May 30, 2012

U.S. Department of Transportation Docket Management System 400 7 th Street, S.W. Room PL 401 Washington, D.C. 20591

- 0001 Subject: Re

- grant of Exemption 8175 Regulatory Docket No. FAA

- 2003

- 16403 Dear Sir/Madam: Pursuant to Title 14, Co de of Federal Regulations, Part 11.61, PSA Airlines, Inc. petitions the Administrator for a grant of exemption which will p ermit PSA Airlines, Inc. an exemption from 14 CFR 121.434(c)(1)(ii) to the extent necessary to substitute a qualified and authorized check airman or aircrew program designee in place of an FAA Inspector to observe a qualifying pilot in command (PIC) while that PI C is performing prescribed duties during at least one flight leg that includes a takeoff and landing when completing initial or upgrade training as specified in 14CFR 121.434. Section of the Federal Aviation Regulation (FAR) affected: 14 CFR 121.434(c)(1)(ii) (Operating Experience, Operating Cycles, and Consolidation of Knowledge and Skills) in pertinent part: “In addition, if a qualifying pilot in command is completing initial or upgrade training specified in § 121.424, be observed in the performance of pres cribed duties by an FAA inspecto r during at least one flight leg which includes a takeoff and a landing.” Relief Requeste d : This petition seeks relief from FAR 121.434(c)(1)(ii) when an FAA Inspector is unavailable to observe a qualifying pilot in command during any of the scheduled operating experience flights subject to the following conditions and limitations : 1. A PSA che ck airman or aircrew program designee may conduct a PIC observation in place of an FAA inspector when

a. The Administrator pre

- approves that substitution for each observation of a qualifying PIC candidate, thus reserving first right of refusal to the FAA in each case;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 flight deck preparation, before starting engines checklist, taxi, takeoff, all other flight phases, landing, taxi, and securing checklist. 2. Each PSA 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 desi gn ee for PSA 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. 3. PSA must maintain student, check airman, and aircrew program designee records that demonstrate compliance with the conditions and limitations of the exemption. Discussion The FAA has the authority to observe any pilot any time it wishes; and the FAA does so routinely. However, the FAA conducts these routine observations on a schedule the local office sets without the burden of having to observe a particular pilot on specific flights necessitated by the airline’s training and service schedule. Relieving FAA Inspectors form 121.434(c)(1)(ii) will allow the FAA to focus their efforts on higher priority safety concerns. PSA Airlines expects 8 to12 new PIC’s per month to complete training indefinitely due to attrition

. Previous experienc e with this volume of training has had PSA waiting for up to 30 days waiting for an Inspector to observe a new PIC. Because of recent budgetary and travel constraints imposed on the FAA, our Certificate Management Office ha s struggled at times to provide p ersonnel on a timely basis. Other FSDOs and national resources have been unable to support the volume of work that has been required. Delays in getting observations performed have been costly to the airline resulting in undue economic and operational burdens. Grant of Original Exemption PSA was previous granted this exemption on November 14, 2003 ( Exemption No. 8175, Regulatory Docket No. FAA

- 2003

- 16403) , and again on June 20, 2007 (Exemption No. 8175A). This exemption expired on June 30, 2009

. An extens ion was not requested at the time due to a reduction in training volume.

Benefits Benefits to the FAA, PSA Airlines, and the traveling public remain the same as in the original application.No Adverse Effect on Safety

Granting or using this proposed exemption would have no adverse effect on safety because: 1. The Check Airmen and Aircrew Program Designees authorized to conduct the observation will be approved by the FAA and will be highly trained and experienced with the particular airplane type. 2. The Ch eck Airman and Aircrew Program Designees will only be used to fulfill the requirements of 14 CFR 121.434(c)(1)(ii) when a qualified FAA Inspector is not available; and 3. The FAA continues to have the authority to observe any pilot at any time during normal l ine operations Request To Waive Publication Of Petition Since the FAA has previously granted this exemption to PSA Airlines, and the granting of this exemption is not precedent setting, PSA Airlines requests that publication of our petition in the Federal Register be waived in accordance with 14 CFR 11.87(b). Any delay in granting this exemption will have an adverse impact on PSA Airlines’ flight operations

. Summary In summary, the exemption focuses on the timely and competent completion of the observation flight and better utilization of qualifying pilots in command. PSA Airlines petitions for an exemption from 14 CFR 121.434(c)(1)(ii), to permit them, at their discretion, when an FAA Inspector is not immediately available; to provide observation of a qualifying PI C when completing initial or upgrade training as specified in 14 CFR 121.434. PSA Airlines will substitute a qualified and authorized check airman or aircrew program designee to observe the qualifying pilot in command in the performance of pre scribed duties subject to certain conditions and limitations.

Sincerely,

/s/ Gary M. Dybdal Director of Training PSA Airlines, Inc.