### 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 f rom 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 complete d October 1 st , 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 sole ly 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 s pecifications in order to continue operations with this model of B767 until June 1 st , 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 1 st, 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 operatio ns 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 req uirements of 14 CFR §121.291(b)(1) and (d). Based on the detail provided herein, we believe an exemption fromthese 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 a nd 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 re quired 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 operat ion 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 succe ssfully 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 elemen ts 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 airp lane 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.

 Recurren t 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 d rill 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, m inimum 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 ame nding 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 B 767. 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 Jul y 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 conducti ng 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 respe ctfully 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 pa rtial 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 removepersonnel 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 a n 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)