By Electronic Submission

Expedited Treatment Requested

U.S. Department of Transportation

Docket Management System – Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave, SE

Washington, D.C. 20590

Re: Petition of United Airlines, Inc. for an exemption from 14 CFR §121.291(b)(1) and (d)

Dear Sir or Madam:

Pursuant to 14 CFR Part 11, United Airlines is requesting exemption relief from the requirements of 14 

CFR §121.291(b)(1) and (d) in order to continue operating the Boeing B767-300 without conducting a 

partial evacuation demonstration and ditching demonstration. In addition, United requests the FAA 

issue the requested exemption no later than April 1, 2012 to avoid unnecessary operational burdens for 

United and the FAA, as well as avoiding disruptions in service by ensuring continued operation of the 

B767-300. The requested exemption is in the interest of the public and, if granted, provides a level of 

safety equivalent to that achieved through an essentially redundant partial demonstration.

Background

Continental Airlines, Inc. and United Airlines, Inc. became subsidiary carriers owned by United 

Continental Holdings, Inc. following a merger completed October 1st, 2010. Continental and United 

received a single operating certificate November 30, 2011 and now operate as a single carrier under 

the name United Airlines and operating certificate CALA014A. Certificate CALA014A was previously 

assigned solely to Continental Airlines. Prior to the issuance of a single operating certificate, 

Continental Airlines was granted Exemption No. 10385 on November 8, 2011. In part, Exemption 

10385 permits the new United Airlines to add the B767-300 to its operating specifications in order to 

continue operations with this model of B767 until June 1st, 2012 without conducting a partial evacuation 

demonstration and ditching demonstration. Under the exemption, the new United is required to 

complete partial evacuation and ditching drills for the airplane no later than June 1st, 2012 to comply 

with 14 CFR §121.291(b)(1) and (d), Demonstration of Emergency Evacuation Procedures. 

Continental has operated the -400 and -200 models of the B767 airplane since 2000; legacy United has 

operated the -300 model of the B767 since 1991. 

Exemption Request

14 CFR §121.291(b)(1) states, in part, “each certificate holder conducting operations with a seating 

capacity of more than 44 passengers must conduct a partial demonstration of emergency evacuation 

procedures ... upon initial introduction of a type and model of airplane into passenger-carrying 

operations.” In addition, 14 CFR §121.291(d) requires, in part, each certificate holder operating one or 

more landplanes in extended overwater operations must show by simulated ditching that it has the 

ability to efficiently carry out its ditching procedures. United is requesting relief from the requirements 

of 14 CFR §121.291(b)(1) and (d). Based on the detail provided herein, we believe an exemption from 
these requirements is warranted, supported by recent precedent, in the interest of the public, and would 

provide an equivalent level of safety.

Support

United submits the following information in support of its request for an exemption:

No New Equipment or Procedures for Flight Attendants

 Operation of the exits and flight attendant evacuation procedures are identical between the legacy 

carriers and across all three models of the B767.

 The -300 model and -200 model have identical exits and an identical exit configuration, save for 

an additional set of overwing exits on the -300:

 Both models are equipped with four (4) Type A floor-level exits in the same locations

 The -300 has four (4) Type III exits (two left and two right) over the wings; the

-200 has two (2) identical Type III exits (one left and one right) in the same location. 

 The -400 model has six (6) identical Type A floor-level exits, four in the same locations as the -

300 and -200, as well as two forward of the wing. Additionally, there are two (2) Type I exits aft of 

the wing.

 For United Airlines, required crew for the -200 is four (4) flight attendants; five (5) flight attendants 

are required for the -300; six (6) flight attendants are required for the -400.

 While the fifth flight attendant on the -300 is responsible for commanding the evacuation at the 

overwing exits, all flight attendants qualified on the B767 are trained in the operation of the 

overwing exits and all flight attendants qualified on the A319/320, B737, B757 and/or B767 are 

trained in procedures for commanding evacuations at overwing exits.

 The type-rating as well as the training, procedures, responsibilities and actions for pilots in an 

emergency are identical across all three models.

Prior Successful Evacuation Demonstrations

 Legacy Continental successfully completed a partial evacuation and ditching demonstration for 

the B767-400 airplane with a required crew of six flight attendants on the CALA014A certificate in 

September of 2000. 

 Following approval of the -400 model, the CALA CMO approved the -200 model with a 

required crew of four (4) flight attendants for operations through analysis on the 

CALA014A certificate on October 26, 2000. The approval was granted in consultation 

with the Regional Flight Standards Division (ASW-200) and FAA Flight Standards 

Division (AFS-200). The -200 and -400 models have remained in operation since their 

initial approval.

 Legacy United successfully completed a partial evacuation and ditching demonstration for the 

B767-300 with a required crew of five (5) in May of 1991 under certificate UALA011A. The -300 

has been in operation since that time, including current operation under the CALA014A certificate.

 Emergency procedures for flight attendants were harmonized April 1st, 2011 and incorporated in 

the Flight Attendant Operations Manual (FAOM), recurrent training and transition training on that 

date. The harmonized emergency evacuation procedures have since been validated in two live 

events: On April 4, 2011, legacy United flight attendants successfully evacuated an A320 with 104 

customers on board following an emergency landing; on September 14, 2011, legacy United flight 

attendants successfully conducted an unplanned land evacuation on a 757-200 with 181 

customers on board. 

Systems Evaluation

 In granting Exemption 10385 the FAA states, in part, “...the provisions in 14 CFR §121.291(b)(1) 

and (d) take a „systems approach‟ to the air carrier‟s partial evacuation demonstration. The ... 
demonstration demonstrates the efficacy of the integrated elements of each certificate holder‟s 

system.” In the case of the B767, both legacy carriers have successfully completed partial 

evacuation demonstrations on the B767, and both have a long and documented history of 

supporting, maintaining and operating the airplane safely.

 Both legacy carriers are currently operating the airplane under the same safety and operating 

policies and procedures.

 Maintenance processes and procedures related to emergency equipment and aircraft handling 

are predicated upon fleet-specific Aircraft Maintenance Manual, Illustrated Parts Catalog, and 

related General Maintenance Manual processes. Associated Technicians have received general 

integration related training and have been qualified and authorized on applicable fleet types.

 Recurrent training curriculum for all flight attendants incorporates the harmonized safety and 

emergency procedures. Since the first day of harmonized procedures, training included, and 

continues to include, at least one hands-on, unplanned emergency evacuation drill for both 

groups. 

 Mandatory annual computer-based training (CBT) for all flight attendants has included, and 

continues to include, a review of all three models of B767, including systems review, cabin and 

exit configurations, preflight of all exits, minimum crew requirements, emergency responsibilities, 

and preferred routes of escape during different evacuation scenarios.

 B767 transition training and requalification training curricula is identical for all flight attendants and 

includes all three models. 

Summary

The -300 is essentially a slightly lengthened version of the -200 and classified by Boeing as a new 

model, despite the high commonality between the two in exits, systems and procedures. The intent of 

§121.291, as stated in the Final Rule amending the regulation in 1982, is to assure “the FAA and the 

traveling public that a Part 121 certificate holder‟s flight attendant training program provides a 

successful evacuation if an emergency occurs. The adequacy of the certificate holder‟s training 

program is reflected in the crew‟s performance during the demonstration.” As stated previously, both 

carriers‟ emergency procedures are identical for the B767, and both legacy carriers successfully 

completed partial evacuation and ditching drills on the B767. The only validation more effective than a 

staged drill is a real evacuation, and in this regard, not one but two successful evacuations in 2011, one 

planned and one unplanned, validated the efficacy of the harmonized procedures. Given this, granting 

the exemption is in line with the intent of the regulation and will not impact safety or the operation of the 

airplane. 

It is also important to note, precedent exists for the granting of this exemption request. The FAA 

granted Exemption No. 9901 in July of 2009 prior to a carrier adding the ERJ-190 to its operating 

specifications, in addition to the ERJ-170 and -175 airplanes already on the certificate. Exemption 

9901 allowed the carrier to add the -190 to its operations specifications without conducting a partial 

evacuation demonstration. 

Based on extensive safe and successful operating experience, commonality of equipment and 

procedures, common training programs, and prior successful partial demonstrations completed by both 

legacy carriers, we respectfully submit there is no benefit or enhancement to safety to be achieved by 

completing a redundant partial evacuation demonstration and ditching demonstration for the B767-300. 

This exemption is requested so United may focus efforts on completing the partial evacuation 

demonstrations on non-common make/model airplanes. Repeating the procedures on the B767-300 

does not provide benefit to the public as systems and procedures will have been adequately 

demonstrated previously. Conversely, requiring partial evacuation and ditching drills will remove 
personnel and equipment from service, working against the public‟s interest by disrupting the operation 

for our customers. Consequently, the granting of an exemption is in the public interest while 

maintaining an equivalent level of safety.

United requests the processing of its petition not be delayed for publication and comment in the Federal 

Register. Publication would cause unnecessary delay to our opportunity to implement the exemption, 

as well as revealing private corporate data contained in this petition.

Sincerely,

Michael Quiello

Vice President Corporate Safety

United Airlines

cc: F. Abbott 

S. Risoli 

W. Ganse 

P. Schenck

G. Beuker

J. Grossman (FAA)

B. Hedlund (FAA) 

J. Martin (FAA)