I did not read the TWU letter. Some of the questions are sort of ridiculous, some are very valid, it would've been nice if ADF had taken the same route and asked good questions instead of jumping to "it's bad mmkay".
There isn't a requirement for a UPS, although it is a good point and should be looked at. There is a list of requirements and an agreement that must be signed, if you can't meet those requirements you are not allowed to dispatch from home.- What oversight will the FAA excise to ensure that at-home workstations are meeting the requirements of 14 CFR 121.99, including access to an uninterrupted power supply? If an at-home workstation does not or cannot meet these minimums due to the location of a dispatcher’s home or their local infrastructure, will the FAA bar the air carrier from assigning that dispatcher to work from home? Does the FAA expect each air carrier to provide at-home workstations capable of meeting federal minimums to each dispatcher?
There is a list of security requirements that have to be agreed to and met in the manual. I'd post them but I am not sure if it is ok to do, so I'll leave it that, there are procedures in place for this. The actual connection uses home internet as a backbone, which is probably highly susceptible to attack, but the dispatching is done through a secure VPN. I think the worst anybody can do is attack the home network but it'd be extremely difficult to compromise anything going through the VPN, you'd really just end up with no connection and need to go into the office. Software doesn't work off of the VPN.- What steps are necessary to secure dispatchers’ homes to a level consistent with FAA and TSA requirements for safety-sensitive personnel and equipment? What steps are necessary to secure dispatchers’ workstations and internet infrastructure from cyber threats? Is the airline or the dispatcher responsible for maintaining these levels? If it is a shared responsibility, which party is responsible for which aspects?
Inspectors have full access to releases, and if they need to perform surveillance they can do so by accessing whatever logged data they need, discussions can be held over phone, and screen share. I think they may have the ability to IM as well, but I'm not sure.- How will FAA inspectors, Transportation Security Administration (TSA) officials, and Aircraft Operator Security Coordinators perform their duties with regard to at-home dispatchers?
There are listed requirements for this that are also part of the signed agreement. They include but are not limited to working in a quiet distraction free environment, having a sturdy desk and appropriate chair, etc. You have to agree to these things to dispatch from home to begin with, and they do verify it. Can somebody lie? Sure, but they can also pull up random phones calls through the day and listen for background noise like a TV, screaming kids, etc.- What distraction mitigation procedures does the FAA believe need to be in place for at-home dispatchers? Will the airlines be responsible for establishing and enforcing these practices? What role does the FAA see itself playing to ensure distraction does not become a safety concern for at-home dispatchers?
This is a ridiculous question.- Will the FAA identify dispatchers’ homes as mobile unit under an aeronautical enroute station? Will dispatchers be required to maintain commercial RTO certificates to perform their duties at home?
It's become clear this is done differently at different shops. For us I don't think it changes, they notify, you go, end of story. Suspecting an on-duty dispatcher is under the influence is likely much harder, but I don't think it's impossible. They should maybe put in place periodic phone check ins in my opinion.- How will drug and alcohol testing be conducted for at-home dispatchers? What standard will be used to establish “reasonable suspicion” before testing individuals?
All SMS processes and procedures continue as normal. There could potentially be a need for changes, but I don't think it stops dispatching from home in its tracks.- Has the FAA approved changes to these air carriers’ safety management systems to account for operational changes necessitated by moving dispatchers to a remote location? What other steps has the FAA taken to ensure that this change will not have a domino effect to other safety-related regulations?
It should now feel like most of these actually have been addressed, and the PDI did not in fact say "The airline wants to do this, so let's approve it ASAP" because that didn't happen.I'll be very interested to see the FAA response to these questions, because a lot of them don't seem to have been considered at all. It feels like at Skywest the PDI said, "The airline wants to do this, so let's approve it ASAP" before looking at all of the potential safety and legal issues.