Francis Shea

Comment on: Proposed Rule: Clarification of Policy Regarding Designated Aircraft Dispatcher  Examiners Docket ID:  FAA-2011-1149 RIN: 2120-AA66 I am a retired Part 121 Aircraft Dispatcher.  With 33 years of   experience, my background includes working dispatcher, Manager of Dispatch Standards and Training, System Manager Dispatch Operational  Control and Director of Flight Control, all with a major Part 121 air carrier.  With that said, I professionally disagree with the proposed rule clarification and changes.  The operation of dispatch schools with DADEs under the strict observation, surveillance, and approval of the local FAA office has been successful for many years.  Relating to my personal experience, I could cite the Sheffield School of   Aeronautics 14 CFR Part 65 aircraft dispatcher school located in Ft.  Lauderdale, FL.  It has been in existence for 65 years and has an excellent reputation.  After many FAA inspections it has   received glowing reports.  To quote from an FAA inspection, “the  DADEs conducted all practical tests in accordance with regulations,  the Practical Test Standards, and procedures found in FAA guidance.     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.” This is a perfect example of the FAA and private industry working  together.  The system works.  It reduces FAA workload and increases  quality education for dispatch candidates. Change for the sake of change is harmful to small and large   businesses alike.  To quote an old Navy saying, “if it ain’t broke,  don’t fix it.”