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 Section 121.915(d) to the extent necessary to permit 

American Airlines to implement the currently approved Continuing Qualification training program for 

fleets that are new to the operator. American could 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 Qualification 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. After that, upon demonstration 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 training program. This would allow new fleets 

(e.g.: A320, B787 and others) to continue with the American Airlines “9/18” Continuing 

Qualification training program that was implemented in September 2001 and is used for all 

American fleets – MD80, B737, B757, B767, and B777. 
2 | Page , American Airline Petition for Grant 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 simulator 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 and twice per cycle. A similar program is in 

use today, at numerous Part 121 carriers. 

After utilizing this program for seven years 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 between 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 particular 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 training 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 Continuing 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 Grant 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 Operational Evaluations in the first 36 months. 

Figure 1 

Timeline Event Types of Training 

Month 1 Qualification Maneuvers 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 carriers 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 utilize our approved Continuing Qualification 

program for new fleets that have not utilized 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 Grant 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 program 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 already 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 training 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 conduct training programs. We go to great 

lengths to ensure our programs and instructors are standardized. Having one fleet conduct 

a different program creates standardization challenges. 

Investing in the “9/18” program, meant spending 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 practice. 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, some containing evaluations and other Line 

Oriented Flight Training (LOFT) instead. Therefore, this request would be in agreement 

with current FAA proposals and current AQP practice. 

6. This request only impacts fleets new to American Airlines. While pilots working on 

incumbent fleets may take 36 months to have two evaluations, this is not true for pilots on 

the new fleets. All pilots will be new to these 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 Continuing Qualification evaluations. 
5 | Page , American Airline Petition for Grant of Exemption (FAR 121.915) 

PUBLIC INTEREST: 

• Granting of this petition for exemption 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 Airmen, Schedulers, and Administrators to a 

standard program, for all American Airlines fleets. 

3. American Airlines to continue providing our pilots 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 training to American Airlines pilots, following a 

proven and effective program, with a commensurate 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 require 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, within the regulation, American Airlines wants 

to continue to invest in this comprehensive program 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 shown 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 higher 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 Grant 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.com 
7 | Page , American Airline Petition for Grant 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 for 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, including new fleets, without waiting 24 calendar 

months to petition the FAA to exceed the 24 month cycle, with two Continuing Qualification 

evaluations.