The NPRM Docket No. FAA-2008-067: Notice No. 08-07A is of enormous concern to me. It proposes to allow contract dispatching for part 121 air carriers. This would allow major airlines, like SkyWest Airlines, to outsource Dispatcher jobs to flight planning mills like Jeppeson.
They tried this back in 2008, when the idea was defeated by safety advocates. Allowing the most safety critical aspects of operational control and flight planning to be outsourced to the lowest bidder would put America's public at risk.
Contract Dispatching would compromise safety, operational control, and mutual trust between the Captain and his/her FAR 121 Licensed Dispatcher and should never be allowed as an option with this NPRM.
Aircraft Dispatchers work behind the scenes keeping you safe, monitoring weather conditions, tracking flights enroute, flight planning around turbulence and severe weather, while communicating with crews before, during and after their flights. The safety record we enjoy here in the U.S. has been attributed in part to the job Aircraft Dispatchers play every day in airline operations. In 1990 Avianca Flight 52 crashed at JFK, an accident attributed to their lack of Dispatcher operational control (Columbia and many foreign countries have no Dispatch operational control requirements). We have seen the safety consequences of allowing contract maintenance outside of the U.S., the consequences will be far more severe if contract dispatching is allowed.
G. Brooks
This is comment on Rule
Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers
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