January 24, 2013

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

Room W12-140 1200 New Jersey Avenue, S.E. Washington, DC 20590

Re: Petition for Exemption from 14 CFR 121.915(d)

Ladies/Gentlemen:

• Pursuant to Federal Aviation Regulation (FAR) 11.63, American Airlines petitions the Administrator for an exemption from FAR Sectio n 121.915(d) to the extent necessary to permit American Airlines to implement the currently appr oved Continuing Qualification training program for fleets that are new to the operator. American c ould implement this training program without waiting 24 calendar months to petition the FAA to allow for a 36 month cycle, in which there are two Continuing Qualification evaluations.

SECTIONS OF THE FAR AFFECTED:

• Section 121.915(d). (Subpart Y – Advanced Qu alification Program - Continuing Qualification Curriculum), in pertinent part:

(d) “Duration of cycles and periods. Initially , the continuing qualification cycle approved for an AQP must not exceed 24 calendar months in duration, and must include two or more evaluation periods of equal duration. Aft er that, upon demonstrati on by a certificate holder that an extension is warranted, the FAA may approve an extension of the continuing qualification cycle to a maximum of 36 calendar months in duration.”

NATURE AND EXTENT OF RELIEF REQUESTED :

• This petition seeks relief from FAR 121.915(d) to allow all fleets, new or incumbent to utilize the currently approved Continuing Qualification tr aining program. This would allow new fleets (e.g.: A320, B787 and others) to continue w ith the American Airlines “9/18” Continuing Qualification training program that was implem ented in September 2001 and is used for all

American fleets – MD80, B737, B757, B767, and B777.2 | Page , American Airline Petition for Gr ant of Exemption (FAR 121.915)

SUPPORTIVE INFORMATION:

• Background:

American Airlines moved to the Advanced Qualification Program (AQP) Continuing Qualification training program in 1994. American expressed its intent to move to AQP and applied for a “Single Visit Exemption (SVE) – exemption 5950.” That Continuing Qualification program (or recurrent training program) provided for each pilot to train as a crew and afforded each pilot two simulator sessions, every 12 months. In addition to ground training, this program provided one day of si mulator training and a second day that was a

combination of a Maneuvers Validation and Line Operational Evaluation. Therefore, there was an evaluation every 12 months, or once per period a nd twice per cycle. A similar program is in use today, at numerous Part 121 carriers.

After utilizing this program for seven year s and collecting volumes of data, American decided to modify the Continuing Qualification program. The goals of the change were to increase training, allow for Check Airmen to have time for training (advanced training, not just checking functions), and decrease duration be tween periods. The objectives were met and approved and in September 2001, we implemented the “9/18” Continuing Qualification training program. With implementation, American has “demonstrated” to the FAA that an extension of the Continuing Qualification cycle was warranted.

Nine months after first qualifying on a partic ular aircraft, a pilot returns for Continuing Qualification training and receives an “R9.” The “R9” consists of ground training and two simulator sessions. Day one is simulator traini ng and the second day is a combination of a Line Operational Evaluation scenario and advanced training, conducted by a qualified Check

Airman.

Nine months after the “R9”, a pilot returns for an “R18.” The “R18” simulator portion is identical to the “R9” footprint, except for the second simulator session. The second simulator

is a combination of a Maneuvers Validation and advanced training, again provided by a qualified Check Airman.

In making this modification, American’s C ontinuing Qualification evaluation cycle moved

to 36 months.

The original purpose of FAR 121.915(d) was to ensure that carriers gained experience and data before moving evaluations periods beyond 24 calendar months. American gained that experience in the first seven years of AQP and made modifications, based on AQP data gathered. Since moving to the “9/18” program we have gained an additional 11 1⁄2 years of experience with AQP and the current Continuing Qualification program.3 | Page , American Airline Petition for Gr ant of Exemption (FAR 121.915)

Below is the profile of what a pilot would see in their first 36 months, on a given fleet (or all pilots on a new fleet), with today’s program . This program provides for three Maneuvers Validations and three Line Operationa l Evaluations in the first 36 months.

Figure 1

Timeline Event Types of Training

Month 1 Qualification Mane uvers Validation and Line Operation Evaluation +9 Months Continuing Qualification – R9 Training Simulator , Line Operational

Evaluation , and Advanced Training +18 Months Continuing Qualification – R18 Training Simulator, Maneuvers Validation, and Advanced Training +27 Months Continuing Qualification – R9 Training Simulator, Line Operational

Evaluation , and Advanced Training +36 Months Continuing Qualification – R18 Training Simulator, Maneuvers Validation, and Advanced Training

Since the introduction of our “9/18” program in 2001, other major carriers have moved to a similar nine month profile. Still, many ca rriers continue to use a 12 month Continuing Qualification program.

• Justification:

1. American Airlines considers our pilot training program “an AQP.” This interpretation of “an AQP” allows American to operate within the bounds of FAR 121.915(d). All training programs are based upon a singular training program and guidance. Each fleet (or curriculum) is an appendix to that single AQP. The section of the Pilot Qualification standards where fleet training footprints are located is entitled “Curriculum Outlines (Appendix).” As an example, The B777 fleet is found in section 11, as an appendix. Section 8 of the appendix is called “Continuing Qualification (all Aircraft).” This was intentional to provide for one high standard for all fleets. There are not Continuing Qualification curricula for each fleet – there is only one.

The FAA interpretation is that “an AQP” is fleet specific. Therefore, American must apply for an exemption to FAR 121.915(d) to u tilize our approved Continuing Qualification program for new fleets that have not u tilized a different Continuing Qualification

curriculum for 24 months.

2. In 2001, American Airlines heavily invested in the current “9/18” Continuing Qualification training program. This large investment was based on data and experience with the former 12 month or single visit training program. We currently provide more training, more frequency, and a higher quality program to our pilots. That should not change for a new fleet. The former SVE program is less expensive, provides less training, but would be permissible for our new fleets under Subpart Y and 121.915(d).4 | Page , American Airline Petition for Gr ant of Exemption (FAR 121.915)

3. Our 11 1⁄2 years of experience with the “9/18” Continuing Qualification training program has proven its value. This very successful pr ogram has led the industry and provides more training to our pilots, more frequently. Part 121.915(d) was written to ensure that carriers did not venture into Continuing Qualification programs, without first gaining experience and data under 24 month cycles. It is much more important that the carrier has experience with AQP or Continuing Qualification vs. the fleet. Our new fleets are administered by

Instructors and Check Airmen that have alread y done the same for other fleets. They are highly experienced with the “9/18” program. Our experience has driven the decision to invest in this higher quality training program . We believe it would be a disservice to our pilots and passengers to revert to the old tr aining program, which in our opinion, was of a lesser quality.

4. American Airlines believes in standardization. We invest in standardization, whether it is how our crews operate aircraft or how we c onduct training programs. We go to great lengths to ensure our programs and instruct ors are standardized. Having one fleet conduct a different program creates standardization challenges.

Investing in the “9/18” program, meant spe nding money to ensure our Instructors and Check Airmen were trained on the new Continuing Qualification program. These same Instructors and Check Airmen are the employees conducting training on the new fleets.

Changing the standards also introduces risk in the arenas of scheduling and regulatory compliance. Schedulers and IT systems were trained and programmed to administer and record the “9/18” program. Variation from the standard creates challenges. This also makes it more difficult for those applying the training programs.

5. This request does not represent a departure from “normal” training standards. Again, this proposal represents current and proven prac tice. Not only is this effective and demonstrated program used by American Airlines and other major carriers, it is very similar to what the FAA proposed in the Part 121, Subpart N&O NPRM in 2009 and SNPRM in 2011. That FAA proposal for a nine month recurrent training program contained a similar scenario, where the evaluation was every other period (for a 36 cycle). Every nine month interval was different, so me containing evaluations and other Line Oriented Flight Training (LOFT) instead. Th erefore, this request would be in agreement with current FAA proposals and current AQP practice.

6. This request only impacts fleets new to Amer ican Airlines. While pilots working on incumbent fleets may take 36 months to have tw o evaluations, this is not true for pilots on the new fleets. All pilots will be new to th ese new fleets and attend Qualification training. As shown in Figure 1 (page 3), pilots on these new fleets will have a Qualification evaluation at the completion of their initial or transition training. Nine months later they will get another evaluation and 18 months later, they will receive another evaluation. Therefore, in the first 27 months on the fleet , the pilot will have received three evaluations,

two of which will be Continui ng Qualification evaluations.5 | Page , American Airline Petition for Gr ant of Exemption (FAR 121.915)

PUBLIC INTEREST:

• Granting of this petition for exemp tion to FAR 121.915(d) would allow:

1. American Airlines to use of our proven and effective Continuing Qualification training program for all fleets.

2. Adherence by Pilots, Instructors, Check Airm en, Schedulers, and Administrators to a standard program, for all American Airlines fleets.

3. American Airlines to continue providing our p ilots more training, more frequently based on

the initial investment we made over 11 1⁄2 years ago and continue making today.

4. The relief requested will provide increased trai ning to American Airlines pilots, following a proven and effective program, with a commensurat e increase in the level of safety which is in the public interest.

NO ADVERSE EFFECT ON SAFETY:

• The granting and use of this exemption would have no adverse effect on safety because:

1. The current Continuing Qualification program has proven to be effective and has been in place for over 11 years.

2. This program provides American Airlines pilots more training, more frequently. Training programs conducted under Part 121, Appendix H re quire a Captain to receive training and a Proficiency Check each year (as little as two simulator sessions per 12 months) and a First Officers requires training and a Proficiency Check each 24 months (as little as two simulator sessions per 24 months). Under 121. 441(a), a proficiency check for a pilot in command (Captain) is required within the preceding 12 months and within the preceding 24 months for all other pilots (SIC or First Officer). The American Airlines program, in fact, provides a minimum of two simulator sessions every nine months, in a crew environment, thereby increasing the level of safety commensurate with the additional training provided. Additionally, our pilots, pilot in command and second in command, receive a Validation (Maneuvers Validation) or Evaluation (Line Operational Evaluation) every nine months. A Maneuvers Validation is almost identical to a Proficiency Check.

3. While there are less expensive alternatives, w ithin the regulation, American Airlines wants to continue to invest in this comprehensive pr ogram for all fleets. This decision is based on experience, feedback, and AQP performance data.

• This exemption proposal focuses on the quality, volume, and frequency of Continuing Qualification training for pilots on fleets new to American Airlines. This exemption request is predicated on the conditions and experience s hown under the "Nature and Extent of Relief Requested", the "Supportive Information" and "Public Interest" discussion listed above, which when considered in its entirety, will provide a hi gher level of safety vs. what is provided by the existing rule, while improving American's ability to provide quality air service to the public with greater benefits to the public, the FAA, and American Airlines.6 | Page , American Airline Petition for Gr ant of Exemption (FAR 121.915)

• A summary of this petition is attached as required by FAR 11.81(f).

Sincerely,

Christopher K. Broom Managing Director Flight Training

cc: Mr. Donald Braun – AMR CMO Dr. Douglas Farrow – AFS-230

Mr. Richard Van Keuren – AFS-230 Capt. John Hale – VP Flight AA Capt. Terry Barker – APA Training Committee

Attachment – Summary

Contact Information

Christopher Broom Managing Director Flight Training

American Airlines

PO BOX 619617

MD 863 GSWFA DFW Airport, TX 75261-9617

Office: 817-967-5483

E-Mail: chris.broom@aa.com7 | Page , American Airline Petition for Gr ant of Exemption (FAR 121.915)

ATTACHMENT: American Airlines Petition for Grant of Exemption (FAR 121.915)

SUMMARY

American Airlines' Petition for Exemption to 14 CFR 121.915(d).

American Airlines petitions the Administrator fo r an exemption from FAR Section 121.915(d) to the extent necessary to permit American Airlines to conduct Continuing Qualification training in the same manner for all fleets, in cluding new fleets, without waiting 24 calendar months to petition the FAA to exceed the 24 mont h cycle, with two Continuing Qualification

evaluations.