AFS-13-191-E

Exemption No. 10882

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

 

In the matter of the petition of 

 

AMERICAN AIRLINES Regulatory Docket No. FAA-2013-0078

 

for an exemption from § 121.915(d) 

of Title 14, Code of 

Federal Regulations 

 

GRANT OF EXEMPTION

 By letter dated January 24, 2013, Mr. Christopher K. Broom, Managing Director Flight 

Training, American Airlines, PO Box 619617, MD 863 GSWFA, DFW Airport, TX 75261-

9617 petitioned the Federal Aviation Administration (FAA) on behalf of American Airlines

for an exemption from § 121.915(d) of Title 14, Code of Federal Regulations (14 CFR). The 

proposed exemption, if granted, would provide relief from the requirement that an initial 

continuing qualification cycle approved for an AQP must not exceed 24 calendar months in 

duration. This will allow for an initial continuing qualification cycle of 36 calendar months in 

duration.

The petitioner requests relief from the following regulation:

Section 14 CFR § 121.915(d) prescribes, in pertinent part, that 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.

The petitioner supports its request with the following information:

The petitioner states that they have nearly 20 years of experience utilizing Advanced 

Qualification Programs and nearly 12 years of experience utilizing a 36 month 
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continuing qualification cycle in all of their other fleets. The requested 36 month 

continuing qualification cycle provides for training opportunities at 9 month intervals 

and would accomplish an initial continuing qualification evaluation after only 9 months 

in lieu of the 12 month evaluation required with a 24 month continuing qualification 

cycle. Additionally utilization of a 36 month continuing qualification cycle would 

make this continuing qualification cycle consistent with all other fleets thus reducing 

risks associated with the application of non-standardized cycles. 

The petitioner also states that there would be no adverse effect on safety and would be 

in the public interest because this program provides pilots more training, more 

frequently. Training programs conducted under part 121, Appendix H requires a captain 

to receive training and a proficiency check each year (as little as two simulator sessions 

per 12 months) and requires a first officer to receive training and a proficiency check 

every 24 months (as little as two simulator sessions per 24 months). 

Under § 121.441(a), a proficiency check for a pilot in command is required within the 

preceding 12 months and within the preceding 24 months for all other pilots. The 

petitioner’s program provides a minimum of two simulator sessions every 9 months, in 

a crew environment, thereby increasing the level of safety commensurate with the 

additional training provided. Additionally, all pilots including pilot in command and 

second in command, receive a Validation (Maneuvers Validation) or Evaluation (Line 

Operational Evaluation) every 9 months. A Maneuvers Validation is almost identical to 

a Proficiency Check.

A summary of this petition was published in the Federal Register on June 19, 2013 

(78 FR 36816). No comments were received.

The FAA's analysis is as follows:

The FAA finds that the granting and use of this exemption would have no adverse 

effect on safety because the petitioner’s current and long established 36 month 

continuing qualification cycle has demonstrated that it is a highly effective 

methodology to ensure pilot proficiency. 

The petitioner currently provides training data to the Pilot Proficiency Database for all 

fleet training and will continue to submit data for any continuing qualification programs 

to include new implementations such as this. This data is analyzed quarterly and 

annually to ensure training cycle lengths are appropriate. 

The FAA agrees that under the petitioner’s approved AQP the current 36 month 

continuing qualification cycle provides sufficient requirements for training and 

evaluation in the petitioner’s advanced simulation equipment. Additionally it has been 

determined that the implementation of an alternate 24 month continuing qualification 

cycle may induce additional risk due to the complication of alternate training cycles, 
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therefore it would be reasonable and within the public’s best interest to allow the 

petitioner to initially implement a 36 month continuing qualification cycle.

The FAA’s Decision

 In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. §§ 106 (f), 40113 and 44701, 

delegated to me by the Administrator, American Airlines is granted an exemption from 

14 CFR § 121.915(d), to the extent necessary to allow American Airlines to initially 

implement a 36 month continuing qualification cycle subject to the conditions and limitations 

listed below.

Conditions and Limitations

1. The petitioner must continue to comply with all elements of their approved AQP.

This exemption terminates on October 31, 2015, unless sooner superseded or rescinded.

Issued in Washington, DC, on October 25, 2013

/s/

Michael J. Zenkovich

Deputy Director, Flight Standards Service