October 11, 2011 

# Continental Airlines**Sa~ty** & 

### Regulatory Compliance

Post Offi<;e 6Q)[ 4607 H OSSY Houllton. TX 77210-4607 T,I1133 24 8593 Fa)! 713 324 S53S 

### continental_com

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# ARYl.: 100

Continental Airlines, Inc. and United Ai r 

### lines, Inc. are commonly owned by United Continental Hol dings, Inc. as a result of the 

### merger completed on October 1, 2010. United and Continental have provided a Transition Plan which has been accepted by the FAA and for which Operation Specification AS02 has been issued in anticipation of a Single Operating Certificate (SOC) being granted in late 2011. The fina l operating certificate w ill be the current Continenta l Airlines certificate (CAlA014A). 

### The objective of th is letter is to request an exemption of 14 CFR § 

### 121.291(b) and (d), Demonstration 0/ Emergency Evacuation Procedures for th e Airbus 319/320 an d Boeing 747 aircraft fleets currently listed on United Air Lines (UALAOIlA) Operations Specifications, but not currently listed on the surviving certificate's (CALAOI4A) Operations Specifications. The air carrier is requesting that the eKemption become effective when the agency approves a Single Operating (ertificate for the merged airline and rem ain in effect until the carrier successfully conducts the required partial evacuation demonstrations, no later than June 1 , 2012. This eKemption is being sought based on the 5iK facts , elaborated be l ow. Also included in th i s letter is an AppendiK, which includes add it ional detail on operational controls, risk assessments, training curriculums, and evaluation results in support of th is petition: Limited Timefram e of the Requested Exemption • Based upon United's anticipation of a Single Operating Certificate (SOC) being granted in late 2011, th i s eKemption request would exist for no more than si x months in total duration • During th is timeframe, a plan to complete the 

### Demonstration 0/ 

### Emergency Evacuation Procedures on the applicable fleets will be submitted for FAA approval. This plan will detail a schedule that comp l etes the demonstrat ions prior to June 1 , 2012 and prior to crewmembers flying on the opposite pre-merger a i rcraft. Preced e nce of Successful Prlor Evacuation Demons trat i ons • These aircraft are currently opera ted by Un ite d Air Lines. United Air Lines conducted successful prior evacuation demonstrations for each type: • B747-4oo
- April 2008 upon interior reconfiguration • A319/320
- December 1993 upon introduction of the type Extensive Operational Control Measu res • United crewmembers are not being hi re d, but moved as part of an AS02 controlled merger, to the CALA014A certificate. • Crewmembers on the United aircraft moving to the Continental certificate will be partitioned by each subsidiary's collective bargaining agreement and each group cannot and will not fly the other group's aircraft. • This condition will continue until a single collective bargaining agreement is n egotia ted which perm it s cross-fleeting, a single seniority list is established and technology and process Integratio n involving crew scheduling and tracking can be accomplished. These steps are not fo re cast to be completed until 20 13

. • (ontrol measures exist to prevent pre-merger crewmembers from operating aircr aft until they complete appropriate transition training

. • Each carrier's crew management syste m w ill be maintained independent ly and populated with fligh t information associated with that carrier's system. Each crew management system will not recognize or accept employee numbers from the opposite carrier. This is a strict control prohibiting the possibility of crossing of personnel until appropriate procedural and technical hurdles have been met. • The carrier considers such controls are more than suffici ent to demonstrate a steady
-state condition wiU exist at SOC without changes in assigned personnel on the se fleet types. 

### • A technology scope assessment describi. l g the crew monagement system is included in the Appendix.

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### Detailed I nternal Risk A ssessments Conducted, With Low Level s of R isk I dentified • Risk assessments were conducted of the controls to ensure flight attendants cannot be scheduled or work as a member of a partitioned crew. The assessment concl uded the controls, detailed within the Appendix, are comprehensive and there is very low overall potential ris k. • Amethodical approach has been applied to the harmonization of the air carrier procedures including those related to this petition. • A risk assessment ofcont rols and a compendium**docu~nt** 

### that elaborates each rele'llantprocess change is 

### included in the Appendix. Completion of Comprehensive Flight Attendant Training • Changes associated with the harmonization have been communicated to flight attendants through written procedures, bulletins, and the implementation of a customized training curriculum

. Assessment data and test scores demonstrate high levels of understanding and retention against t he curriculum requirements and written procedures

. • Results ofthese assessments are included in the Appendix. Evacuati ons in the Field • On April 4, 2011 , legacy United Airlines' flight attendants completed an evacuation using th e approved integration procedures on an A320 with 104 passengers onboard Flight 497MSY/SFO. This incident is currently under investigation by the NTS8. • On September 14, 2011 , legacy United Airlines' flight attendants completed a successful evacuation using the approved integration procedures on a 87S7MQ with 181 passengers onboard Flight 586IAD/SFO

. This exemption is requested so that the air carrier may focus efforts on completing the required tasks to merge both operating certificates. Repeating these procedures at this time does 'not provide benefit to the public as the Flight A ttendants that currently fly these aircraft will be the same until the demonstration of emergency procedures have been completed. Granting this exemption request would not adversely affect safety for the same reason. The company requests that processing of its petition not be delayed for publication and comments in the Federal Register. Publication would cause unnecessary delay to the carriers' opportunity to avail themselves of the requested relief and reveal priva\e corporate data contai ned in this petition.
Sincerelv,

Oon Gunther Staff Vice Pres i dent Safety Continental Airlines