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' america AIRLINES February 13, 2017 Mr. JohnS. Duncan Director, Flight Standards Service Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 HORIZON

R Re: Petition of Virgin America Inc. for Extension of Exemption No. 10102B (Regulatory Docket No. FAA-2010-0631) Dear Mr. Duncan, Pursuant to14 C.F.R.

§ 11.61, Virgin America Inc. ("Virgin America"),

aPart 121 operator, hereby requests that the Federal Aviation Administration ("FAA") extend Exemption No. 101 02B, most recently granted onJune 18, 2014 and issued in the above-captioned docket (copy enclosed),
asmore fully described herein. Exemption No. 10102B, as issued, provides relief from 14 C.F.R.

§ 121.434(c)(l)(ii)

toallow Virgin America tosubstitute

a qualified and authorized check airman oraircrew program designee for anFAA inspector to observe

a qualifying pilot in command ("PIC") who is completing initial or upgrade training specified in 14 C.F.R.

§ 121.424, during atleast one flight leg that includes

atakeoff and landing. Exemption No. 101 02B, by its terms, expires on July 31, 2017. Virgin America respectfully requeststhat anyextension granted by the FAA in responsetothis petition be for a period of notless than two years. In supportof this petition, Virgin America statesasfollows: 1. The FAA determined,

in its original decision granting Exemption No. 10102 (dated July 22, 2010), that the circumstances presented by Virgin America weresimilar in all material respectstoa previous exemption granted by the FAA, specifically Exemption No. 6473, asamended. The FAA found that the reasons for issuing Exemption No. 6473 also applied tothe situation presented by Virgin America, and that "permitting alimited number of qualified and authorized check airmen toconduct certain PIC observations would benefit the public by reducing unnecessarycoststhat mayinfluence the price of services tothe public.
It would also improve the airline's ability to provide on-time, dependable air service." Exemption No. 10102 at1-2. Importantly, Exemption No. 10102 and the extension last granted to Virgin America pursuant
to Exemption No. 10102B wereissued subject to conditions and limitations setforth in the exemptions. 2. In extending and amending the exemption and granting Exemption No. 10102B, the FAA determined that
the justification for the issuance of the exemption remained valid and wasin the public interest. 3. Virgin America's reasonsand need for the grantof this requested relief remain the same today as when the FAA granted Exemption Nos. 10102, 10102A, and 10102B and fully supportanextension for a further two-year period. Virgin America will continue to expand its operations overthe nexttwo years,and anticipates upgrading additional captains this year,with newPICs completing training overthe nexttwo years. 4. An extension ofExemption No. 10102B would:a) be wholly consistent with previous exemptions granted in similar circumstances; b) allow the FAA greater flexibility and better useof its inspector force by focusing on higher priority safety functions; c) allow the useof qualified pilots immediately after completing operating experience; d) allow significantly increased useof qualified pilots and improve Virgin America's ability to provide dependable, on-time air service tothe public; e) reduce the unnecessarycostof wagesand lost productivity for those qualified pilots awaiting FAA observation; and f) provide the traveling public greater accessto Virgin America's well-received, low-cost service ata paceconsistent with its planned expansion of operations; allow full utilization of Virgin America's fleet by ensuring adequate qualified pilots; and allow increased service to previously underserved markets

. 5 .Grant of this requested relief to Virgin America will notreduce the level of safety provided by the applicable regulation,

at14 C

.F.R.
§ 121.434(c)(1)(ii),

asthe Administrator has previously determined

in similar requestsfor relief, including Exemption No. 10102B issued to Virgin America. The Virgin America check airman oraircrew program designee will only conduct

aPIC observation

in place of anFAA inspector when: a) the FAA preapprovesthat substitution for each observation
of a qualifying PIC candidate, thus reserving first right of refusal tothe FAA in each case; b) the qualifying PIC candidate has completed noless than 10 hours of supervised operating experience ("OE") and accomplished
nofewer 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. In addition

,each Virgin America check airman oraircrew program designee conducting

aPIC observation

in place of anFAA inspector must: a) be approved by the FAA toconduct the observation; b ) have served asacheck airman oraircrew programdes
i gneefor Virgin America for no
l essthan 6 months; and c) not supervise the OE orconduct the initial line check for the qualifying PIC candidate being observed

. 6. Virgin America will also maintain student, check airman, and aircrew program designee records that demonstrate compliance with the conditions and limitations of this exemption. 7. Virgin America submits that the requested extension of Exemption No. 10102B
is not controversial.

A summaryofthe request made herein is attached,
as required under 14 C

.F.R.
§ 11.81. However, Virgin America submits that good causeexists for not publishing

a summaryof this petition in theFederal Register,
asthe requested extension of the exemption

is not precedential, and any delay in acting on this petition would be detrimental
to Virgin America. WHEREFORE,
for the foregoing reasons, Virgin America Inc. respectfully requests that the FAA extend Exemption No. 10102B for a period of notless than two years,asdescribed more fully herein, and grant such other oradditional relief asit deems consistent with this requestand the public interest. If youhave anyfurther questions, please do nothesitate tocontactmeat 206-392-5453

or by e-mail at J eremy.Ross@alaskaair.com. Very best regards, Jeremy Ross Associate General Counsel Alaska Airlines

I Virgin America

I Horizon Air AttachmentAttachment Docket No. FAA-2010-0631 February 13, 2017 SUMMARY OF PETITION Petitioner: Virgin America Inc. Regulations affected:

14 C.P.R. 121.434(c)(1)(ii) Description
of Relief Sought: Virgin America Inc. (Virgin America) petitions for an extension of Exemption No. 10102B. The exemption permits Virgin America
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 14 C.F .R. § 121.424, during at least one flight leg that includes

a takeoff and landing.u.s. Deportment of Transportation Federal Aviation Administration June 18, 2014 Ms. Barbara Russell Associate General Counsel Virgin America, lnc. 555 Airport Boulevard, 5th Floor Burlingame, CA 94010 Dear Ms. Russell: Exemption No. 10102B
800 Independence Ave

..S W Washington. DC

.20591 Regulatory Docket No. FAA-2010-0631 This letter is toinform youthat wehave granted your petition toextend Exemption No. 10102, asamended.

It explains the basis for our decision, descnbes
its effect, and lists the conditions and limitations. The Basis for Our Decision By letter dated April3, 2014, you petitioned the Federal Aviation Administration (FAA) onbehalf of Virgin America, Inc. (Virgin America) for anextension ofExemption No. 10102, asamended. That exemption from
§ 121.434(

c )(1 )(ii) of Title 14, Code ofF ederal Regulations (14 CFR) allows Virgin America
tosubstitute

a qualified and authorized check ainnan oraircrew program designee for anFAA inspector
toobserve

a qualifYing pilot in command (PIC) who is completing initial or upgrade training specified
in § 121.424 during atleast one flight leg that includes

atakeoff and a landing. 1n your petition, youindicate that there has been no change
in the conditions and reasonsrelative to public interest and safety that werethe basis for granting the original exemption. The FAA has determined that good causeexists for not publishing

a summaryof the petition in the Federal Register because the requested extension of the exemption would notseta precedent

,and any delay in acting onthis petition would be detrimental

to Virgin America. AFS-14-240-EOur Decision The FAA has detennined that the justification for the issuance ofExemption No. 10102, as amended, remains valid with respectto this exemption and is in the public interest. Therefore, under the authority provided by 49 U.S.C. §§ 106(f), 40113, and 44701, which the FAA Administrator has delegated
to me, Virgin America, Inc. is granted anextension
toits exemption from 14 CFR 121.434(

c )(1 )(ii) that allows Virgin America
tosubstitute

a qualified and authorized check airman or aircrew program designee for anFAA inspector
toobserve

a qualifYing PIC who is completing initial or upgrade training specified in§ 121.424 dtrring atleast one flight leg that includes

atakeoff and a landing, subject tothe following conditions and limitations. Conditions and Limitations 1. A Virgin America check airman oraircrew program designee mayconduct

a PIC observation

in place of anFAA inspector when-- a.The Administrator preapprovesthat substitution for each observation
of a qualifYing PIC candidate, thus reserving first right of refusal tothe FAA in each case. Virgin America, therefore, mustcontactan appropriate FAA office, in each instance, before substituting that check airman oraircrew program designee; b. The qualifYing PIC candidate has completed
noless than 10 hotrrs of supervised operating experience (OE) and accomplished

norewerthan two takeo:ffi; 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 seeming checklist. 2. Each Virgin America check airman oraircrew program designee conducting

aPIC observation

in place of anFAA inspector musta.Be approved by the Administrator

toconduct the observation; b. Ha veserved asacheck airman oraircrew program designee for Virgin America for noless than 6 months; and c.Not supervise the OE orconduct the initial line check for the qualifYing PIC candidate being observed. 3 .Virgin America mustmaintain student

,check airman, and aircrew program designee records that demonstrat

e compliance with the conditions and limitations of this exemption

. 23 Our decision extends the termination date of July 31, 2017, unless sooner superseded
or rescinded. Sincerely, /S/ John Barbagallo Acting Deputy Director, Flight Standards Service