December 20 , 2010

U.S. Department of Transportation Docket Management System

400 7 th Street SW, Plaza 401 Washington, DC 20591

- 0001

Re: Exemption No. 4901, as amended; Docket No. FAA

- 2001

- 9282

Ladies/Gentlemen:

In accordance with Title 14 of the Code of Federal Regulations (14CFR) § 11.61, the Air Transport Association of America, Inc. (ATA), on behalf of its member airlines 1 and other similarly situated Part 121 operators, operators of Part 63 flight engineer training schools, and Part 142 training center certificate holders, petitions the Administrator for an extension of Exemption No. 4901, Docket FAA

- 2001

- 9282. This exemption is sch eduled to expire on May 31, 2011

. Exemption No. 4901 provides relief, under certain conditions

and limitatio ns, from specific provisions of 14 CFR § 63.39 (b) (1) and (2) and § 121.425 (a)(2)(i) and (ii). Under flight engineer training programs approved under part 121, the qualification requirements of § 121.424 (a)(2)(i) and (ii) may be met concurrently with the certification requirements of § 63.39 (b)(1) and (2) in a single flight check. The exemption also grants relief to the extent necessary to permit applicants in training for that flight check to take the airplane preflight inspection portion of that fli ght check using an advanced pictorial means instead of an airplane, and normal procedures portion of that flight check in an approved flight simulation device. Also, all qualifying operators of part 63 flight engineer courses and all part 142 training cent er certificate holders conducting flight engineer training courses in accordance with part 63 requirements be granted an exemption from § 63.39 (b)(2) to the extent necessary to allow applicants who are training in preparation for the flight engineer pract ical test to take the normal procedures portion of that test in an approved flight simulation device.

_____________________________________________ 1/ Operator Members: ABX Inc., AirTran Airways

, Alaska Airlines, American Airlines, ASTAR Air Cargo, Atlas Air, Continental Airlines, Delta Air Lines, Evergreen International, Federal Express, Hawaiian Airlines, JetBlue Airways, Southwest Airlines, United Airlines, United Parcel Service Co. , US Airways.

Associate Members: Air Canada, Air Jamaica, and Mexicana.U.S. Department of Transportation

Docket Management System

Docket No. FAA

- 2001

- 9282

December 20 , 2010

Page Two

The conditions and circumstances, in regard to public interest and equivalent levels of safety, which warranted the original grant o f exemption, continue to exist. This petition does not seek to change the conditions and limitations of the current exemption. This exemption has been in use for over fifteen years with no known compromise of safety. The renewal of this exemption is not a controversial issue. For this reason, and the

reasons stated above, ATA requests that a finding of good cause be made for waiving publication in the Federal Register (14 CFR §11.87). Granting the requested relief will set no precedents. The existence of the exemption is well known and widely accepted. A summary of this petition as required by 14 CFR §11.81 is attached. If you have any questions or need additional information, please call me at (202) 626

- 4012.

Very truly yours,

AIR TRANSPORT ASSOCIATIO N

OF AMERICA

By: ______

/S/

____________________ Paul W. Railsback

Director

- Operations 1301 Pennsylvania Avenue, NW

Suite 1100 Washington, D.C. 20004

- 1707 (202) 626

- 4012 prailsback@airlines.orgAttachment

U.S. Department of Transportation Docket Management System

Docket No. FAA

- 2001

- 9282 December 15, 2010

Attachment

SUMMARY OF ATA PETITION

To renew Exemption 4901K which allows flight engineer training programs approved

under part 121, the qualification requirements of § 121.424 (a) (2) (i) and (ii) be met concurrently with the certification requirements of § 63.39 (b) (1) and (2) in a single flight check. Also allows Part 121 operators, Part 63 flight engineer schools and Par t 142 training center certificate holders to train and check flight engineer applicants in the performance of preflight inspections using approved pictorial displays instead of the airplane, and normal procedures portion of that flight check in an approved flight

simulation device.