October 07 , 2014

U.S. Department of Transportation Docket Operations West Building Ground Floor

Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

Subject: Petition for Exemption

– Request to expand relief given to military and civilian

personnel supporting the Armed Forces stationed outside the United States from knowledge test expiration to those supporting the Armed Forces who were stationed in the United States (61.39(a)(1)(i)(ii ))

To whom it may concern:

The Air Line Pilots Association, International (ALPA) is the largest airline pilot union in the world and represents the interests of over 51,000 pilots who fly for 30 airlines in the U.S. and Canada. We are submitting this “Pe tition for Exemption” pursuant to 14 C.F.R. Sections 11.61 and 11.63 requesting the FAA to expand the relief from the knowledge test expiration dates contained in 14 CFR 61.39(a)(1)(i)(ii) already granted to others. The additional relief sought is

for thos e who served in a U.S. military or civilian capacity in support of the U.S. Armed Forces

that were stationed in the U.S

.

There is a preceden t for providing relief from the requirements that the knowledge test be taken within the designated times preceding the practical test contained in 14 CFR 61.39. Relief is already provided to those who served in a U.S. military or civilian capacity outside the U.S. in support of the U.S. Armed Forces by 14 CFR Part 61 SFAR 100

- 2

. This relief recognizes the priority of military service and the logistical difficulty of having access to the practical test.

SFAR 100

- 2 only applies to those who were stationed outside the U.S . We request that relief to use an expired knowledge test also be made available to those who served in the U.S

. ALPA feels that the same challenges to taking the knowledge test by members of the Armed Forces overseas can exist for all those in military service regardless of their duty location.

It is very possible that those stationed in the U.S. would not have the time or access to facilities to pursue acquiring the required ground and flight training, build the required aeronautical experience and study in prepar ation to take the practical test while fulfilling their service duties.In regards to the ATP knowledge test in particular, many who had already passed the ATP

knowledge test but had not completed the practical test were pilots who had to go on leave from their respective airlines to serve. Not only those stationed outside th e U.S.

, but even the pilots stationed in the U.S. would not have the opportunity to obtain their ATP through their employer while on leave. As you are aware, even pilots stationed at U.S. bases flew missions

over other areas of the world from those bases e ither on board the aircraft or operating as a pilot of a UAS/RPA aircraft. These assignments and operations required considerable training preparation and focus, leaving little time for other non

- military activities. Obtaining the ATP through their emplo yer allows them to utilize the aircraft /simulator they are proficient on for the practical test. The time and cost for the pilot to reach an ATP proficiency skill level on a different aircraft would be excessively burdensome. These pilots should not be sub ject to retaking the ATP knowledge test with a prerequisite of first taking an ATP CTP course which would add a significant burden of time and expense. Therefore, pilots who served in a U.S. military or civilian capacity in support of the U.S. Armed Forces in the U.S. should also be provided relief so that they can use an expired knowledge test to take the practical test.

Public Interest:

We believe an equivalent level of safety will be obtained by extending the knowledge test expiration relief to those who served and were stationed in the U.S. as it is for those stationed

outside the U.S . In fact, in regards to the ATP knowledge test

, an increased level of safety may

be achieved. This is so because the airline pilots who were already proficient on their airline’s air transport category aircraft will not potentially be required to take an ATP CTP course on different equipment. Such training would be inconsistent with what they have already been taught by the air carrier and require the pilot to unlearn por tions of what was taught by the air carrier to pass the ATP CTP course , and finally unlearn portions of what was taught at the ATP CTP course to transition back into the aircraft they fly for their airline. This confusing process would potentially impact s afety in a negative way.

Thank you for considering this petition for exemption. If you have any questions please contact

Mr. Kevin Comstock at 703

- 689

- 4176.

Sincerely,

Captain Sean Cassidy National Safety Coordinator

cc: P. Gilligan, Assoc. Admin. for Aviation Safety, FAA
J. Duncan, Director, Flight Standards Service