## ~YEXPRESS

December 17, 2015 U.S. DepartmentofTransportation Docket Operations WestBuilding Ground Floor Room W12-140 1200NewJerseyAvenue, SE Washington, DC 20590 Dear Sirs: ExpressJetAirlines Inc., holderofAir Carrier Operating CertificateASOA029B, requests an extensionofthe approval to utilizeExemption 7135 to 14 CFRpart 121.434(1)(c)(ii). The original approvalto utilizeExemption 7135 was issuedMarch7, 2000 and extended in March2004, March2006, March2008, March 2010, March 2012 andMarch2014. We are requestingto extendthe approval basedonthe original conditionalrequirements ofExemption7135 as amended. Thepetitionfor exemptionis attached. Sincerely,



# ~ Brad Sheehan SeniorVicePresident, Operations /attachment

100 Hartsfield Centre Parkway, Suite 700 Atlanta, GA 30354 404.856.1000

### ExpressJet Airlines Inc. PETITION FOR EXEMPTION

U.S. Department ofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590
SUBJECT: PETITION FOR GRANT OF EXEMPTION 

### 12/17/2015

Pursuantto Section 11.61(b) ofthe Federal Aviation Regulation (FAR), ExpressJet Airlines Inc., holder of Operating Certificate ASOA029B, hereby petitions the Federal Aviation Administration (FAA) for the renewal ofthe exemption from FAR Section 121.434(c)(1)(ii) to the extent necessary to permit ExpressJet to observe the pilots in qualification observation as required by the aforementioned rule. This exemption renewal is requested in orderfor ExpressJet Airlines Inc. to continue to perform this required observation as allowed by the previously approved Exemption 7135 and 7135G amended, which expires March 31, 2016. NATURE AND EXTENT OF RELIEF The exemption will allow a FAA authorized CheckAirmen, in the employ of ExpressJetAirlines Inc., to conduct the required observation when a FAA inspector is unavailable to conduct the observation, as required bythe 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 ofa pilot in command underthe supervision of a check pilot; and (ii) In addition, if a qualifying pilot in command is completing initial or upgrade training specified in 

### § 121.424, be observed in the performance of prescribed duties by an FAA inspector during at least one flight leg which includes a takeoffand landing. During the time that a qualifying pilot in command is acquiring the operating experience in paragraphs (c)(1) (i) and (ii) ofthis section, a check pilot who is also serving as the pilot in command must occupy a pilot station. However, in the case ofa transitioning pilot in command the check pilot serving as pilot in command may occupy the observer's seat, ifthe transitioning pilot has made at least two takeoffs and landings in the type airplane used, and has satisfactorily demonstrated to the check pilotthat he is qualified to perform the duties of a pilot in command ofthattype ofairplane. 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, underthis exemption, must:
a. Be an employee of ExpressJetAirlines Inc.; b. Be qualified and current in the duties ofthe PIC in the aircraft being operated;


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### ExpressJet Airlines Inc. PETITION FOR EXEMPTION 12/17/2015
c. Be approved by the FAAAircrew Program Manager; and d. Have been employed by ExpressJet Airlines Inc. as a check airman for a minimum of6 months. 2. ExpressJetAirlines Inc. must submit and have approved by its FAA principal operations inspector (POl), in a letter of approval, the name ofeach check airman to be used underthis exemption before this use occurs. 3. Before each observation conducted underthis exemption, ExpressJetAirlines Inc. must contact its POl orthe POl's designated representative and obtain approval forthe observation, thus reserving first right of refusal to the FAA. 4. The check airman observing the qualifying pilot must be otherthan the check airman conducting the operating experience flight. 5. The check airman observing the flight may not previously have conducted anyoperating experience flight during the current, initial, or upgrade training ofthe qualifying PIC. 6. The qualifying PIC candidate must be observed performing the duties ofa PIC during a complete flight leg, including flight deck preparation, before starting engines checklist, taxi, takeoff, all otherflight phases, landing, taxi and securing checklist. 7. Each operation conducted underthis exemption must be recorded in ExpressJetAirlines Inc. approved training records. 8. No observations may be conducted underthis exemption until the qualifying PIC has completed no less than 10 hours ofsupervised OE and accomplished no fewer than two takeoffs and landings. 9. ExpressJet Airlines Inc. must maintain the records necessaryto demonstrate compliance with the conditions and limitations ofthis exemption. PUBLIC INTEREST Granting ofthis petition for exemption to permit an ExpressJetAirlines Inc. Check Airman to conduct the required observation as previously outlined is in the public interest for reasons ofsafety, economics and being able to complete the requirements ofthe FAR in a timely manner. With the current staffing ofthe Certificate holding District Office (CHDO), the FAA is not always available to conduct the observation as scheduled. Allowing ExpressJetAirlines Inc. to conduct the observation, when the FAA is unavailable, will allowforthe completion ofthis pilot qualification element in a timely fashion, thereby reinforcing the training guidance given to the pilots in training. EQUIVALENT LEVEL OF SAFETY ExpressJetAirlines Inc. believes that this proposal for the requested exemption renewal, will not merely provide an equivalent level ofsafetyto operations underthis present regulation, but will in fact, enhance safety. Operations underthe exemption requested herein should enhance total air safety due to the observations being conducting by ExpressJetAirlines Inc. will allow yet another review ofthe FAA


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### ExpressJet Airlines Inc. PETITION FOR EXEMPTION 12/17/2015 approved pilot training program. These additional observations will provide valuable feedback to enhance the quality ofthe FAA approved pilot training program. In summary, this exemption, in addition to supplementing the FAA staffing, will provide valuable information on the preparedness ofthe newlytrained pilots. This exemption, in addition to making available additional resources, will allow an ExpressJetAirlines Inc. Check Airman to evaluate the training and checking effortwhere experience has shown it to be most valuable. EXCEPTIONS TO PUBLICATION OF SUMMARY OF PETITION FOR EXEMPTION In accordance with the provisions of FAR §11.87(a) (Circumstances in which FAA may decide not to publish a petition for exemption), ExpressJet Airlines Inc. requests that a finding of good cause be made forwaiving publication in the Federal Register, since similar exemptions and waivers forthis 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 ExpressJet Airlines Inc. In view ofthe numerous opportunities to comment in the past, and the analysis previously done by FAA in the related industry cases, which ultimately resulted in grants of exemption, ExpressJet Airlines Inc. requests that the publication and comment period be waived. SUMMARY As required by FAR Section 11.81 (f), a summary ofthe petition is as follows: ExpressJetAirlines Inc. requests an exemption from FAR 121.434(1)(c)(ii), (FAA observation), to the extent necessary to permit authorized ExpressJetAirlines Inc. Check Airmen to conduct the required pilot observation when a FAA inspector is unavailable. Sincerely,

r eehan SeniorVice President, Operations
cc: Inspector Billy Smith ExpressJet Airlines Inc. Principal Operations Inspector



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