V.F. Dispatch System

Parts 121 and 135 require certificate holders to exercise

operational control over all flights conducted by the certificate

holder. "Operational control" is defined in 14 CFR part 1 as "The

exercise of authority over initiating, conducting and terminating a

flight." Operational control consists of making decisions and

performing activities on an ongoing basis that are necessary to

operate specific flights safely. These activities include among other

things crew and airplane scheduling, reviewing weather and NOTAM's

(Notices to Airmen), and flight planning.

Parts 121 and 135 provide for three general types of operational

control systems based on the kinds of operations and the complexity of

operations: aircraft dispatch, flight following, and flight locating

systems. Part 121 domestic and flag operations require a dispatch

system, part 121 supplemental requires a flight following system, and

part 135 requires a flight locating system for any flight for which a

flight plan is not filed. In Notice 95-5, the FAA proposed that the

affected commuters would be required to have a dispatch system.

Affected commuters would have to meet all part 121 dispatch

requirements, including dispatcher qualification requirements,

recordkeeping, and flight release requirements. As proposed, affected

commuters that would conduct some nonscheduled flights under part 121

supplemental rules could use a flight following method for the

nonscheduled flights.

The FAA also stated in Notice 95-5 that Alaskan operations pose

certain unique problems and requested comments on alternatives that

could be considered for Alaska.

Comments: Two individuals suggest that the use of a dispatcher

and dispatch system be an option for 10- to 19-seat certificate

holders, recommending compliance with existing subpart F of part 121.

Both commenters believe that the FAA should seriously consider

permitting, at least on an interim 36- month basis, compliance with

subpart F flight following requirements in lieu of subpart E dispatch

requirements for transition carriers. This will, in their opinions,

gain the early momentum of the industry by making it possible for many

certificate holders to transition early. A long lead time is

necessary to qualify existing personnel as dispatchers under existing

part 65. The commenters remind the agency that during the early

1980's, by the FAA's own rules, 20- to 30-seat aircraft were subject

to part 121 supplemental rules, including the flight following

requirements of subpart F. One of these individuals also states that

interim compliance with subpart F flight following requirements would

ease the transition to subpart E dispatch requirements for affected

certificate holders.

NATA comments that the FAA lacks understanding on the types of

operations 10- to 19-seat certificate holders typically fly and

recommends a flight following system instead of a dispatch system.

NATA states that many small, independent carriers operating aircraft

with 10 to 19 seats may have only 2 to 4 of these types of airplanes

and may operate them over only a few selected routes. According to

NATA, many of these carriers conduct on-demand operations in addition

to their scheduled activity. NATA believes, along with several other

commenters, that for operations such as these, to implement a full

dispatch system will result in significant cost with little or no


RAA and other commenters suggest that the FAA identify specific

safety objectives in requiring a dispatch system for short-haul

certificate holders.

One commenter believes that a formal dispatch system for all

scheduled air carriers should be required, but points out both the

pros and cons of requiring such a system. This commenter, as well as

others, states that pilots may be shouldering many additional

responsibilities other than flying the aircraft in an effort to

minimize the cost of flight operations. Due to the task saturation of

pilots and other crewmembers, functions involving flight planning,

weather analysis, and weight and balance calculations may not be

thoroughly performed. According to the commenter, the majority of

commuter pilots are, as a rule, very young and inexperienced. These

crews must continually perform at peak levels of performance both on

the ground and in the air.

According to this commenter, as well as others, the use of the

flight dispatcher would increase safety, operational efficiency, and

productivity. The duties of filing the flight plans, checking NOTAMs,

planning fuel requirements dictated by weather, and obtaining ATC

routing would be completed by the dispatcher prior to the crew

arriving for the flight. Optimum routes based on known ATC or weather

delays would be filed, resulting in substantial fuel savings and

improved arrival and departure reliability. The pilots would now be

able to concentrate on flying and be able to relax and rest between

flights. Flight could be more effectively managed, thus saving fuel,

maximizing aircraft utilization, and passenger satisfaction.

On the other hand, according to the commenter, mandating the

dispatch system for part 135 air carriers may create some heavy

financial burdens. It will require a facility, communications

hardware for the facility and the aircraft, trained personnel, and

training for dispatchers. The initial capital outlay would not be

recovered for several years. According to the commenter, this mandate

will place severe constraints on many less established carriers and

may actually result in bankruptcy for some.

Many commenters are in favor of the role of the aircraft

dispatcher in operational control issues. One commenter states that

the requirement for a formal dispatch system is long overdue.

One commenter believes that dispatch centers might create a sense

of complacency on the part of the flightcrew and, along with other

commenters, thinks that automated flight planning and flight following

information should be used in lieu of dispatchers and dispatch

centers. Two of the commenters advocating automated flight following

systems state that the three accidents cited by the FAA in Notice 95-5

would not have been prevented by the use of a dispatcher. One

commenter states that in his experience PIC's typically check

dispatcher computations but do not duplicate the computations as the

FAA stated in Notice 95-5.

The NTSB states that in its 1994 study report, it examined the

differences in flight dispatch requirements between parts 121 and 135.

The NTSB found that, in the absence of support from licensed dispatch

personnel, pressures on commuter airline pilots to accomplish several

tasks between flights in shorter periods of time might increase the

risk of critical mistakes that could jeopardize the safety of flight.

As a result, the NTSB recommended that the FAA require each principal

operations inspector (POI) to periodically review air carrier flight

operations policies and practices concerning pilot tasks performed

between flights. This review was to ensure that carriers provide

pilots with adequate resources (such as time and personnel) to

accomplish those tasks. According to NTSB, the proposed rulemaking,

if implemented, would meet the intent of the safety recommendation


ASA, RAA, and Gulfstream International Airlines support many of

the elements of the dispatcher rule. They state that flight dispatch

systems that are required under part 121 are extensive since they

address the dispatch and en route communications needs for a span of

air carriers from international airlines with worldwide flight

operations to the largest U.S. regional carriers. ASA supports the

requirement for licensed dispatchers, believing that the most

qualified candidates for licensing as dispatchers are the individuals

currently employed as flight followers. These commenters request that

the criteria in § 65.57 be examined to provide guidance for granting a

dispatcher certificate based on practical experience as a flight

follower under part 135 operations. According to the commenters, many

flight followers have passed the written portion of the dispatch

license but have not attended formal dispatch school and do not hold

licenses. However, they may have extensive practical experience in

scheduled air carrier operations performing what is essentially a

dispatcher function. According to these commenters, the criteria

contained in § 65.57 includes experience in scheduled military

operations. The commenters believe that if military experience is

applicable, the experience of a flight follower with a scheduled

airline should qualify. These commenters also point out that the

practical portion of the dispatcher license is administered using a

Boeing 727 aircraft. The commenters believe that while many of the

functions and decision making circumstances would be the same, the

experience of part 135 flight followers, managing flights of high

performance turbopropeller-powered aircraft is a considerably more

significant and practical measure of their capabilities than military

experience or demonstrating their skills in managing a turbojet

operation. The commenters believe that the cost and time to send

current flight followers to a formal dispatcher school is not


Samoa Air comments that since its longest flight is only 70 miles

(35 minutes), a dispatch system would not enhance or change any of its

current requirements. Samoa has established VFR and IFR fuel

requirements to all of its destinations and the requirements do not

change. The only alternate airport is the destination airport. Samoa

also states that § 121.101 requires each domestic and flag operator to

show that enough weather reporting facilities are available along each

route to ensure weather reports and forecasts necessary for

operations. Section 135.213 allows the pilot in command to use

various other sources, including his own weather assessment, for VFR

operations. Of the four airports Samoa serves, only one (departure

airport) is in controlled airspace with weather reporting facilities

and instrument approach procedures. Enroute and terminal weather

conditions are received through the ATC tower from their weather

station. VHF communications with the tower cover almost the entire

route, so the aircraft has ready access to any weather information

available and direct information on the status of communications,

navigation, and airport facilities. A dispatcher would not enhance

safety but would add significant cost. If Samoa is required to

provide weather conditions at each airport to the pilot from an

approved source and the pilot can not assess the weather himself, the

rule change could eliminate all of Samoa's present operations.

Similarly, Inter Island and Air Vegas comment that the

requirement for enroute weather reporting is unfeasible because of

minimal weather reporting facilities in the certificate holders'

regions. Air Vegas also comments that radio communication in

mountainous terrain would be difficult if not impossible with VHF

radio systems because mountains block radio transmission.

Air Vegas comments that all "dispatcher duties" are currently

being accomplished by personnel in the operations department, station

managers, and company pilots. All flight following is being done by

telephone. The commenter states that current flight following

procedures meet part 135 requirements and are operationally safe and


Mesa Airlines comments that due to its short flight segments and

the lack of significant weather changes in the areas in which it

operates, a dispatch system is not needed. Mesa believes that all

enroute communications can be accomplished by ATC.

AACA states that the requirements of subpart E come at a time

when the availability of weather information in Alaska has been

identified as a significant issue adversely affecting aviation

activities (proceedings of an NTSB "Aviation Safety in Alaska" forum,

May 1995).

The Airline Dispatchers Federation supports the dispatch proposal

and agrees with the upgrading of current commuter facilities to

dispatch centers. It believes this upgrading is necessary because of

the extensive use of code-sharing by the aviation industry. The

commenter is not in favor of amending part 121 dispatch rules for

certificate holders of the 10- to 19- seat category. The commenter

provides its estimate of costs to certificate holders that could be

affected by the implementation of this rule. The commenter notes that

the costs provided by some certificate holders may not be accurate.

For example, cost estimates concerning flight planning and performance

issues are inaccurate since several airlines use bulk stored flight

plans and performance information taken directly from aircraft flight

manuals for fuel planning. The commenter also provides its assessment

of various aircraft accidents for which it believes dispatchers could

have made a difference in changing events that led to the accident

(crew fatigue, lack of management oversight, operational control

issues, late arriving weather information).

ALPA comments that dispatchers should be required to complete

their 5-hour inflight operating experience in 10- to 30- seat

aircraft, not in larger 60-seat aircraft, as currently allowed. ALPA

proposes that § 121.400(b) be amended by adding a group specific to

propeller-driven aircraft with a seating capacity between 10-30 seats.

AACA comments that due to the operating environment of Alaska,

the pilot and not the dispatcher is in a better position to access and

evaluate operational control information. The commenter believes that

scheduled operations in Alaska more closely resemble the operations

conducted under supplemental rules and not domestic or flag

operations. The commenter notes that pilots frequently are not in

radio communication with company offices directly, but could

communicate via Flight Service Station, ATC, or other aircraft.

According to the commenter, enroute and destination weather conditions

are either not accessible or not available at any time from "official"

sources. The commenter notes that three affected certificate holders

in Alaska presently have a part 121 type dispatch system in place.

AACA further states that the assumption that estimated fuel savings by

dispatchers would offset the cost of establishing a dispatch system is

not true. AACA recommends that the FAA adopt the flight following

supplemental rules of part 121 for Alaskan 10-19 seat certificate

holders. AACA also recommends that current part 135 personnel be

"grandfathered" for dispatcher certificates if they have been employed

as flight followers. The commenter notes that the practical

experience dealing with turboprop aircraft and flight planning may be

lost to the industry if flight followers are required to take

extensive dispatcher training courses, pass a written and practical

test, and lose time and money on the job while they obtain an FAA

dispatcher certificate.

FAA Response: The FAA anticipates that requiring operators to

have a certificated dispatcher double check the work of the pilot and

provide the flightcrew with updates on weather and alternate airports

can reduce human factor errors. With a dispatcher system, the chances

of pilot miscalculations or oversights could be reduced. Moreover, a

dispatcher can assist the flightcrew in making plans for an alternate

airport (which might be necessary due to weather problems, air traffic

control problems, airplane equipment problems, fuel problems, etc...)

during the flight while the crew focuses on flying the airplane.

The FAA disagrees with the recommendation to make the use of a

dispatcher and dispatch system optional since that would not address

the safety issues involved. The FAA also disagrees that a flight

following system is an acceptable alternative to a dispatch system or

that dispatch systems are not needed for limited flight distances if

there is adequate weather reporting facilities. The use of a dispatch

system is based on the type of operation (scheduled), and not the

distance of a flight, the number of aircraft, or the type of aircraft

being flown. Flight following systems are used for nonscheduled

operations, and could be used for nonscheduled operations by affected

commuters under the supplemental rules of part 121. Note: The

dispatch system requirements apply only to scheduled passenger-

carrying operations.

The FAA disagrees with the basic idea that the decision making

process of operational control of aircraft can be made by automated

means. While automation has improved the accuracy and timeliness of

flight planning, weather information, and NOTAMs, nothing so far has

replaced the decision making capabilities of a certificated

dispatcher. Dispatchers receive training in subject matter beyond

just flight planning, e.g. crew resource management, hazardous

materials regulations. These subjects are just a small representation

of the subject matter an aircraft dispatcher must know in order to

make operational control decisions.

The FAA agrees with the comment that dispatchers are usually in a

better position to review weather reports and forecasts than pilots

hurrying to accomplish other postflight/preflight aircraft duties.

Operational control issues are enhanced when both the pilot in command

and the aircraft dispatcher are jointly responsible for the safe

conduct of a flight. As several commenters point out the overall

level of safety is enhanced when a dispatcher is available to assist

and back up the pilots who already may have numerous responsibilities

in addition to flying the airplane. Thus, while it may not be

possible to pinpoint accidents that have actually been prevented by a

dispatch system, there can be little doubt that the existence of a

dispatch system contributes to the overall high level of safety of

scheduled operations under part 121.

The FAA does not agree that use of dispatchers would lead to

complacency on the part of the flight crewmembers. Section 121.663

states that for each domestic and flag operation, a dispatch release

must be prepared based on information furnished by an authorized

dispatcher. The pilot in command and an authorized dispatcher shall

sign the release only if they both believe that the flight can be made

safely. Dispatchers provide the necessary resources and expertise

needed to review operational control issues.

In response to comments that in some companies "dispatch"

functions are being adequately performed by individuals from three

separate departments (operations, station managers, and company

pilots), the FAA finds that operational control decisions can not be

effectively made by three separate groups of individuals. The

perception is that "whoever is available" makes the decision. For

effective operational control, the dispatch process should be

standardized and consistent.

In response to NATA's and others' comments on the nature of 10-

to 19-seat certificate holders, the FAA finds that these certificate

holders are not unique. The same situation currently exists for some

part 121 certificate holders who are required to maintain dispatch


In response to comments on the issue of limited areas of

operation and short flight duration, the requirement for a dispatch

facility is not based on distances, the type of aircraft, or weather

patterns alone. It is the type of operation (scheduled) an air

carrier is currently operating under that determines if dispatch

systems are required. The role of the aircraft dispatcher in the

operational control of aircraft provides an enhancement to safety that

has clearly been established through years of operations by many air

carriers in both domestic and flag operations. Continuous

communications could be accomplished with HF radios or through

satellite communications, both of which can be provided through


The FAA agrees with commenters that for some part 135 certificate

holders, personnel will first have to acquire the necessary

certificate and then complete required air carrier training

requirements for dispatchers. The average dispatcher school

curriculum lasts 5 weeks and usually includes instruction on both the

written and practical tests. The FAA believes that some part 135

personnel already possess aircraft dispatcher certificates and that

these personnel would be required to attend only the air carrier's

dispatcher training program. Regardless, once an air carrier employs

a certificated dispatcher, company training would have to be

completed. That training would entail 40 hours of basic

indoctrination, differences training, initial ground/transition of 30-

40 hours (based on the type of aircraft), and a competency check (see

§ 121.422).

While the FAA does not agree with AACA's recommendation to

"grandfather" dispatcher certificates to current flight followers or

flight locating personnel, § 65.57 outlines a means of providing

credit for previous experience in order to take the practical test.

All dispatcher applicants must complete the appropriate written and

practical tests before a certificate can be issued. The FAA agrees

that training costs will be incurred to prepare current flight

following or flight locating personnel to qualify for a dispatcher

certificate, regardless of who pays for the training. Replacement

personnel will be needed if the decision by the certificate holder is

to send current employees to dispatcher training.

There is no requirement for dispatchers to attend a formal

school. Section 65.57, entitled experience requirements, allows

several options in lieu of a formal school.

In response to specific requests to expand the criteria in

§ 65.57 (aircraft dispatcher experience requirements) to include

personnel assigned to flight locating and flight following under part

135, the FAA believes that some part 135 experience is acceptable as

equivalent experience in § 65.57. Through current policy and guidance

provided to FAA inspectors, a review on a case-by-case could be

accomplished to ascertain if an applicant has equivalent experience.

In response to comments on the current format of the dispatcher

practical exam, § 65.59 requires an applicant for an aircraft

dispatcher certificate to pass a practical test with respect to any

one type of large aircraft used in air carrier operations. Further,

current practical test standards require dispatcher applicants to

exhibit adequate knowledge of applicable aircraft flight instruments

and operating systems. The scope of the practical test allows for

turboprop aircraft and representative commuter operations. Practical

tests are developed by the inspector conducting the test and can be

designed for any type of large aircraft, including turboprop


There is only one dispatcher written examination, the Airline

Transport Pilot question book. The selection sheet has questions

applicable only to dispatchers and not based on any particular make

and model of aircraft. The FAA is considering developing written

tests geared to commuter-type operations. However, the current

written exam is valid in that it tests for areas common to all make

and models of aircraft. The test requires knowledge of various

subject areas, i.e. the ability to interpret weather information,

interpret regulations, handle emergencies, compute weight and balance,


The FAA disagrees with the ALPA recommendation to require

dispatchers to receive 5 hours of operating experience in aircraft

they will actually dispatch. Section 121.463(c) requires the

dispatcher to satisfactorily complete at least 5 hours of operating

familiarization in one of the types of airplanes in each group he is

to dispatch. Section 121.400(b) includes all sizes of propeller-

driven aircraft under group 1. Therefore, the FAA allows dispatchers

to complete the operating familiarization in airplanes that are not

exactly the same size or configuration as the ones they will dispatch.