Captain Ron Thomas

Managing Director

Flight Operations

4601 Highway 360 MD 843

Fort Worth, Texas 76155

Office 817-967-5156

Ronald.Thomas@aa.com

April 29, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Subject: Request for Extension to Exemption 6916H, as Amended

References:

• CFR 121.434(c)(1)(ii)

• Exemption 6916 (Docket No. FAA-2001-8878

Ladies/Gentlemen:

In accordance with Title 14 Code of Federal Regulations (CFR) §11.61, American Airlines petitions the 

Federal Aviation Administration (FAA) for an extension to Exemption 6916H (Docket No. FAA-2001-

8878), as amended. This exemption is due to expire on July 31, 2015.

Exemption 6916 provides relief from Title 14, CFR §121.434(c)(1)(ii), and allows American 

Airlines to substitute a qualified and authorized check airman or aircrew program designee for an 

FAA inspector to observe a qualifying pilot in command (PIC), who is completing initial or 

upgrade training, during at least one flight leg, that includes a takeoff and a landing.

The conditions and circumstances regarding public interest and equivalent level of safety, which 

warranted the original grant of exemption, continue to exist. This exemption has been in use since 2001

with no known compromise of safety.

In accordance with the provisions of Title 14 CFR §11.87, American Airlines requests that a finding of 

good cause be made for waiving publication of this Exemption request in the Federal Register. Since 

similar exemptions were granted to other Part 121 Air Carriers, no precedent will be set by granting this 

extension. Therefore, American Airlines requests the publication and comment period be waived, as well.

A summary of this petition is attached, as required by Title 14 CFR §11.81, along with the previous letter 

of FAA approval. Please advise if you require any addition information in order to evaluate or act upon 

this petition extension request.

Regards,

Captain Ronald J. Thomas

Managing Director, Flight Operations
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Ecc: Mr. Chris Broom, Managing Director Flight Training Administration

Mr. Calvin R. Lott, Jr. (FAA) Principal Operations Inspector, American Airlines CMO

Mr. Larry Mayes (FAA), Assistant Principal Operations Inspector. American Airlines CMO

Captain J. D. Walker, Manager Advanced Qualification Program

Mr. Alan Clay, Director Flight Operations Specifications

Mr. Rich Yuknavich, Regulatory Compliance Specialist 

Att: FAA Letter Dated May 02, 2013 Granting Extension to July 31, 2015

Summary of Petition
Docket FAA-2001-8878

Attachment

April 28, 2015

SUMMARY OF AMERICAN AIRLINES PETITION

Petitioner: American Airlines, Inc.

Regulations Affected: FAR § 121.434 (c)(1)(ii).

Description of Relief Sought: American Airlines requests an extension and amendment of 

Exemption No. 6916 (Docket No. 2001-8878) which is due 

to expire on July 31, 2015. This exemption provides relief 

from FAR §121.434(c)(1)(ii) to permit American Airlines

to substitute a qualified and authorized check airman or 

aircrew program designee for an FAA inspector to observe 

a qualifying pilot in command (PIC) who is completing

initial or upgrade training specified in §121.424 during at 

least one flight leg that includes a takeoff and a landing.
AFS-13-237-E

May 02, 2013

 Exemption No. 6916H

 Regulatory Docket No. FAA-2001-8878

Mr. Christopher K. Broom

Managing Director, Flight Training

American Airlines

P.O. Box 619617

DFW Airport, TX 75261-9617

Dear Mr. Broom:

This letter is to inform you that we have granted your petition to extend Exemption No. 6916, 

as amended. It explains the basis for our decision and describes its effect, and lists the 

conditions and limitations.

The Basis for Our Decision

By letter dated February 20, 2013, you petitioned the Federal Aviation Administration (FAA) 

on behalf of American Airlines (American) for an extension of Exemption No. 6916, as 

amended. That exemption from § 121.434(c)(1)(ii) of Title 14, Code of Federal Regulations

(14 CFR) allows American to substitute a qualified and authorized check airman or aircrew 

program designee for an FAA inspector to observe a qualifying pilot in command (PIC) who 

is completing initial or upgrade training specified in § 121.424 during at least one flight leg 

that includes a takeoff and a landing.

In your petition, you indicate that there has been no change in the conditions and reasons

relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to American.
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Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 6916, as 

amended, remains valid with respect to this exemption and is in the public interest. Therefore, 

under the authority provided by 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I grant your petition, subject to the conditions and limitations listed 

below.

Conditions and Limitations

1. An American check airman or aircrew program designee may conduct a PIC 

observation in place of an FAA inspector when –

a. The Administrator preapproves that substitution for each observation of a 

qualifying PIC candidate, thus reserving first right of refusal to the FAA in 

each case. American, therefore, must contact an appropriate FAA office, in 

each instance, before substituting that check airman or aircrew program 

designee;

b. The qualifying PIC candidate has completed no less than 10 hours of 

supervised operating experience (OE) and accomplished no fewer than two 

takeoffs and landings; and

c. The qualifying PIC candidate is performing PIC duties during a complete flight 

leg, including flightdeck preparation, before starting engines checklist, taxi, 

takeoff, all other flight phases, landing, taxi, and securing checklist.

2. Each American check airman or aircrew program designee conducting a PIC 

observation in place of an FAA inspector must –

a. Be approved by the Administrator to conduct the observation;

b. Have served as a check airman or aircrew program designee for American for 

no less than 6 months; and 

c. Not supervise the OE or conduct the initial line check for the qualifying PIC 

candidate being observed.
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3. American must maintain student, check airman, and aircrew program designee records 

that demonstrate compliance with the conditions and limitations of this exemption.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 6916, as amended, to July 31, 

2015 unless sooner superseded or rescinded. 

Sincerely,

/s/

John S. Duncan 

Deputy Director, Flight 

Standards Service