the CMO-29 office indicating ASI was

the FAA Specialist assigned to Mr. Bories and Eric Morris, as DADEs; however, school

certificate/oversight contact or official statement was missing.

Part 65 schools online indicate of FSDO-19 as our school inspector.

Mr. denied being our school inspector in an email and stated he was told we

should have been under CMO-29 all along.

 (located in CMO-29 building or FSDO-19) on phone – “Why are CMO-29

watching you? They are air carrier – that’s why I was removed from you.”

statements:

1st meeting (Oct 2009):

“I have been assigned to you.” “I did not request this assignment.” “I am busy

overseeing twenty-one Part 121 air carriers.” [By a December 23, 2009 meeting, it

reduced to “4 air carriers.” [The word “I” was always used.]

“I am willing to learn from you, I have no expertise.”

“I am not your FAA Specialist” followed by “I am your FAA specialist” within 30-45

seconds. All within 30 minutes after handing me a October 26, 2009 dated letter

from CMO-29 office stating that “ is now the assigned FAA Specialist

maintaining oversight of your designated examiner appointment.”

“I’m not your POI.” to Brett Bories and Eric Morris after inquiring about school

oversight, followed shortly thereafter by “I am your POI” to my instructor in the

classroom.

Mr. did not understand the difference between an Airmen report and

practical examination requirements - he claimed that the ADX Knowledge test is

part of practical exam and asked why the ADX report did not state “take 2” on a FAA

practical exam retake – this validates Mr. inexperience and /or training.
Appendix M-2

“For exam retests, just email me – if I can get to it or not (oversight) – fine.”

[nothing wrong – just documenting for the record to prepare for a change of position

or denial of statement.]

“Can send paperwork after 7 days if coordinated with me.” [nothing wrong – just

documenting for the record to prepare for a change of position or denial of

statement.]

Initial TCO requests were – “just send differences for shorter classes, not entire

thing.” This evolved into sending “full TCOs”, edits, more edits, and now provisional

acceptances with delays for final approvals. We have not heard of any progress on

these TCO approvals since January 5, 2010, which were edited EXACTLY as directed

(multiple times). We were granted a “temporary approval” until further reviewed.

Delay tactic now at 8 weeks without any further communication or guidance.

“Ted Perry and associated group likely authored current 8900.1”, which is huge

conflict of interest, as indicated elsewhere in this report.

Statements to Brett Bories on phone in early December 2009:

“How was course credit granted if no short course TCO?” We replied with all

inspectors have been ok with it, and approved everything. Additionally, FAR Parts

65.61d and 65.57 are wide open and AUTHORIZE credit.

“How can you advertise 200 hours if now only 5-weeks?” After having our advertising

information and access to our web site, we had to explain yet again how we instruct

longer days resulting in the same 200-hour requirement being met, etc.. Statement

(tone) was accusatory and not appreciated.

Dec 8 meeting:

“Long-time DADEs were consulted for the rewrite of 8900.1.”

[not me (over 850 exams), not Ron Morris (over 2500 exams), not Leon Jansen

(over 500 exams), or Brett Bories (over 300 exams).] If this statement is not true,

then ethics standards have been violated; if true, then this must be viewed as

vendetta action from higher offices. One other long-time DADE in Kentucky was also

not consulted, as verbally told to me about 2 weeks ago.

Following 3 statements are typical of the ever-changing story:

“Acting Manager only replies by certified mail or return receipt requested.” – then:

“ resigned” after I mentioned that he refuses to email a quick reply

to me, regarding receipt of mail sent to him from my office.

“Just found out today that he resigned” after I mentioned that “he’s resigning” and

“answering only via certified mail” are 2 different things.”

TCO change of directives:

Par. #13 – 2-3x – Mr. confirmed MULTIPLE (3) TIMES that adding “previous

experience along with FAR 65.61d” would suffice, then changed story via email

requesting details of how we credit per FAR 65.57, which was never discussed in

terms of credit amounts.

Office requests everything in writing “for accounting purposes” now after I asked

“can the CMO-29 office print an email pdf attachment?” Story then morphed into
Appendix M-3

“office can’t print the color logo on your letterhead because we only have a black and

white printer.”

 “The NTSB info is missing from TCO” = wrong, it was there.

From Dec. 8:

– Mr. claimed TCO errors with classroom information when he was missing a

page – all were emailed and mailed. Wrong again.

- “did you receive the denial (to our petition for 8900.1 relief) letter from AFS-200?”

then looked for a copy in his notebook, but claimed he did not know what was in the

letter. He stated that it will be our decision on how to proceed – he implied we have to

submit a reply to the letter. All the while denying what he knew about the letter. Brett

Bories and I are still confused to this day.

– “(an off-the record comment reserved for later, if needed)” after discussing

ownership and exam policy.

– veiled threats – “if you continue swimming against the flow, you will drown.” He said

we shouldn’t contact AFS-1, regarding various matters.

– Accused us for errors we did not make on certification paperwork:

Hana Yoo – graduate who failed practical on initial take, then passed retest - see

below:

During the visit by Dispatch ASI on Tuesday, December 8,

2009

The following communication occurred:

At 4:40pm, Mr. brought up a note from the paperwork for the retest of 

 administered by Eric Morris. First, he suggested that there could not be a retest

within 30 days unless the applicant had received additional instruction. However,

Mr. , our instructor, had signed that additional instruction had been provided.

Also, he told Eric that “he’d let it go this time,” but that “the remarks of Form 8400-3

should indicate, for retests, which topics had been retested.” In retrospect, this

guidance from Mr. was incorrect. The portion of Order 8900.1 that deals

with retests is Volume 13, Para 13-232 does not stipulate that each retested element

be stated in the remarks; nor does it state that for original applicants. The only

requirement is for the examiner or inspector to indicate “S” or “U” for satisfactory or

unsatisfactory, and to explain any elements found to be UNsatisfactory. Also, the

only requirement for retraining or tutoring is for a “certificated dispatcher” – not

necessarily an instructor – to certify in the appropriate space on the form. That had

been done. And, there is NO requirement in Order 8900.1 or the PTS for a waiting

period of any amount, and certainly not 30 days. That may be true of the ADX test,

but not the practical test. Therefore, Mr. accused Eric Morris of having

committed an error on the paperwork, when no such error had been

committed. This once again speaks to our growing concern that Mr. by

his own admission, lacks the expertise to perform the functions for which he’s

been assigned.

At an earlier meeting, Mr. stated that due to Ms. Yoo’s practical exam retake

requirement, there should have been a “Take #2” on her FAA ADX Airmen test

report. Incorrect – we explained to him that the ADX is a prerequisite toward FAA AD

certification, but it is NOT a part of the FAA AD practical examination.
Appendix M-4

TCO change of position timeline:

December 8 meeting: requests edit of item #13. I verbally state “can I simply

include a reference to FAR Part 65.61d – is that ok?” He verbally confirms “yes” 2-3

times even after I asked “to confirm now, this is all you require?” However,

December 10 email of #13 draft was sent to him with agreed-upon amendments. He

replied to email requesting that we need to elaborate, which was never said to me.

He also quoted an Order 8900.1 paragraph referring to experience requirements for

a practical, not the course credit as we agreed upon. I asked if these changes are

what he truly wants now for the 5-week TCO even though I stated numerous times

that it does not apply to a full-time residency course, but will gladly add it if he

confirms to me. No reply to my Dec 10, 7:07pm email.

Dec 15 email him at 1:23pm – with other issue and that “I’m ready to send all TCOs

once you let me know if you truly want me to add the FAR Part 65.57 clause.” – no

reply.

Dec 17, left phone message 10:17am kindly asking for an answer to TCO questions

and will follow-up with email. No return call or email.

Emailed same on Dec 17 at 10:29am – no reply since then. Also, mentioned that I

will assume that if you require anything else of me or Sheffield School that he would

inform us. – no reply.

Earlier requests that were unanswered via email were at least returned with an “out

of office” reply. None of the above transmissions resulted in such a reply nor did Mr.

 frontline manager feel a need to assist me even though he was cc’d on all of

the above.

This is not assisting customers in a timely or professional manner per the

ethics or conduct codes within the Order 8900.1.

My prediction: the TCOs will suddenly contain more problems that were not

previously there or discussed, including on December 23, 2009.

Respectfully, I will not tolerate this any longer. After 62 years, with no inspection or

inspector problems, and an unparalleled reputation in the aviation training industry, I

refuse to accept this treatment as the new standard, regardless of new inspector

assignments or inexperience or whatever lame reason the guilty feel they must

provide. Also, anything verbally said or written about me or Sheffield School should

be confirmed with me before action or inaction is taken.

More nonsense occurred on November 9, 2009 when Mr. decided to visit our

classroom during a test (see Appendix O). Appendix N details a January 29, 2010

telephone call, and Appendix Q is yet another example of what I’ve endured for the

past 4 months.

Again, I appreciate your assistance in this matter.

Eric Morris – President - Sheffield School of Aeronautics (est. 1948)
499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-1

Appendix N

Below was drafted for the local Certificate Management Office (CMO29), but my advisors suggested that it would be useless, and

recommended I send in to a higher office.

E.M.-Sheffield School (est. 1948)

---------------------

January 29, 2010

Federal Aviation Administration

Certificate Management Office - 29

2895 SW 145 Avenue, Suite 291

Miramar, FL 33027

To: CMO-29; [ 

I am still trying to figure out if only one local inspector is trying to be overly difficult

with my certification school and me as a DADE or if it stems from the entire office, or

if it is coming from AFS-200/220. You’re welcome to let me know or I’ll figure it out

soon. I simply am having a difficult time adjusting to the inconsistency of customer

service, which has ranged from good to adequate to nit-picky to nil. Below is what I

can recall from my telephone conversation today with Mr. 

Report: telephone conversation January 29, 2010; approx. 10:30-11:30am between

and Eric Morris.

Apparently Mr. and/or your office appear upset that I have asked sincere

questions, and sought assistance from others when not assisted by you.

Recent email and “staggered” exams request

Mr. called my office on Friday, January 29, 2010 regarding the following

email sent today from me to him and cc’d to his managers:

“Unless otherwise informed directly by your office, I will assume that you have all

required paperwork from Sheffield School of Aeronautics, including all additional

requests, and are seeking “hard copies” of nothing else for the time being.”

To preclude the “We never received this or that” statements in the future, we posed

the question above. It was also to prompt SOME TYPE OF RESPONSE to my

“staggered exams” request per Order 8900.1 since we had not received a response

or acknowledgement even though it was requested via email and mail.

When asked what I meant by “other requests,” I told Mr. of the “staggered

exam” request sent via email to your office on January 11, 2010 at 10:27am, and

subsequently mailed later the same day by 2:30 pm. The email request was

addressed to Mr. Mr. and Mr. The only email response

received was from Mr. on the same day acknowledging that the CMO-29
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-2

office has a limited number of inspectors who can assist me. He included a list of

DADEs, which I noted in an email on January 7, 2010, was not needed. No reference

was made to the “staggered exams” request.

Mr. said that the request was answered and “mailed about a week ago.” I

told him that I have not received it and when asked what the answer was, he replied

the answer was “no” – that my request was denied. When asked for reasons, he

quoted a December 16 2009 email from AFS-220 and the mailed denial of our

request for relief from Order 8900.1 Vol. 13, Ch3 Section 2, par. 13-175c, from AFS200. So I was possibly “mailed a denial by CMO-29 about a week ago” or I was not,

but the December 16 denial supposedly answered my post-December 16, 2009

request anyway, depending on which version, from Mr. I should believe. To

be clear – the paragraph from Order 8900.1 reads:

C. Test more than one simultaneous applicant. Conduct any portion of the

practical test with more than one applicant at the same time. The option to

“stagger” the tests.... is allowed only if approved by the specialist.

Mr. Duncan of AFS-200 graciously cut and pasted that paragraph with others in his

denial letter to me on December 16, 2009. To be as clear I can possibly be, there are

2 sentences in the above paragraph that follow the title. We were asking to be able

to conduct our flight plans simultaneously, and hopefully other portions of the

practical, if needed. The 2nd sentence includes an allowance by a non-AFS200/220 person within the CMO-29 office. The “stagger” option will be

allowed only if approved by the specialist. The FAA Specialist works within the

CMO-29.

My request for “staggering” was made on January 4, 2010, clearly AFTER December

16, 2009; therefore, it is obvious that I’m asking my FAA specialist to approve

“staggering” exams, if needed, to relieve our workload due to large classes. I did not

receive a reply from your office approving or denying this request. It was either

mailed to me “about a week ago”, which has not arrived as of today, or there was no

letter. But it appears that everyone is considering the December 16 denial from AFS200 to be a blanket denial with nobody willing to inform me unless continually

prompted, as in today’s email. Mr. eventually claimed that he assumed that

I accepted the December 16 denial since I sent a schedule of non-staggered exams –

wrong assumption. How can I send your office a schedule, including

staggered exams, WITHOUT APPROVAL? I sent the “non-staggered” schedule

out of courtesy assuming your office was still deciding whether to grant approval or

not. So I’m unsure what the actual story is at this point. If your office claims that

staggering exams will be deleted in the future, fine. Common courtesy would have

been to inform me, instead of having me wait or have me assume that AFS-200

denied ALL of the PARAGRAPH ABOVE. If the latter is true, that AFS-200’s denial

includes barring the FAA Specialist from approving his own locally overseen DADEs,

THEN AFS-200 IS NOW the FAA SPECIALIST for Mr. Bories and myself, or AFS-200

has overstepped it’s bounds. They obviously, are not the Specialist overseeing me

and Mr. Bories as DADEs. is my specialist as a DADE, not only for my

school. THESE ARE ALL DADE-BASED QUESTIONS. Mr. continues to believe

that I cannot distinguish between an FAA specialist for a DADE versus an FAA

Specialist for a school, even though HE is the person who handed me a letter dated

October 26, 2009 stating “Inspector is now the assigned FAA
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-3

Specialist maintaining oversight of your designated examiner appointment.”

However, when questioned about FAA Specialist approval authority FOR DADES on

the same day, he replied that “I’m not the Specialist” followed by “I am the

specialist”, which may have been reversed yet more than once – we cannot

remember the number of answer reversals. This is now irrelevant since he is now

BOTH a Specialist for both DADEs and Sheffield School; however, not knowing if and

when to exercise authority as an FAA specialist to assist a school and/or its assigned

DADEs who are leveraging his workload is disturbing to me.

I realize that I am being restricted by Order 8900.1 policy as a DADE since the DADE

has the exam restrictions, NOT THE SCHOOL. After giving over 840 exams, I know

the rules and I know how to read. I also know how to serve the public interest and

leverage FAA workload. The most recent schedule is a testament as to the number of

DAYS I’m saving the local FAA office. All I request is a bit more coordination and

cooperation.

So I will assume that Mr. of CMO-29 does not want to allow myself and Mr.

Bories as DADEs to stagger exams because AFS-200 or 220 or both told him so, and

that eventually rules to that effect will eliminate the possible “FAA specialist

approvals” entirely. If so, please send me the denial (with reasons) from your office

in writing for my record keeping, stating which office has specifically denied my

“staggered exams” request, as an acting DADE, of January 11, 2010. Since you

require a hard copy, which your office apparently did not receive, although it was

mailed, I suggest that you open my previously emailed attachment of a pdf file on

letterhead and print it, since mail delivery may or may not work and this entire

process has been delayed unnecessarily. Then feel free to send me the official denial

from CMO-29 in writing upon receipt of my request. If the denial is in any way based

on AFS-200 or AFS-220 feedback, I assume that you will include those statements as

well.

Mr. also mentioned that there would be NPRM on these future Order 8900.1

policy changes possibly in early 2010. I replied “how, if it is policy and not

regulatory, especially since this past Order 8900.1 rewrite was behind closed doors

without any NPRM?” Mr. confirmed so or replied “yes” or words to that

effect. Note: 8900.1 was also written without the assistance of Sheffield’s long-time

DADEs, although Mr. mentioned that “long-time DADEs were consulted in

the 8900.1 changes” to Mr. Bories and myself in a 2009 meeting. I would like to

contribute very much to any NPRM, assuming it will exist.

I am unaware of any NPPM, Notice of Proposed Policy Making.

Using outside DADEs

I was told that I must use outside DADEs before attempting to enlist others to apply

for a DADE position with your office. I mentioned that using outside DADEs may be

possible, but there cannot be any conflict of interest due to other DADEs being past

or present competitors of Sheffield School. They also must be reliable and be well

versed in the airplane used by the graduating students of Sheffield School.
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-4

I asked Mr. if outside DADEs were to supply school feedback to inspectors.

He claimed “no, to give exams and certify” or words to that effect. I pointed out that

Order 8900.1 calls for the inspector to train new DADEs in how to provide school

feedback – he then agreed that is true or said “that’s right/correct” or words to that

effect. In addition to yet another answer switch, I pointed out that this “feedback

training” issue conflicts with FAR Part 183. This contradiction is obviously one of my

concerns - ignorance is another.

Hopefully, outside DADEs used by Sheffield School will be dependable, available

(including complete weekends and most holidays), objective, knowledgeable,

periodically overseen, and charge a reasonable exam fee, and work in harmony with

myself and Mr. Bories. If all 7 points cannot be accommodated, (example – “I’m not

doing long flight plans or 2 exams per day”, “I don’t work weekends” etc..), then we

shall have a problem; I will then kindly ask that your office seek more DADEs or

kindly recommend that your office be prepared to provide exams, as designated by

the Southern Regional office. Are these outside DADEs willing to produce a 3-hour

flight plan with a 2-3 hour oral in the interest of fairness and uniformity among ALL

Sheffield graduates, using different DADEs? I cannot have graduates complaining of

unequal quality or disparate treatment having to wait for his/her exam because

‘Johnny DADE’ is in Europe for a week or won’t do weekends. I mentioned that I’m

willing to try to work with outside DADEs, but NOBODY aside from us is used to

conducting the quantity of exams that Sheffield School alone requires.

Mr. did mention that due to varying experience, some exams may not last

the full 3 hours per portion. True – it’s also wishful thinking. The FAA prerequisites

for the course are basic: know English, be at least 21, and have a pulse. The only

advantage for a student to finishing his/her flight plan early is that more time is now

allowed for “discussion” of it to the next group. Something easily avoided if ANY

office within the FAA would be willing to admit it and do something about it.

The bad news is that according to Mr. my “complaining about five 12-hour

days would be a problem”; if that is standard policy, then any outside DADE with

similar complaints would also have “a problem” with the FAA. I am willing to do the

work – are others? 12-hours for 5-10+ consecutive days is simply ludicrous

when a simple logical waiver to allow simultaneous flight plans in a 100%

secure environment using different flight plans between adjacent applicants

is permitted, thus cutting a DADE’s daily workload under 10 hours. This has

already been proven effective for the past 34 years, and previously approved by

Flight Standards, yet for some odd reason, most levels within the FAA, now prefer

lower test security per new policy, and nobody seems to care or actively comment on

this problem, other than me. A reply from anyone within the FAA citing that oralbased questions pertaining to the flight plan, (no-go items, etc..), cannot be

achieved in this type of test setting is incorrect. My reply: oral-based questions

regarding the flight plan exercise can be asked during the....ORAL portion of the

practical exam.

Special Inspection – July 14, 2003 ASI – Bonatti

The Procedures used by Sheffield School of Aeronautics and the Designated Aircraft

Dispatch Examiners (DADE’s) to conduct Area of Operation 1 “Dispatch Exercise” Task A

“Flight Planning” is not commonly found, however it does meet the requirements of the

Aircraft Dispatcher Practical Test Standards (FAA-S-8081-10A). The applicants are all

given their Flight Planning Exercise at the same time. All applicants are required to
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-5

remain in the testing room the entire time while being observed by one of the DADE’s.

This portion of the examination is commonly conducted on a one on one basis by other

designees, however they are normally only working with one applicant at a time. In the

environment that Sheffield is conducting this portion of the Dispatcher Practical, it is as

secure and allows the designee the ability to test the specific areas in which knowledge

and skills must be demonstrated by the applicant before the issuance of an Aircraft

Dispatcher Certificate with more efficiency and less time consumption. The security

measures used to assure that each applicant does his own work are different exercises

for each applicant and the exercise is observed by the DADE.

The good news is Mr. claimed to already have his 3 exam scenarios;

therefore, he can step in whenever outside DADEs fail to assist us for five to ten 10-

12 hour days – hopefully, the scenarios will eventually match our airplane’s runway

analysis and performance. I am willing to assist those who need it with materials.

Also, any FAA office providing exams when outside DADEs are unable to, or illegal to

(FAR 65.57 applicants), is in the public interest due to the lack of test fees required,

to the best of my knowledge. This backup plan will also help in case an instructor, or

any DADE, including myself and Mr. Bories, becomes ill, serves jury duty, etc..

I highly recommend hiring and training at least one outside DADE as a backup plan –

this was mentioned to Mr. but he prefers that I depend only on current

DADEs. Once again for the record, Sheffield has large classes, even during a

recession. Thinking of the future recovery, our history, and new restricting Order

8900.1 policy - one day, there will be a problem with our DADEs or other current

DADEs and we will need assistance. I’m sure you have other things to do rather than

sit with an applicant for 2-3 hours, twice, then process his paperwork, and possibly

repeat this sequence multiple times. A newly appointed and well-trained outside

DADE or two (preferred), in addition to those already designated, will alleviate this

issue. Naturally, I expect this to be met with “we don’t have time”, “we don’t have

money”, “we don’t have resources.”

Prepare ahead of time for large classes

Mr. told me to prepare ahead for large classes for scheduling purposes. I

replied that we have done so, and have emailed classes ahead of time to plan on

many extra days due to new restricting FAA policy. My concern for airlines requiring

up to 2 weeks to receive exams in large classes was met with “it is their problem” by

Mr. He stated that I “want to have my cake and eat it too.”

[Actually, I simply prefer not to provide poor customer service. It is a bit analogous

to the FAA over-restricting the same people who leverage their workload. If DADEs

quit, as one recently did in Arizona, do inspectors actually believe they do not have

to solicit for, interview, and train new DADEs or be prepared to conduct practical

exams themselves AND process the certification paperwork? So if a DADE quits 3

days before exams are scheduled to begin, will an FAA inspector, authorized and

designated to conduct FAA AD practical exams do so, or simply tell the airlines and

individuals to wait – “it is your problem.” BAD POLICY. BAD IN THE PUBLIC’S

EYE. BAD FOR SMALL BUSINESS.]

I will therefore assume that this the policy of CMO-29 - to not seek appeal to higher

offices when obviously there exists a policy problem. My new understanding, is that

my job is to notify you officially in writing. You are THEN able to OFFICIALLY deny

assistance/relief/waivers for my request due to policy, and/or if required, send my
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-6

requests up to AFS-200/220 for them to deny everything without answering or

stating specific reasons. It used to be different over the past 40 years for my father

and myself – that’s why it has taken me a while to figure this out.

Apparent threat following question

I posed the following scenario, which may develop. What would happen if a group of

20 Asian students arrive, met FAR Part 65.57 experience requirements with

supervisor letters, have passed the ADX exam, and request a practical exam without

passing a 200-hour approved course? Mr. quoted or referred to FAR 65.57

and the experience time required, and that we have limitations with our TCO

regarding credit granted. I realize this – after 62 years, we understand this. This is a

regulation that I did not write, which involves policy in Order 8900.1 that I also did

not write. It appeared to me that Mr. took this to be me trying to get away

with something - he appeared to feel the need to emphasize that he will check our

files for credit letters, etc.. and mentioned that all must be in order or DADE

authority may be removed, he gave me the impression that he believes I’m trying

to be sneaky – he missed my point. The intention of my question was to forewarn

your office that these people cannot be examined by DADEs per your policy - it

was not to be threatened by an FAA inspector. It would be completely out of my

hands – who would check their background? YOU. Who would be required to conduct

the practical exam? YOU. Order 8900.1 now PROHIBITS me and any other DADE

from doing so. He was informed that I was not pleased with that implication. He

mentioned that the applicants would have to make an appointment/arrangement and

it “may take 3 months.” I replied that I understood. He also mentioned that if

students have to wait 2-3 weeks for exams, or have visa issues “that is their

problem.” I will assume that CMO-29 feels this is an example of working

with the public harmoniously. To assist the FAA, I’d recommend

coordinating or researching student visa and non-student visa time

limitations and fees with the Department of State – a 3-month delay

coupled with additional transportation and new visa costs are NOT in the

public interest.

The scenario was based on an actual offer I sent to an airline for possible arrival here

for training in 2010, hence the question. The plan is to pass the Part 65 course and

examine them without requesting any local FAA assistance, as usual. I’m trying to

assist your office, but I will not lie to qualified applicants who meet FAR 65.57 and

want an exam in less than a week or two, and if it is their intention to be examined,

I have no right to blockade them – all I can do is send them to your office for YOU to

evaluate their experience, check their Airmen report, administer the exam, and

complete their paperwork. Again, I did not write your policy banning DADEs from

examining applicants who meet experience requirements in this manner alone. I am

not being difficult in recommending that you have your scenarios prepared

– I cannot conduct their exams because I am not allowed to.

To ask a legitimate question based on a recent offer sent to an airline with over 20

experienced students, who plan to arrive later this year, then have it twisted into a

threat is abuse and harassment. What are my options? To NOT ask questions to

avoid threats, but have 20+ people contact your office without warning. Do I

forewarn the FAA to assist them for planning purposes? Apparently, this school

operator and DADE loses either way. Very unfortunate.
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-7

Simultaneous flight planning

I mentioned to Mr. that I would continue to push at any level required for

the allowance of group testing of flight planning because of the test security lost if

conducted separately. I clearly pointed out that after giving 1-2 flight plans, then

followed by 1-2 more pairs, that the entire class now had the ability to communicate

vital points. This was mentioned in earlier meetings with Mr. as well. It is

beyond my comprehension that Mr. or others within your office are upset

that I seek answers outside of your office when I cannot get anyone within YOUR

office to approve certain clauses solely as the acting Specialist per Order 8900.1,

whether the policy is flawed, going to change, etc.. The policy was written and your

office along with AFS-200 and AFS-220 chose not to allow its application. I have

received NOTHING in writing explaining these reasons for avoiding my requests.

I also explained EXACTLY how students would have the ability to discuss all flight

plans since everyone will be taking them at different times. I believe Mr. 

then quoted that I require 3 scenarios as a DADE and Mr. Bories requires 3 different

scenarios. I noted that they are already prepared, but we all know 3+3 = 6.... not 19

or 25 or 35+ test-taking applicants over 2 simultaneous classes, as we’ve had in the

past.

At this point, we will agree to disagree. I will presume that the official stance of the

CMO-29 office is that there is no test security issue involved with this method of

testing, and that your office can offer no relief due to Order 8900.1 policy and will

not seek answers from above offices to rectify this situation. I have no problem if

this is your official stance, but kindly request for your office not to become irritated

with me when I seek assistance outside your office. As a small business operator

with rights, it is in my best interest as well as the public’s best interest to seek

assistance in this matter.

AFS-200/220 were sent an email on December 10, 2009 with 3 specific questions

based on Mr. refusal to act as an approving FAA Specialist for me, Eric

Morris, as a DADE. THIS HAS NOTHING TO DO WITH THE LACK OF A STATEMENT

REGARDING MR. AS A SPECIALIST FOR THE SCHOOL. I repeated this

statement 2-3 times for him. These questions were “specialist overseeing DADE”

issues only. Mr. seems to believe that since the denial letter was dated

December 16, 2009, which was 6 days after my 3 questions from December 10,

2009 were sent to AFS-200/220, that my questions were answered. Well, to me it

seems logical that if the questions were repeated on January 4, 2010 with a

request of “still seeking answers”, that would imply that I am still seeking answers

that were not found within the denial template sent on December 16, 2009. See

EXACTLY what these questions were, who they were addressed to, and when they

were sent on the following pages.
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-8

In case you need the email history prompting my questions of AFS-200:

I asked Mr. about the staggered practical exam request in person.

He told me to send him an email. I did. See below:

Date: Wed, 09 Dec 2009 12:16:54 -0500

To: < faa.gov>

Subject: Sheffield School update

Mr. 

..... Since you are officially the FAA Specialist for Mr. Bories and myself, according to

the definition within the 8900.1, we kindly request the approval of “staggered”

practical exams. Obviously, the authors of this paragraph felt that this allowance could

be beneficial for a variety of reasons. For us, this would allow us both as DADES to

avoid the fatigue issue from an excessive number of examination hours for larger

classes, including our next fully booked class - times that may exceed 8, 9, 10, or

more hours daily, which would be repeated for possibly many consecutive days.....

Eric Morris

President

Sheffield School of Aeronautics (est. 1948)

He replied avoiding the term “FAA Specialist.” See below. Not knowing if he

was the SCHOOL’s FAA specialist was NOT the issue. Email above states

“FAA Specialist for Mr. Bories and myself.” I did not mention “school” and I

do not confuse the two, as he seems to think. Now “email” request changed

to “formal written” request, he avoided the ‘FAA specialist’ term, and now

claims I’m asking for a deviation from National Policy, which I’m not. “If

approved by the FAA specialist” IS ALREADY IN THE POLICY!!!!!

From: aa.gov

Date: Thu, 10 Dec 2009 13:59:25 -0500

To: Eric Morris <morris@sheffield.com>

Cc: Jack. aa.gov

Subject: Re: Sheffield School update

Mr. Morris, Thank You, as the assigned Dispatch-Aviation Safety Inspector assigned to

the two DADEs at Sheffield, please submit a formal written request enumerating your

reasoning from a deviation from national policy. We will evaluate your request and

advise as soon as a decision is made.

Below in an answer from Mr. the story now shifts to AFS-200 who

appears to be calling the shots regarding FAA specialists. I do not care if

they plan to rewrite policy, unless it is to avoid my questions and restrict me

further. They are overstepping their bounds based on current policy.

Excerpt:

Date: Thu, 10 Dec 2009 16:34:38 -0500

Subject: Re: Sheffield School questions

Q: To which FAA Specialist am I to submit a formal written request to, enumerating

my reasoning from a deviation from national policy?

A- Requests for deviation from national policy shall be sent to AFS-200 as detailed in

Order 8900.1 Volume 13 Chapter 3 Section 2 paragraph 13-177.
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-9

Following this email above, it was apparent that neither Mr. nor his

management at that time, felt a need to clarify matters further or assist us,

only to avoid applying the authority of the FAA specialist; therefore, the

following 3 questions were posed for AFS-200 & AFS-220, which received

ZERO response. The questions are clear and respectfully request specific

answers, which were NOT included in their blanket denial dated December

16, 2009. A follow-up email was sent to AFS-200 and AFS-220 in January

2010 requesting answers to Questions 2 and 3, since Mr. provided

verbally as well as in writing that he was not only the FAA Specialist for

myself and Mr. Bories as DADES, but also as the specialist for Sheffield

School.

Questions 2 and 3 below have never been answered or replied to. Hopefully,

policy changes were not initiated after these dates. That would be a slamdunk case for us.

Date: Thu, 10 Dec 2009 18:12:08 -0500

To: <Greg.Kirkland@faa.gov>, <Leo.D.Hollis@faa.gov>

Subject: Sheffield School question

Mr. Kirkland and/or Mr. Hollis,

My apologies, but I’m unsure who to address this to. I appreciate any help you can

offer me.

Q1: Who is the official FAA Specialist for the DADE program under/used by/approved

for Sheffield School of Aeronautics? I do not require a citation of 8900.1 CHG 35 Vol.

13, Chapter 3, Section 1, Paragraph 13-140 – I know the definition/description. The

issue is that my local CMO prefers not to confirm the answer, and I’m seeking an

answer in writing.

Q2: If my assigned ASI is in fact, the FAA Specialist, may that person approve on

his/her own, per the wording “if approved by the specialist” or “approved by the FAA

specialist”, without consultation or coordination with AFS-200, any

provisos/exceptions/exemptions, within 8900.1 CHG 35 Vol. 13, Chapter 3, Section 2,

Paragraph 13-175c and 13-175d, for the DADE(s) under their supervision?

Q3: If the answer is “no” to Q2, then what reference mandates that the FAA Specialist

shall never exercise such authority?

Thank you for your interest in aviation safety.

Best Regards,

Eric Morris

President

Sheffield School of Aeronautics (est. 1948)
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-10

The December 16, 2009 letter of denial from AFS-200 even stated I had certain

privileges if approved by the FAA Specialist. Even if my logic is incorrect, Mr.

Hollis/Kirkland were STILL sent a follow-up email on January 4, 2010 asking again

for answers to Q2 and Q3 since your office answered Q1. As of today, I still have

received no answer which breaks many ethics and conduct codes for inspectors. It is

unacceptable to be ignored as a DADE with questions, who is working for free to

leverage the FAA’s workload.

New inspectors - reason for all the changes

Mr. explained that I might be feeling uncomfortable with the changes

because we have never truly had inspectors with dispatch certificates.

[There may be truth in that statement, but the statement, by itself, appears to mock

our previous inspectors, many of whom HAD prior experience overseeing a Part 65

school and still work for the FAA. Mr. has never overseen a FAR Part 65

school, and has never observed someone overseeing a FAR Part 65 school during

OJT, to the best of my knowledge. I believe Mr. received no training for this

task. According to verbal statements during our first meeting, I know he did not ask

for this task – he was “assigned this task.”]

[I also would not completely discount prior inspectors’ effectiveness including the

Dispatch ASI who performed his “surprise” inspection on us during practical exams,

resulting in high praise. I’ve never been falsely accused of incorrect certification

paperwork from inspectors without a dispatcher certificate, as I have been by Mr.

 They have done their job well and always worked together with us trying

not only to oversee us, but learn the specifics of a Part 65 school operation, which I

admire. Before Mr. arrival, Sheffield School never experienced an

FAA disruption during a test.]

Mail in addition to email

I was told to mail in requests, regardless of whether attached letterhead was already

emailed, because your office does not have a color printer, which I find incredible.

What would you think if you handed me a black and white letter from your office,

which you have, and it was refused because “I need the FAA’s logo in color.” I shall

comply - you’ll get everything mailed as requested – there’s no point in saving me

any time since I’m not an air carrier, only a lowly certification course operator. The

FAA priorities have been clearly spelled out for me by Mr. 

Resume not matching DADE renewal application

Mr. mentioned that my supplied (abridged) résumé did not exactly match

my DADE renewal application. I know of no policy requiring me to include nonpertinent employment, but I complied. Please note that if this is current policy or

becomes National Policy, then DADE applicants with more than 4 different positions

or titles of employment on their résumé will be unable to comply, due to space

limitations on the DADE application. This has never been requested before, and

appears to be another example of your office trying to be difficult because I have had

questions and sought outside assistance. You will be mailed a new résumé, in color,

on letterhead matching what the application states.
Sheffield School of Aeronautics (est. 1948)

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

–www.sheffield.com

Appendix N-11

Different inspector ok

I mentioned to Mr. that this arrangement does not appear to be working and

I would have no problem if another inspector were assigned to us.

[He appears too busy for our operation and too incompatible with Mr. Bories and myself. We

have NEVER experienced this before within the school’s history nor have any of the 5 DADES

who have examined Sheffield’s graduates. I doubt Wilbur Sheffield ever did as well. I’m also

uncomfortable with a Sheffield graduate overseeing Sheffield School or any of its’ assigned

DADES. In addition to everything else, this appears to be a conflict of interest.]

Summary - The DADEs of Sheffield School have conducted more than 4,514 FAA

Aircraft Dispatcher practical exams, which has “leveraged” anywhere from 25,000 to

40,000 hours of workload from South Florida inspectors. The amount of $$$ earned

for those exams performed FOR the FAA is ZERO. It is our time, our postage, our

paper, our Airman Branch phone calls for others’ mistakes, etc. that SAVE the

FAA’s time.

There once was an era in which inspectors wrote us letters of thanks and

commendation for reaching certain exam plateaus, who would approach Washington

with pressing issues to assist us or defend us, who would understand our concerns,

and who would communicate with us in a timely manner. Nowadays, all I do is place

my “Small business” on hold while writing daily logs for reports for your office, and

others. In addition, I have to listen to an inspector tell me that five 12-hour days is

not bad out of 30 days (as if I have little to do on non-exam days), and that any

complaints about it, “would be a problem” or “that’s a problem.” I feel too much

acrimony from your office. Whether intentional or not, that last comment was

disrespectful considering I worked everyday, including holidays since Mr. 

introduced himself to me. It also assumes I do nothing for 25 days prior to exam

days. I’m disgusted with the time spent on minutia, bad policy from “headquarters”,

and threats of DADE removal, and am losing patience. I have lost a multitude of

business productivity because of this, so I’ll be in here all weekend...working hard.

Is there a problem for [local airline] Gulfstream or other airlines, likely overseen by

CMO-29, working “5 consecutive 12-hour” days, and more?

I’m sure most or all of the above statements may be denied. If so, I am requesting a

written report to be forwarded to me so that I can submit it along with mine to other

offices. Aside from today’s phone call and the December 23, 2009 meeting, I have at

least one witness for everything, and more.

A few excerpts from the FAA web site:

Our Vision .... We are responsive to our customers and are accountable to the taxpayer and the

flying public.

Our Values* Quality is our trademark. We serve our country, our stakeholders, our customers,

and each other. * People are our strength. We treat people as we want to be treated."

The evolution of restricting policy from the national level without coordination or

contribution from the users and public is sadly expected, but I’ve always had a good

relationship with the local FAA offices. If you don’t want to support me, fine, but I

could use less of the threats and insults, whether real or implied. I would like to

move forward.

Eric W. Morris - President-Sheffield School of Aeronautics (est. 1948)
Appendix O-1

ASI CMO-29 Misconduct - 1

Excerpts from Instructor email to Eric Morris:

From: < yahoo.com>

Date: Wed, 4 Nov 2009 15:32:18 -0800 (PST)

To: morris@sheffield.com

Subject: For the record - 

Eric,

For documentation...if ever [hopefully never] necessary.

Today [November 4th, 2009] entered the classroom while students

were testing under official FAA business. He stated he wanted to sit and observe the

testing session, and requested copies of the test. I provided

him with copies of AIM/Jepp for review (returned afterward).

We pulled in an office chair for him from the second classroom, since all

desk space was occupied. He set his briefcase and other personal effects on

desk before he sat down, momentarily distracting him and

others around him during examination time.

With 40 minutes remaining in the exam, Mr. walked to the front of the

room, and told me we'd have to change the TAF in the test (while directly

pointing to a METAR) because it was presented under the old format. I

explained we are using the new format and he was pointing to a METAR. He

then flipped through until he found the KORD TAF and defended (incorrectly)

that this was the old TAF format. I responded quietly that it was - however

at this point most eyes were up front (more distraction).

I have absolutely no problem with FAA spot inspections, however I don't feel

that FAA Inspector's normal duties should disrupt the learning and/or

testing process of others. Announcing, albeit incorrectly, that the TAF

Format is wrong invalidates the test to those who were currently taking it.

I've been through a few airplane ramp checks acting as PIC previously, and I

always gave the FAA unfettered access right up until departure time - at

that point if they had no further issues they couldn't interrupt the normal

course of business by making me late. I don't see much of a difference

here. I'll be happy to comment further about this at any time, ...

Respectfully,

-
Appendix O-2

ASI CMO-29 Misconduct – 2

Excerpts from student email to Eric Morris:

From: " < >

Date: Sat, 12 Dec 2009 10:23:51 +0100

To: Eric Morris <morris@sheffield.com>

Subject: Re: Sheffield

Dear Eric,

...I remember during the Test, it was the AIM Test, the FAA inspector came

into the class, without asking for permission. Then the Inspector

took a chair and was sitting behind me. He put his books on my desk, also

without asking me. Then he looked at the test sheet, I think for around

about 10 seconds. Than he was sitting again in the rear and looked at the

class. I think, there was a discussion with several times, they

both leave the class several times. I think, was little bit upset,

above the behaviour of the Inspector. I didn ́t remember what was the topic

of the discussion. ....., I think the inspector mixed METAR and TAF`s.

... the behaviour of the Inspector was not the best, he disturbed the concentration

during a live test ,and I think he must speak with the teacher before the test and not

just go in, without asking....

If you have any further questions, contact me, you have my full support......

If you want to use my name for the report, you can do this, you have my

full support.

All the best for you and with very best regards,
Appendix P-1

Owners acting as DADEs

We believe that the restriction against owners, instructors and contractors

employed by a Part 65 dispatcher course being approved as DADEs, as

mentioned in Volume 13, Chapter 3, Section 2, paragraph 13-175(D), was

written to exclude us specifically. Further, we must assume that this bolsters

our case for vendetta action since AFS-200/220 have refused to answer our

questions about this clause – and indeed, have not even replied to our

questions in direct violation of the customer service standards for inspectors

as written in Order 8900.1. Although it is true that there is statement at the

end of the paragraph cited above that states “unless approved by the FAA

specialist,” we have been advised that AFS-200/220 is currently working on a

rewrite of this section that will remove the possibility of an exception – the

timing of which would be after we asked the questions, which looks even

more conspicuous.

If there can be any other logical reason for exclusion of the staff of Part 65

programs as DADEs, we kindly ask that such explanation be provided to us.

This is especially important to us because there had never been such a

restriction prior to the closed-door authoring of Order 8900.1.

However, we cannot accept potential conflict of interest as a reason. Outside

of dispatch, there are many other designated examiners who are employees

of training institutions. Parts 141 and 142, for example, allow for designees

who are employees and instructors. And even within dispatch, the proposed

Part 121 allowance for combined certification and initial training of

dispatchers not only allows for employees of the company to give practical

exams for certification under Part 65, but also requires that such designees

be employees of the certificate holder. We submit that employees of a Part

65 training program are no less trustworthy in representing the FAA than any

of the other designees mentioned in this paragraph. If AFS-200/220 would

like to go on record stating that Part 65 course owners and instructors are

less capable of exercising the required judgment than other airmen, then

that would be libelous. Please let us know if that is their stance.

If this is NOT the position of the Flight Standards Service, then potential

conflict of interest cannot be cited as a reason for the inclusion of such a

limitation in Order 8900.1. If this IS the position of the Flight

Standards Service, then we further request an immediate rewrite of

Parts 141 and 142 along with the pending changes to Part 121 to

eliminate those employees from being able to conduct certification

activities. Without that, we would need to forward our concerns of

disparate treatment to the DOT Inspector General’s office (among

others) for investigation as to why the FAA is singling out one group

of individuals for higher scrutiny than others, without probable

cause.
Appendix P-2

Also, we cannot accept this restriction on the basis that DADEs should

provide objective feedback about the strengths and weaknesses of an

approved Part 65 school to the FAA specialist. This idea is mentioned in the

wording/logic of Volume 13, Chapter 3, Section 3, Paragraph 13-206(A)(8),

which describes the content of DADE initial training as including the

“importance of providing feedback on the approved part 65 dispatch courses

(strengths and weaknesses) to the FAA specialist.”

Unfortunately, this is not only impossible for a DADE to ascertain, but also in

violation of 14 CFR 183 and needs to be removed from Order 8900.1 because

of the conflict. 14 CFR 183.1 states that the FAA may designate private

persons to “act as representatives of the Administrator in examining,

inspecting and testing persons and aircraft for the purpose of issuing airman,

operating and aircraft certificates.” Evaluating the content or effectiveness of

an approved training program is beyond the scope allowed for designees by

Part 183. Paragraph 183.25(f)(1) and (2) state that a DADE may “accept

applications for, and conduct, written and practical tests necessary for

issuing aircraft dispatcher certificates under Part 65” and “issue temporary

aircraft dispatcher certificates to qualified applicants.” Neither subparagraph

states that the DADE may evaluate an approved Part 65 course.

To have a DADE assess the strengths or weaknesses of a program on the

basis of his/her observations of applicants is not just flawed reasoning – it is

impossible. It assumes that any deficiency noted during a practical exam is

directly tied to a deficiency of the training program, which is false logic. An

applicant may be found deficient in a task for myriad reasons that have

nothing to do with the training itself – poor phrasing of questions by the

DADE, distraction due to personal/family crises, individual IQ, nerves,

applicant fatigue and an applicant’s poor memory all come to mind. In the

last case, consider that an applicant can take a practical exam 89 days after

the course completion certificate is signed; if such an applicant arrives for a

practical exam that long after completion of the course without reviewing

materials during the intervening timeframe, then that can hardly be

considered a weakness of the training program.

During the conduct of a practical examination, the examiner’s focus shall be

on one function ONLY – determining whether the applicant can perform all of

the required tasks and behaviors as outlined in the Practical Test Standards.

The FAA does not provide DADEs with separate training on how to assess a

Part 65 program based on applicant responses, and provides no job aids on

how to perform this function. But again, all of that is moot because Part 183

does not allow for a DADE to evaluate strengths and weaknesses of such a

program in the first place. To thoroughly evaluate a school’s training

program, a significant amount of time must be spent in the classroom, which

we know is virtually impossible. The FAA has always had an open invitation

to sit through any portion of our course.
Appendix P-3

Even if this were the reason for such an exclusion of employees of Part 65

courses, did AFS-200 consider that non-affiliated DADEs could have as much

(or even more) bias in the conduct of their examinations and in their

assessment of program strengths and weaknesses? For example,

appointment of non-affiliated DADEs who have had a history of animosity

toward a Part 65 program and who are appointed without consultation with

the Part 65 course operator, would also create a conflict of interest. While

this does not serve the best interests of the Flight Standards Service, there is

no requirement in Order 8900.1 to check with the course operator before

appointing a DADE that would examine that course’s graduates.

Besides, if the FAA truly believed that the owner/employee restriction was

necessary on the basis that school-employed DADEs would never forward

concerns about deficiencies of their employer to the FAA, then why does AFS10 manage a Whistleblower Protection Program in the first place? DADEs

may not officially be Federal employees, yet they represent the FAA.

In point of fact, each Part 65 school historically has been assigned a Principle

Operations Inspector, or more recently, a Dispatch ASI to provide oversight

of their training. Those are the individuals who should be evaluating the

strengths and weaknesses of the programs based on their own observations

and surveillance.

Finally, if the reason for the inclusion of the restrictions against Part 65

program employees is due to provable improprieties committed by other

DADEs at other schools in the past, then those persons should have their

DADE privileges revoked – but it makes no sense to limit the continued

ability of DADEs with spotless records to continue the performance of their

duties.

Therefore – we are asking for an explanation of the reasoning behind

the exclusion of owners, instructors or other employees of Part 65

programs. If AFS-200/220 cannot provide any valid, logical reasons

for the inclusion of this restriction or any explanation of why this

provision was written without consultation of the most experienced

DADEs in the world, then we kindly request that AFS-1 require its

removal from Order 8900.1.
Eric Morris – DADE

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

Appendix Q-1

February 16, 2010

Federal Aviation Administration

Certificate Management Office - 29

Attn. ASI

2895 SW 145 Avenue, Suite 291

Miramar, FL 33027

Mr. 

I received your certified letter (text below) on Friday, February 12, 2010, allowing me 5 days

to determine what specifically to respond to.

February 10, 2010

The FAA has received your application for renewal of your Designated aircraft Dispatch Examiner

(DADE) SO-19-605.

Your application for renewal can not be considered at the present time until supporting

documentation has been submitted to indicate compliance with FAA guidance 8900.1 Volume 13,

Chapter 3, Section 2, Paragraph 13-175.

In order to separate your duties and responsibilities as a DADE your communications with the

FAA should be submitted on a DADE letter head.

Please respond in writing within five (5) days of receipt of this letter

Thank you. - Aviation Safety Inspector

My official response within the required 5-day limit is below:

Instead of directly informing me of the missing supporting documentation, to save us all time

and effort, which also contradicts what you verbally told me via telephone on January 29,

2010 (“we have all documentation required”), it appears that it is now my task to determine

what you specifically mean.

You were not specific in what was missing and how to satisfy your request. So to assist us all,

we will address each paragraph and hopefully, I have pinpointed what “supporting

documentation” is required. If I am incorrect, I kindly request that you specifically inform me

what is still missing and precisely what format you need the documentation in.

For your convenience, the text from Order 8900.1 is included below:

13-175 LIMITATIONS. A DADE will not:

A. Test Outside the Certificate_Holding District Office. Conduct practical tests at locations outside their

supervising certificate_holding district office (CHDO) unless approved and coordinated between the

supervising CHDOs.

NOTE: DADE designation should be limited to one CHDO area of responsibility. If additional areas of

responsibility are added the action must be coordinated between both CHDOs and their FAA specialists.

DADE Eric Morris reply: Unless policy changes, we will not conduct practical tests at locations

outside our supervising certificate_holding district office (CHDO) unless approved and

coordinated between the supervising CHDOs.

B. Administer More than One Test at a Time. Except as provided in 307(c), administer more than one

practical test at a time, to include no more than two full practical tests per day. In addition to the two full

tests, a retest may be administered on the same day depending on the amount of material that must be

covered.

DADE Eric Morris reply: I kindly request that exemption 307c be explained to me in writing.

Regarding the remainder text, unless policy changes, I will not administer more than one

practical test at a time, to include no more than two full practical tests per day. In addition to

the two full tests, I understand that a retest may be administered on the same day depending

on the amount of material that must be covered. The recent 5 days of exams, which you did not

oversee, complied with all current policy.
Eric Wayne Morris – DADE

499 N.W. 70th AVE.–STE.110–PLANTATION,FL 33317-7572–(954) 581-6022 – FAX: (954) 584-8980

Appendix Q-2

C. Test More Than One Simultaneous Applicant. Conduct any portion of the practical test with more

than one applicant at the same time. The option to “stagger” the tests (start the oral portion of the

first test, and start the practical portion of the second test in conjunction with first test) will be

allowed only if approved by the specialist.

DADE Eric Morris reply: I emailed and mailed my “staggered exams” request on January 11,

2010. No official written reply following January 11, 2010 was ever received from your office,

as explained via telephone to you on January 29, 2010. I will continue to send exam schedules,

as I previously did, in a non-staggered format, until a decision has been officially made.

Otherwise, unless policy changes, I will not conduct any portion of the practical test with more

than one applicant at the same time. The recent 5 days of exams complied with all current

policy.

D. Be Employed in a Part 65 Dispatcher Course. Be employed as an instructor, owner, or contractor of

an approved Title 14 of the Code of Federal Regulations (14 CFR) part 65 dispatcher course in his/her

district unless approved by the FAA specialist.

DADE Eric Morris reply: I am assuming this may be the issue - ownership. Since it has been

determined that you are my FAA Specialist regarding this DADE matter, and this is current

policy, what is your decision? I still have not received an official written notification of

approval or denial (with reasons) from my assigned FAA specialist pertaining to this paragraph

section. And to jump ahead, and reduce these continual delays, please specify EXACTLY what

you require of me as a statement of changed ownership. As of December 23, 2009, you

“require a letter stating a change in ownership with names of signatures of both parties” or

words to that effect. Is this still your official answer or has it changed? If it has changed,

please indicate clearly what your office requires.

E. Test Non_Graduated Applicants. Conduct tests for applicants who have not graduated from an

approved 14 CFR part 65 dispatcher course, unless approved by the specialist.

DADE Eric Morris reply: We shall not conduct tests for applicants who have not graduated from

an approved 14 CFR part 65 dispatcher course, unless approved by the specialist. Since we will

likely not be approved by you, the specialist, we have no option, but to refer all qualified

applicants, who are not Part 65 course graduates, to CMO-29 since Order 8900.1 mandates that

inspectors conduct the practical examinations, not DADEs.

F. Conduct Competency Checks. Conduct competency checks for a 14 CFR part 121 Dispatcher Training

Program, unless employed as an Air Transportation supervisor or qualified ground instructor for that

operator.

DADE Eric Morris reply: We shall not conduct competency checks for a 14 CFR part 121

Dispatcher Training Program, unless employed as an Air Transportation supervisor or qualified

ground instructor for that operator.

One last question: What else do you need sent or resent using “DADE letterhead?” I will

assume a non-response to indicate that I have satisfied all paperwork submission

requirements.

I will also assume that “DADE letterhead” consisting of my full name and address, as indicated

on your February 10, 2010 certified letter, can be located at the top and/or bottom of the

document, as submitted herein, with nothing else required. This shall suffice, unless directed

by your office, or if your office provides Order 8900.1 “DADE letterhead” sample forms or

guidance.

Reminder: emails to my office to save time, are welcomed.

Regards,

Eric Wayne Morris - DADE
Sheffield School of Aeronautics

Appendix R-1

FOIA notes from 2003 & possible vendetta origin

03/13/2003 10:42am

To Dave Malloy, Theodore Perry

Subject: Practical’s at Sheffield in FLL

Dave,

Some feed back from through the NWA DADES is that employees currently being sent to

Sheffield for a 4-week course have 300 questions to study from for the practical. A few of the

practicals have taken only 90 minutes. It seems to me that we have a rubber stamp going on. My

concern on this comes from my oversight of the NWA folks asking why I am so by the book and in FLL

they are giving the certificates away.

I am not sure what to do with this feedback so I am sending it to you and Ted as an FYI.

Gordy Rother

Aviation Safety Inspector/Aircraft dispatch

FAA NWA CMO

Sheffield reply:

Students are instructed to study all material within their notebooks, study sheets,

handouts, and flight plans. There were no “90-minute” practicals. An FAA AD practical exam

consists of 2 parts: a flight plan exercise and oral portion. Our flight plan averaged 2 hours

in 2003. Our oral portion typically ranged from 1:45–3 hours in 2003, and were based on

how quick and intelligent the applicant is.

There was no “rubber stamp going on” as there never has been. Mr. Rother should have

considered the source of this information, confirmed it, and contacted me and my local

office and other Sheffield graduates (just pick any airline) directly. He chose not to, which

is intriguing since the plural “NWA DADES” later becomes singular.

Mr. Rother should also understand that the method of qualifying for an AD practical exam,

whether passing a true AD school vs. a diploma mill vs. receiving “training” from a coworker at an airline, flying the line for 2 years, etc.., should determine how deep BOTH

sections of an exam should be conducted. Personally, if I had to examine anyone outside of

Sheffield, especially airline personnel without formal schooling, the exam would last for 2-3

days.

Mr. Rother should be lucky that the origin of the line “in FLL they are giving the certificates

away” was not ever investigated. He would have been requested to produce the person(s)

who uttered it, so as not be held accountable for it himself. informed me that NOBODY

ever mentioned such a statement, only the contrary.

-------------

04/15/2003 02:29pm

To Dawn Veatch/ASO/, Clark Schadle/ASO, Thomas Penland/AWA

Dawn,

It has been brought to my attention by Gordon Rother, one of our new hire Dispatcher Inspectors in

the Minneapolis NWCMO, that something might not be right in the way that the dispatcher Practical

Exams are conducted by the Sheffield School of Aeronautics in Plantation, FL under the oversight of

the FLL FSDO and the POI, This information was received by Inspector Rother

through his feedback from through the NWAA DADES that he oversees. He stated that some of

the Dispatcher Practical Exams given have been completed in only 90 minutes which seems to be very

short time. A normal Dispatcher Practical Exam averages between 5-6 hours total time.

I telephoned the POI, concerning the above statement. He didn’t think that there

was a problem to be worried about. He called and passed the information on to Erick Morris, the CEO,

at Sheffield School. The following day, I received a semi irate telephone call from Erick. He wanted

names and more information on the facts. I told him that I was just looking into the situation and that

I would get back to him if and when I had more information. The next day, I received another
Sheffield School of Aeronautics

Appendix R-2

telephone call. This time it was Ron Morris, Erick’s Father and owner of the school. He was not as

upset as Erick. He proceeded to tell me that he “is an attorney and of his airline and government

connections. He also mentioned a slander lawsuit that he might bring against someone that made the

statement about his school.”

I have discussed the situation with Jim Gardner, Dave Malloy and Bill Bonatti who are all well qualified

SME’s in the dispatcher field. The feeling is that the school, it’s training and testing might need to be

looked at by someone qualified to do so. If you are looking for a well qualified person to take a look

into the facts at the Sheffield School, I recommend Bill Bonatti at MCO. He has volunteered to do the

inspection if funded.

I have been told to pass this information on to your region and let you handle it. I have the original

hard copy of Gordon Rother’s email that I can fax to you if you need it. If I can be of any additional

help please let me know. Please keep me apprised of your findings.

Ted Perry

AFS-220

Sheffield reply:

Fascinating that Gardner (who we asked to close an illegal Middle East School claiming FAA

approval), and Malloy (who we asked to investigate AD certificates handed out in a matter

of days to Arabs in NY after FAILING Sheffield) thought we were shady. How do you go

from following all policy and failing unqualified students, thus preventing them from taking

a practical exam, to “rubber-stamping” the Dutch.

Additionally, we have always clamored for better oversight and have extended open

invitations to the FAA to observe. Unfortunately, it took a “sting operation”, according to

Dawn Veatch’s words below, to initiate a visit.

-------------

04/17/2003 10:18am

To Ted Perry, Dave Malloy, James Gardner

Subject: Florida Practicals

Ted,

As requested, I have had some e-mail dialogue with the individual that expressed the

concerns about the Sheffield practicals. As I understand it the students are given a final

exam of 200-250 questions, (written exam) in the morning. I am not sure if this is

administered by the school as a final exam to pass the course or if the DADE is giving this

and crediting the practical exam. This may be difficult to determine since the DADE

owns the school. In the afternoon they have a “group” practical that takes about 90

minutes.

I just completed some practicals in DTW for the FSDO and they took 5 to 7 hours each. No

written exam but a manual flight plan based on the guidance in the 8400.10 and the PTS.

Maybe we can get some headway with them when the PTS is updated.

has no concerns with how they are certificated, however, they have nothing to gauge

this against.

It should be noted that this is second hand information and this was not observed by my

source.

Gordy Rother
Sheffield School of Aeronautics

Appendix R-3

Sheffield reply:

“The NWA DADES” is now a “second-hand” source who observed nothing.

Regarding the “exam” - wrong again – our “final exam”, which by the way is closer to 400

questions, is not an FAA practical exam – it is a final exam for the COURSE. Once completed,

the instructor determines who can receive the signoff for the FAA AD practical exam. The

practical exams which follow, are on separate days.

RE: “In the afternoon they have a “group” practical that takes about 90 minutes.”

We have NEVER had a “group” practical. “Group” implies that everyone is sitting around

performing the same task together, perhaps even assisting one another – absolutely

absurd. Mr. Rother fails to distinguish which portion he or his ignorant “source” is referring

to. As previously mentioned the flight plan at that time was 2 hours on average, and oral

the same. 2+ 2 = 4 hours, for the quicker applicant. The slower applicant requires longer.

Perhaps contacting multiple airlines with multiple Sheffield graduates would have yielded a

more accurate description of our testing procedures.

We now see where the 8900.1 time rules originated. The FAA actually believed that we

examined applicants for 90 minutes for BOTH exam portions cumulatively! A bit of

investigation and clarification, without relying on the rumor mill, would have been smarter,

and less costly.

Also, it would have been nice if Mr. Rother pointed out that this was all “unobserved,

second hand information” a month and 4 days earlier when he began this relay of

exaggerated and false nonsense.

“This may be difficult to determine since the DADE owns the school.” This line shows a

possible link to the origin of DADE/owner restrictions in the 8900.1 policy changes

instigated years later – all or most based on someone in the MSP area who either had a

vendetta against Sheffield School, or who listened to another person with the vendetta.

The original source was never named. Convenient.

------------------

04/22/2003 10:29 pm

To: Perry, Clark Schadle, Thomas Penland, Fred Walker

RE: Sheffield School of Aeronautics

Ted,

I spoke with the Assist. Manager of FLL FSDO today and they are trying to arrange for Inspector

Bonatti, Orlando FSDO, to conduct an investigation. We should have closure soon.

Dawn Veatch

ASO-201

----------------
Sheffield School of Aeronautics

Appendix R-4

06/13/2003 09:30 am

To: Leonard Beers/ASO, Joseph R. Hunt/ASO, Dawn Veatch/ASO

RE: Sheffield Aircraft Dispatcher school in Ft. Lauderdale.

Ted,

As per correspondence with Dawn Veatch and our discussions, I gave Sheffield a call and played the

applicant/student role. They have a course running now that will be ending on the 9th of July. Practical

Tests are scheduled for the 10th, 11th of July. The next available as per their schedule would be

September 3rd thru 5th. I would be able to go down and conduct an unannounced inspection and

observation on the 9th thru 11th, but I will need two things.

1. I will need something in writing from the powers above authorizing this. (I will be working

outside of my district unannounced!!!!!)

2. Funding!!!

Please let me know as soon as you can.

William L. Bonatti

FAA-Orlando Flight Standards District Office

Sheffield reply:

So apparently Veatch ordered Mr. Bonatti to deceive Sheffield School and “play the

applicant/student role.” A smarter move would have been to contact the district office for

exam dates and times or look them up on the school’s web site.

These types of FAA tactics, initiated from unverified 2nd-hand information, are truly

disgusting.

-----------------

06/15/2003 08:14 pm

To: Dunbar, Hunt, Beers, Perry, Bonatti

RE: Sheffield Aircraft Dispatcher school in Ft. Lauderdale.

John,

I don’t have a problem funding this or with Bonatti working “unannounced out of his district”. But I do

have a concern about it having the appearance of a Sting Operation. Have you been in the loop on

this coordination? Please advise.

Thanks

Dawn

ASO-201

Sheffield response

A surprise “out of district” visit by an inspector trying to verify absurd claims is something I

can deal with – we’ve always conducted ourselves professionally and ethically. But when

coupled with deceiving phone calls, then the term “Sting Operation” that Veatch used was

indeed, appropriate.

-------------

Summary:

The “sting” backfired. The FAA went on a witch hunt at the wrong school based on false,

unsubstantiated, 2nd-hand rumors which morphed into tales of complete and utter nonsense. The final

report was 180 degrees in the opposite direction of what was initially alleged. It resulted in a glowing

report of what most informed people within Aircraft dispatcher training circles already knew. It also

wasted tax payers’ dollars.
Sheffield School of Aeronautics

Appendix R-5

Result?

Certain FAA personnel were disappointed, yet held on to their notion that owners cannot objectively

be DADEs, some form of collaborative group of insecure exams must somehow be given, and the

complete exams last 1.5 hours. These misguided notions along with further false rumors over the

years, which were still overheard at a 2009 FAA meeting (reported to me by FAA inspectors

themselves on Hollywood Beach, FL), helped foster the current Order 8900.1 DADE restrictions.

This appears to be policy aimed squarely at my school, and its’ DADEs – the ones who the FAA failed

to successfully “sting” in 2003.

Hopefully, the Administrator will understand my position as a DADE, and the impact of all this on a

very successful and reputable small business, which has helped this profession more than any other

dispatcher school in history. Leveraging up to 45,000 hours of workload over 4 decades for the FAA for

free should be rewarded with something more than FAA misconduct and bullying of a small business

resulting in 100s, if not 1000s of hours of lost productivity.

Thank you.

Eric Morris

President

Sheffield School of Aeronautics (est. 1948)
APPENDIX S

(Highlighted excerpts & Ethics and Conduct

violations from Order 8900.1, Volume 1,

Chapter 3, Section 2)

[See other Appendices and report body for details.]
8900.1 CHG 0 9/13/2007 

1 

VOLUME 1 

A. 

B. 

A. 

B. 

 GENERAL INSPECTOR GUIDANCE AND INFORMATION 

CHAPTER 3 INSPECTOR RESPONSIBILITIES, ADMINISTRATION, ETHICS AND 

CONDUCT 

Section 2 Personal Ethics and Conduct 

1-176 PURPOSE. This section contains direction and guidance for aviation safety inspectors 

(ASI) pertaining to principles of ethics and conduct as they affect the performance of duties. (In 

this section, ASI also refers to aviation safety technicians, cabin safety inspectors, and aircraft 

dispatcher inspectors.) Although some basic outlines are listed, this section could not possibly 

cover all circumstances an ASI may encounter. As ASIs are always in the public eye, the Federal 

Aviation Administration (FAA) expects them to exercise good judgment and professional 

behavior at all times while on and off duty. 

Unique Responsibilities of ASIs. ASIs are exposed to a number of circumstances 

that are critical to their positions and that are not pertinent to other FAA job functions. The ASI 

has the critical position of frequently interpreting and evaluating the quality of training programs, 

operations and maintenance manuals, pilot and mechanic performance, and overall safety 

activities. It is imperative that all ASIs be sensitive to the responsibilities and demands of their 

positions and be objective and impartial while performing their duties. ASIs must also be 

sensitive to actual as well as perceived appearances of any conflict that could disrupt the 

effectiveness or credibility of the Flight Standards mission. 

Department of Transportation (DOT) Requirements. ASIs are required to comply 

fully with the letter and spirit of the standards of conduct as set forth by this section; with those 

set forth in United States Office of Government Ethics publication, “Standards of Ethical 

Conduct for Employees of the Executive Branch”; and FAA Order 3750.3C, Orientation to 

Government-Wide Standards of Conduct (both include Title 5, Part 2635, of the Code of Federal 

Regulations (5 CFR)); and with those set forth in FAA Order 3750.4A, Conduct and Discipline. 

The agency’s policy on employee conduct is designed to encourage employees to maintain a 

level of professionalism that will promote the efficiency of the FAA and conform to accepted 

principles of conduct. 

1-177 GENERAL. Standards of Professionalism for Flight Standards (AFS). The definition and 

standards below apply to all Flight Standards employees. 

Professionalism Definition. Professionalism is a set of behavioral traits that 

enhances mission effectiveness both internally and externally by: 

• Fostering collaboration with others; 

• Focusing on customer service; and 

• Making a positive impact on organizational success. 

Standards of Professionalism. 

UNCONTROLLED COPY WHEN DOWNLOADED 

Check FSIMS to verify this version is current prior to use 
8900.1 CHG 0 9/13/2007 

2 

1) 

2) 

that requirements are incorporated into final work products and 

designs 

• ecommendations and decisions in a manner appropriate for the 

audience 

• Listens to, accepts, and acts on customer feedback 

• try to achieve and maintain regulatory 

compliance and improve safety 

• ale and actions needed for resolution when required to take 

regulatory action 

Collaboration. When interacting with others, the employee: 

• Seeks support from and objectively listens to the suggestions and comments 

of others 

• Demonstrates attention to and understands the concerns of others 

• Identifies and resolves professional differences of opinion 

• Communicates in an understandable and timely manner 

• Offers assistance and shares information that will be useful in producing 

acceptable and complete solutions 

• Remains calm and diplomatic in tense situations in which there may be a 

significant disagreement among parties 

• Discusses problems openly and manages conflicts constructively so that work 

is not adversely impacted 

Customer Service. When interacting with customers, the employee: 

• Employs Aviation Safety (AVS) “Customer Service Principles” 

NOTE: AVS’s customer service information may be found at: 

http://www.faa.gov/about/office_org/headquarters_offices/avs/cust_service. 

• Understands customer requirements at the outset of assignments 

• Asks questions to assure understanding of customer expectations 

• Informs customers of guidance material and FAA directives 

• Ensures 

Explains r

Works with the public and indus

Explains the ration

UNCONTROLLED COPY WHEN DOWNLOADED 

Check FSIMS to verify this version is current prior to use 
8900.1 CHG 0 9/13/2007 

3 

lic perception of unfair or 

disparate treatment 

3) Impact on Organizational Success. The employee: 

ectations with work of acceptable quality 

and quantity 

• 

ram objectives in a timely fashion 

ission of the organization through actions and communications 

ents that 

 inspectors. 

nces (Curre

• Avoids action or inaction that contributes to pub

• Satisfies requirements and meets exp

• Uses assigned resources effectively 

Adheres to published policy, procedures, and work instructions 

• Elevates cases of nonstandard FAA application of published national policy 

and procedural guidance to the immediate supervisor for resolution 

• Reviews workload and adjusts priorities continually to account for changing 

circumstances while meeting prog

• Conforms to FAA regulations, Model Work Environment (MWE) principles, 

and safety and security standards 

• Supports the m

1-178 OTHER INSPECTOR GUIDANCE. Table 1–4 references other docum

contain guidance for

Table 1 – 4, Refere nt Editions) 

FAA Order 1400.8 Equal Opportunity in FAA Employment 

FAA Order 1600.2 cedures for Classified National 

rmation 

Safeguarding Controls and Pro

Security Information and Sensitive Unclassified Info

FAA Order 1600.24 Listening-In to or Recording Conversations on Telephone or 

Telecommunications Systems 

FAA Order 3750.7 Ethical Conduct and Financial Disclosure Program 

FAA Order 3900.19 Occupational Safety and Health Program 

Federal Aviation Personnel 

Manual (FAPM) Letter 2635 

Conduct and Discipline 

Title 29 of the Code of 

Federal Regulations (29 CFR) 

part 1604 

Title 49 of the Code of 

Federal Regulations (49 CFR) 

part 99 

Employee Responsibilities and Conduct 

Title 18 of the United States section 208 

Code (18 U.S.C.) 

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nd with the 

public bear great responsibility in the determination of public perception of the FAA. Inspectors 

must guard nce 

their behavior or actions in providing assistance to operators, or in filing enforcement actions. 

While an inspe

s must observe the following rules of conduct: 

1) 

2) 

 to fully occupy employees at any given time, they should notify their 

supervisor so that additional work may be assigned. 

3) Maintain a clean and neat personal appearance to the maximum practicable extent 

during working

4) Respond promptly to directions and instructions received from their supervisor. 

e 

6) 

sciplinary action may be taken if the circumstances warrant. 

7) y 

owledge of and 

observe all applicable legal requirements and restrictions. In addition, employees are expected to 

be prudent and f the 

e 

ion. ASIs shall not disclose or 

discuss any classified information or “official use only” information unless specifically 

authorized to do so

osed to anyone who does not have the 

1-179 ON-THE-JOB ETHICS AND CONDUCT. 

A. On-Duty Behavior. The conduct of an ASI has a direct bearing on the proper and 

effective accomplishment of official job functions and responsibilities. ASIs are required to 

approach their duties in a professional manner and to maintain that attitude throughout their 

activities. Through their conduct, ASIs working in direct contact with operators a

 against allowing personal emotions or conflicts with industry personnel to influe

ctor need not tolerate harassment, they must not respond in kind. 

B. Rules of Conduct. All employee

Report for work on time and in a condition that will permit performance of 

assigned duties, i.e., in appropriate clothing, with appropriate tools or equipment, and in a 

mentally alert and physically fit condition. 

Render full and industrious service in the performance of their duties. If such 

duties are not sufficient

 hours. 

5) Exercise courtesy and tact in dealing with fellow workers, supervisors, and th

public. 

Employees must obtain approval of all absences from duty (including leave 

without pay). An absence that is not approved will be charged as absence without leave. In 

addition, di

Conserve and protect FAA funds, property, equipment, and materials (ASIs ma

not use or permit others to use FAA equipment, property, or personnel for other than official 

business). 

8) When duties concern the expenditure of public funds, have kn

 exercise sound judgment in the expenditure of such funds. Summaries o

penalty provisions of some of the more important laws relating to the misuse of Federal funds ar

contained in Title 49 of the Code of Federal Regulations (49 CFR) part 99. 

9) Safeguard classified information as provided in FAA Order 1600.2 and 

unclassified information that should not be given general circulat

 or except as required on a “need-to-know” basis in the proper discharge of 

official duties. Classified information shall not be discl

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appropriate securit

a) Divulge any official information obtained through or in connection with their 

government emplo

b) Release any official information in advance of the time prescribed for its 

authorized issuanc

se, any official information for private purposes that 

is not available to the general public. 

Order 3900.19.) 

In addition to avoi

ials and cooperate fully with the safety officer to ensure that the safety of persons 

or property is not endangered. Willful nonobservance of the governing safety regulations, such 

as the acts describe

a) Failure to report an accident involving injury to persons or damage to property 

or equipment; 

b) Failure to use protective clothing or equipment (e.g., failure to use a safety 

device when one i

c) Endangering the safety of or causing injury to personnel or damaging property 

or equi

icle for 

official

NOTE: As government employees, inspectors have immunity from personal 

liability

No immunity, assistance, protection, or indemnification will apply unless the 

conduc

loyment. 

11) . 

12) Report known or suspected violations of law, regulations, or policy through 

appropriate cha

e activities for personal gain or any other unauthorized 

purpose while on government property. 

y clearance. In addition, employees shall not: 

yment to any unauthorized person. 

e. 

c) Use, or permit others to u

d) Remove official documents or records from the files for personal reasons. The

willful and unlawful falsification, concealment, mutilation, or unauthorized removal of official 

documents or records is prohibited by law. 

10) Observe the various laws, rules, regulations, and other authoritative instructions. 

This includes all rules, signs, and instructions relating to personal safety. (FAA 

ding accidents, employees must report potential accidents and fire hazards to 

the proper offic

d below, constitutes grounds for disciplinary actions: 

s provided); 

pment through negligence; and 

d) Failure to wear an available safety/seat belt while using a motor veh

 government business. 

 for common law torts committed within the scope of their employment. 

t that is the basis of the tort was within the course and scope of the 

inspector’s emp

Uphold with integrity the public trust involved in the position to which assigned

nnels. 

13) Do not engage in privat

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 all 

d of, arising under the law, rules, and 

regulations administered by the FAA. 

15) Do not make irresponsible, false, or defamatory statements that attack, without 

foundation, the int

enever any other person is placed on the line 

for any purpose whatsoever. An advance verbal warning must be given when an automatic 

recording device o

t 

s, near-collision reporting, Command Communications Network, and the 

Washington Tactical Switch (FAA Order 1600.24). 

onduct of their official duties, may not use secret 

recording or monitoring equipment of any kind or aid in or ignore the improper use of such 

equipment

c safety. When there is creditable evidence that any employee is involved in 

the growing, processing, manufacturing, selling, disposition, transportation, or importation of 

narcotic dr ant drugs or substances, that employee shall be 

separated from the Federal service. Use, possession, purchase, or being under the influence of 

drugs on duty 

1) The FAA is committed to providing a workplace that is free of sexual harassment. 

All employees

2) Acts of sexual harassment are prohibited conduct and a single incident will result 

14) Give any supervisor or official conducting an official investigation or inquiry

information and testimony about all matters inquire

egrity of other individuals or organizations (ASIs are accountable for the 

statements they make and the views they express). 

16) Telephone eavesdropping is prohibited. 

a) Advance notice must be given wh

r a speaker telephone is used. The use of recording devices (portable or 

otherwise) on telephones shall be limited to areas involving air safety. This includes acciden

investigation

b) FAA employees, in the c

. 

c) The prohibitions do not preclude the use of normal or standard types of 

recording equipment used openly in areas. 

C. Substance Abuse. As an employer, the FAA is concerned with the private decision

of any employee to use illicit drugs or abuse alcohol or other substances in a way that could 

affect the employee’s work performance. As an employer with responsibility for aviation safety, 

the FAA is especially concerned when this private decision can affect the safety of the flying 

public. Employees directly involved in aviation safety that use illicit drugs or abuse alcohol or 

other substances place their jobs in jeopardy. Anyone known to do so will not be permitted to 

perform any duties related to aviation safety until the FAA is satisfied that any such person is no 

longer a risk to publi

ugs, marijuana, or depressant or stimul

by employees whose duties could affect the safety of people or property will also 

result in separation. 

D. Policy Against Sexual Harassment. 

 have a right to work in an environment in which they are treated with dignity and 

respect. Acts of sexual harassment will be treated as misconduct in violation of the agency’s 

policy against sexual harassment and, when appropriate, as unlawful sex discrimination in 

violation of Title 29 of the Code of Federal Regulations (29 CFR) part 1604. 

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