AFS

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- E Exemption No. 10882

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591

In the matter of the petition of

AMERIC AN 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 beha lf 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 a n 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 pert inent 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 th at 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 n early 20 years of experience utilizing Advanced Qualification Programs and nearly 12 years of experience utilizing a 36 month2

continuing qualification cycle in all of their other fleets. The requested 36 month continuing qualification cycle provides for t raining opportunities at 9 month intervals and would accomplish an initial c ontinuing q ualification 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 c ontinuing qualification cycle would

make this c ontinuing 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 adver se effect on safety and would be in the public interest because t his program provides pilots more training, more frequently. Training programs conducted under p art 121, Appendix H require s a c aptain to receive training and a proficiency c heck each year (as little as two simulator sessions per 12 months) and requires a f irst o fficer to receive training and a p roficiency c heck

e very 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 month s 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 commensu rate 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 t he granting and use of this exemption woul d have no a dverse 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 tr aining 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 cy cle 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. Add itionally it has been

determined that the im plementation of an alternate 24 month continuing qualification cycle may induce additional risk due to the complication of alternate training cycles,3

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 authorit y 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