October 6, 2014

Docket FAA-2014-______

Docket Management Facility

US Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12-140

Washington, DC 20590

RE: Petition for Exemption

Dear Sir or Madam:

The Regional Airline Association (“RAA”), on behalf of its Part 121 member airlines,1 petitions 

pursuant to Sections 11.61 and 11.63 of the Federal Aviation Regulations (“FARs”) for an exemption 

from the regulatory requirements of FAR 61.3(a), 61.3(c), and 121.383 with regard to temporary 

confirmation of airmen certificates. 

14 CFR §§ 61.3(a) and (c) provide, in pertinent part, that no person may, within the United 

States, serve as a required flight crewmember of a U.S. civil aircraft unless he or she has in their 

personal possession a current pilot certificate issued under Part 61 and current medical certificate issued 

under Part 67. Section 121.383(a)(2) establishes similar requirements for airmen. If granted, the 

exemption would permit RAA Part 121 member airlines to establish special procedures that enable air 

carriers to issue to its flight crewmembers, on a temporary basis, confirmation of any required 

crewmember certificates based on information contained in the airline’s approved record system.

1 Air Wisconsin Airlines Corp., AirNet Systems Inc., Cape Air, Chautauqua Airlines, CommutAir, Compass Airlines, Empire 

Airlines, Endeavor Air, Envoy, Era Aviation, ExpressJet Airlines, GoJet Airlines, Great Lakes Aviation, Horizon Air, Island Air, 

Mesa Airlines, Piedmont Airlines, PSA Airlines, Republic Airlines, Seaborne Airlines, Shuttle America, Silver Airways, SkyWest 

Airlines, Inc., Trans States Airlines

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RAA has previously been granted such relief for its Part 135 member airlines under Exemption 

No. 5560, dated November 27, 1992 and amended by Exemption 5560A thru 5560I. The conditions and 

circumstances pertaining to safety and public interest, which warranted those grants of exemption, are 

identical for Part 121 airlines. In addition, FAA has granted a similar request for exemption (Exemption 

No. 5487) submitted by Airlines for America (“A4A”) on behalf of its member airlines. 

RAA previously petitioned for this relief for its Part 121 member airlines on June 18, 2012. In 

response to that request, the FAA renewed the existing Exemption 5560 which covers its Part 135 

member airlines, but did not extend the relief to RAA’s Part 121 member airlines. RAA subsequently 

filed a Petition for Reconsideration on September 12, 2012 that remains pending. However, with the 

filing of this petition for exemption, RAA wishes to withdraw the pending Petition for Reconsideration 

at Docket No. FAA-2000-8180. 

Granting this exemption will not compromise or adversely affect safety, rather it simply provides 

an equivalent alternative to an administrative aspect of the stated regulations. The approved procedures, 

encompassing the conditions and limitations established by previous grants, have been in use for over a 

decade with no known compromise of safety. It is also in the public interest as the exemption can 

prevent possible and unnecessary delays or cancellations of scheduled air service.

In accordance with FAR 11.87, RAA requests that the requirement for publication and comment 

be waived as this request is virtually identical to existing exemptions and therefore, does not set 

precedent. This petition for exemption is not a controversial issue and the reasons which form the basis 

for previous grants to Part 135 airlines and to similar Part 121 airlines are virtually identical. Although 

RAA requests waiver of publication, a summary of this petition is attached as required by FAR 11.81.

Please do not hesitate to contact me if you have any questions or require additional information. 

Respectfully submitted,

Stacey Bechdolt

Sr. Director, Safety & Technical Affairs

Regulatory Counsel

Regional Airline Association

2025 M Street, NW, Suite 800

Washington, DC 20036

202-367-1252

Bechdolt@raa.org

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SUMMARY

Petitioner: Regional Airline Association.

Sections of 14 CFR Affected:

14 CFR 61.3(a)

14 CFR 61.3(c)

14 CFR 121.383(a)(2)

Description of Relief Sought:

To permit RAA Part 121 member airlines to establish special procedures that enable an air carrier to 

issue to its flight crewmembers, on a temporary basis, confirmation of any required crewmember 

certificate based on information contained in the carrier’s approved record system.

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