U.S. Department ofTransportation

Docket Operations, M-30

West Building ground floor

Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Dear Sirs:

Atlantic Southeast Airlines Inc. and /or ExpressJet Airlines Inc., holder of Air Carrier

Operating Certificate ASOAO29B, requests an extension ofthe approval to utilize Exemption 7135 to 14 CFR part 121.434(1)(c)(ii). The original approval to utilize Exemption 7135 was issued March 7, 2000 and extended in March 2004, March 2006, March 2008 and again in March 2010.

We are requesting to extend the approval based on the original conditional requirements of Exemption 7135 as amended.

The petition for exemption is attached.

Sincerely,

Charles S. Tuft

VP Flight Operations

/attachment

Live Connected. 990 Toffie Terrace AUanta, GA 30354-1 363 p :404.856.1000 404.856.1203 flyasa.com
SUBJECT: PETITION FOR GRANT OF EXEMPTION

Pursuant to Section 11.25 of the Federal Aviation Regulation (FAR), Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc., holder of Operating Certificate ASOAO29B, hereby petitions the Federal Aviation Administration (FAA) for the renewal of the exemption from FAR Section 121 .434(c)(1)(ii) to the extent necessary to permit ASA to observe the pilots in qualification observation as required by the aforementioned rule. This exemption renewal is requested in order for Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc. to continue to perform this required observation as allowed by the previously approved Exemption 7135 and 7135E amended, which expires March 31, 2012.

NATURE AND EXTENT OF RELIEF

The exemption will allow a FAA authorized Check Airmen, in the employ of Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc., to conduct the required observation when a FAA inspector is unavailable to conduct the observation, as required by the below regulation:

FAR 121.434(c)(1)(ii)

Pilot crewmembers must acquire operating experience and operating cycles as follows: (1) A pilot in command must -

(I) Perform the duties of a pilot in command under the supervision of a check pilot; and (ii)

121.424,

In addition,

be observed

if a qualifying pilot in command is completing initial or upgrade training specified in § in the performance of prescribed duties by an FAA inspector during at least one flight leg which includes a takeoff and landing. During the time that a qualifying pilot in command is acquiring the operating experience in paragraphs (c)(I) (i) and (ii) of this section, a check pilot who is also serving as the pilot in command must occupy a pilot station. However, in the case of a transitioning pilot in command the check pilot serving as pilot in command may occupy the observer’s seat, if the transitioning pilot has made at least two takeoffs and landings in the type airplane used, and has satisfactorily demonstrated to the check pilot that he is qualified to perform the duties of a pilot in command of that type of airplane.

This relief, to conduct the required observations as requested, will be implemented under previously approved guidelines which are:

1. Each check airman performing the duties otherwise appropriate to an FAA inspector, under this exemption, must:

a. Be an employee of Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc.;

b. Be qualified and current in the duties of the PlC in the aircraft being operated;

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airman to be used under this exemption before this use occurs.

3. Before each observation conducted under this exemption, Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc. must contact its P01 or the P01’s designated representative and obtain approval for the observation, thus reserving first right of refusal to the FAA.

4. The check airman observing the qualifying pilot must be other than the check airman conducting the operating experience flight.

5. The check airman observing the flight may not previously have conducted any operating experience flight during the current, initial, or upgrade training of the qualifying PlC.

6. The qualifying PlC candidate must be observed performing the duties of a PlC during a complete flight leg, including flight deck preparation, before starting engines checklist, taxi, takeoff, all other flight phases, landing, taxi and securing checklist.

7. Each operation conducted under this exemption must be recorded in Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc. approved training records.

8. No observations may be conducted under this exemption until the qualifying PIG has completed no less than 10 hours of supervised CE and accomplished no fewer than two takeoffs and landings.

9. Atlantic Southeast Airlines Inc. and for ExpressJet Airlines Inc. must maintain the records necessary to demonstrate compliance with the conditions and limitations of this exemption.

PUBLIC INTEREST

Airlines

Granting of this petition for exemption to permit an Atlantic Southeast Airlines Inc. and br ExpressJet Inc. Check Airman to conduct the required observation as previously outlined is in the public

timely

interest

manner.

for reasons

With

of safety, economics and being able to complete the requirements of the FAR in a

always

the current staffing of the Certificate holding District Office (CHDO), the FAA is not

br ExpressJet

available to conduct the observation as scheduled. Allowing Atlantic Southeast Airlines Inc. and Airlines Inc. to conduct the observation, when the FAA is unavailable, will allow for the

given

completion of this pilot qualification element in a timely fashion, thereby reinforcing the training guidance to the pilots in training.

EQUIVALENT LEVEL OF SAFETY

Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc. believes that this proposal for the

present

requested exemption renewal, will not merely provide an equivalent level of safety to operations under this regulation, but will in fact, enhance safety. Operations under the exemption requested herein should enhance total air safety due to the observations being conducting by Atlantic Southeast Airlines

2
Check

Airman to evaluate the training and checking effort where experience has shown it to be most valuable.

EXCEPTIONS TO PUBLICATION OF SUMMARY OF PETITION FOR EXEMPTION

In accordance with the provisions of FAR 11 .27(jX3)(i) (Exceptions to Publication of Summary of Petition for Exemption), Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc. requests that a finding of good cause be made for waiving publication in the Federal Register, since similar exemptions and waivers for this purpose have been granted to other Part 121 air carriers electing to conduct the observations required by FAR 121.434(1)(c)(ii). The justifications and supporting arguments are nearly identical to those presented by Atlantic Southeast Airlines Inc. and for ExpressJet Airlines Inc.. In view of the numerous opportunities to comment in the past, and the analysis previously done by FAA in the related industry

ExpressJet

cases, which ultimately resulted in grants of exemption, Atlantic Southeast Airlines Inc. and br Airlines Inc. requests that the publication and comment period be waived.

SUMMARY

As required by FAR Section 11.25(d), a summary of the petition is as follows:

Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc. requests an exemption from FAR 121 .434(1)(c)(ii), (FAA observation), to the extent necessary to permit authorized Atlantic Southeast Airlines Inc. and br ExpressJet Airlines Inc. Check Airmen to conduct the required pilot observation when a FAA inspector is unavailable.

Sincerely,

Charles S. Tu

Vice President, Flight Operations

cc: Inspector Bill Smith

Atlantic Southeast Airlines Inc. and for ExpressJet Airlines Inc. Principal Operations Inspector

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