October 11, 2011 

Continental 

Airlines 

Sa~ty & Regulatory Compliance 

Post Offi<;e 6Q)[ 4607 HOSSY 

Houllton. TX 77210-4607 

T,I113324 8593 

Fa)! 713 324 S53S 

continental_com 

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ARYl.: 100 

Continental Airlines, Inc. and United Air lines, Inc. are commonly owned by United Continental Holdings, 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 will be the current Continental 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 the Airbus 319/320 and 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 remain 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 below. Also included in this letter is an AppendiK, which 

includes additional detail on operational controls, risk assessments, training curriculums, and evaluation results in support of this 

petition: 

Limited Timeframe of the Requested Exemption 

• Based upon United's anticipation of a Single Operating Certificate (SOC) being granted in late 2011, this eKemption 

request would exist for no more than six months in total duration 

• During this 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 completes the demonstrations prior to 

June 1, 2012 and prior to crewmembers flying on the opposite pre-merger aircraft. 

Precedence of Successful Prlor Evacuation Demonstrations 

• These aircraft are currently operated by United 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 Measures 

• United crewmembers are not being hired, 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 negotiated which permits cross-fleeting, a 

single seniority list is established and technology and process Integration involving crew scheduling and tracking can be 

accomplished. These steps are not forecast to be completed until 2013. 

• (ontrol measures exist to prevent pre-merger crewmembers from operating aircraft until they complete appropriate 

transition training. 

• Each carrier's crew management system will be maintained independently and populated with flight 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 sufficient to demonstrate a steady-state condition wiU exist at SOC 

without changes in assigned personnel on these fleet types. 

• A technology scope assessment describi.lg the crew monagement system is included in the Appendix. 

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Detailed Internal Risk Assessments Conducted, With Low Levels of Risk Identified 

• 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 concluded the controls, detailed within the Appendix, are comprehensive and 

there is very low overall potential risk. 

• A methodical approach has been applied to the harmonization of the air carrier procedures including those related to 

this petition. 

• A risk assessment of controls and a compendium docu~nt that elaborates each rele'llant process 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 of these assessments are included in the Appendix. 

Evacuations in the Field 

• On April 4, 2011, legacy United Airlines' flight attendants completed an evacuation using the 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 Attendants 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 contained in this petition. 

Sincerelv, 

Oon Gunther 

Staff Vice President Safety 

Continental Airlines