AMERICAN AIRLINES FLIGHT ACADEMY, P.O. BOX 619617, DALLAS/FORT WORTH AIRPORT, TEXAS 75261-9617

 

 January 11, 2010 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

1200 New Jersey Ave. S.E. 

Room W12-140 

Washington, DC 20590 

Sent to Web Site: http://www.regulations.gov/

 

SUBJECT: Petition to Combine American Airlines’ Exemptions No. 8660 and No. 9570 

Ladies/Gentlemen: 

American Airlines, Inc. currently holds Exemption No. 8660 (Regulatory Docket No. FAA-2005-

22820) and Exemption No. 9570 (Regulatory Docket No. FAA-2006-25049). Both exemptions 

are very similar and provide relief from 14 CFR 121.619 by allowing American Airlines to 

dispatch aircraft to domestic airports without designating an alternate for the destination airport 

where for at least 1 hour before and 1 hour after the estimated time of arrival at the destination 

airport the appropriate weather reports or forecasts, or any combination of them, indicate the 

ceiling will be at least 1,000 feet above the airport elevation and visibility will be at least: 

 2 statute miles with an operable CAT II or CAT III ILS approach (per Exemption No. 

8660) or 

 3 statute miles with an operable CAT I ILS approach with published minimums of 200 

feet and RVR of 2,000 feet or lower (per Exemption No. 9570). 

Authorization for both exemptions is subject to American Airlines’ receipt of accompanying 

Operations Specification (OpSpec) C355, and compliance with ten Conditions and Limitations. 

The Conditions and Limitations are specified separately in each exemption, but nearly identical 

between exemptions. Note the only differences between Exemptions No. 8660 and 9570 are the 

visibility and accompanying approach types required at destination.

Exemption No. 8660 was originally issued on November 15, 2005 and has been in use at 

American Airlines since February 26, 2006. Exemption No. 8660 was amended by Exemptions 

No. 8660A, 8660B, and 8660C on October 13, 2006, November 29, 2007, and March 6, 2008, 

respectively. Exemptions No. 8660A and 8660B simply extended the expiration dates to 

January 31, 2008 and January 31, 2010, respectively. Exemption No. 8660C was initiated by 

the FAA and added to and clarified the Conditions and Limitations, but left the expiration date of 

January 31, 2010 unchanged. 

Exemption No. 9570 was originally issued to American Airlines on December 11, 2007 and has 

been in use since December 17, 2007. Exemption No. 9570 was amended by Exemptions No. 

9570A on September 11, 2008 and most recently by 9570B on December 24, 2009. Exemption 

No. 9570A amended the original Exemption by correcting an administrative error. Exemption 

No. 9570B extended the expiration date to December 31, 2011 with no other modifications. 

 

Since their implementation, American has successfully operated approximately 2,092 flights 

under Exemption No. 8660 and approximately 1,090 flights under Exemption No. 9570. All 
U.S. Department of Transportation 

Petition to Combine Exemptions No. 8660 & 9570 

January 11, 2010 

Page 2 of 2 

flights under both exemptions have been operated with no known compromise of safety, no 

weather diversions, no special ATC handling, and no declaration of minimum fuel or emergency 

fuel as a result of use of either exemption. 

Exemption No. 9570 was recently renewed on December 24, 2009 as Exemption No. 9570B 

expiring December 31, 2011. Because Exemption No. 8660C expires January 31, 2010, in a 

letter dated November 6, 2009 American petitioned for renewal of Exemption No. 8660, as 

amended, including the current Conditions and Limitations, with no modifications. 

However, since Exemptions No. 8660 and 9570 are so similar, American proposes the 

provisions of both exemptions be combined into one exemption. If the FAA agrees, American 

requests to withdraw our petition for renewal of Exemption No. 8660 dated November 6, 2009 

and requests a single new or amended exemption be issued that includes the provisions of both 

Exemptions No. 8660 and 9570. 

The conditions and circumstances with regard to public interest and safety which warranted the 

original Exemptions No. 8660 and 9570 continue to exist. Justification for continuation of 

Exemption No. 8660 is the same as for the original Petition for Exemption No. 8660 dated 

October 20, 2005, and amended Petitions for Exemptions No. 8660A and 8660B dated June 19, 

2006 and October 15, 2007, respectively. Similarly, justification for continuation of Exemption 

No. 9570 is the same as for the original Petition for Exemption No. 9570 dated June 8, 2006, 

and amended Petitions for Exemptions No. 9570A and 9570B dated February 7, 2008 and 

October 9, 2009, respectively. 

In accordance with the provisions of 14 CFR 11.27 (j)(3)(i), Exceptions of Publication of 

Summary of Petition for Exemption, American Airlines requests that a finding of good 

cause be made for waiving publication in the Federal Register. Since similar exemptions 

have been granted to other Part 121 Air Carriers, no precedents will be set by granting 

the requested relief. Therefore, American requests that the publication and comment 

period be waived. 

A summary of this petition is attached as required by 14 CFR 11.25. Your consideration and 

approval of this request is appreciated. Please advise if you require additional information in 

order to evaluate or act on this petition. 

 Sincerely, 

 OJ Treadway 

 Manager 

 Flight Operations Support 

 817-967-5157 

oj.treadway@aa.com

One Attachment: Summary of Petition 

cc: Captain Bart Roberts (American Airlines Managing Director Flight Operations) 

 Mr. Robert E. Talmadge (FAA Principal Operations Inspector American Airlines)
Petition to Combine American Airlines’ Exemptions No. 8660 and No. 9570 

Attachment 

January 11, 2010 

SUMMARY OF AMERICAN AIRLINES PETITION 

Petitioner: American Airlines, Inc. (AAL) 

Regulations Affected: 14 CFR 121.619 

Description of Relief Sought: American Airlines requests to combine the provisions of 

existing Exemption No. 8660 (Docket No. FAA-2005-

22820) and Exemption No. 9570 (Docket No. FAA2006-25049) into one amended or new exemption. 

Exemptions No. 8660 and 9570 provide relief from 14 

CFR 121.619 by allowing American Airlines to dispatch 

aircraft to domestic airports without designating an 

alternate for the destination airport where for at least 

1 hour before and 1 hour after the estimated time of 

arrival at the destination airport the appropriate weather 

reports or forecasts, or any combination of them, 

indicate the ceiling will be at least 1,000 feet above the 

airport elevation and visibility will be at least 2 statute 

miles (per Exemption No. 8660) or 3 statute miles (per 

Exemption No. 9570). Authorization for both 

Exemptions No. 8660 and 9570 are subject to the 

Conditions and Limitations specified in each Exemption. 

Exemption No. 9570 was recently renewed on 

December 24, 2009 and Exemption No. 8660 is due to 

expire on January 31, 2010.