~YEXPRESS 

December 17, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Sirs: 

ExpressJet Airlines Inc., holder of Air Carrier Operating Certificate ASOA029B, requests 

an extension of the 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, March 2010, March 2012 and March 2014. 

We are requesting to extend the approval based on the original conditional requirements 

ofExemption 7135 as amended. 

The petition for exemption is attached. 

Sincerely, 

Brad 

~ Sheehan 

Senior Vice President, Operations 

/attachment 

100 Hartsfield Centre Parkway, Suite 700 Atlanta, GA 30354 404.856.1000 
ExpressJet Airlines Inc. 

PETITION FOR EXEMPTION 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

SUBJECT: PETITION FOR GRANT OF EXEMPTION 

12/17/2015 

Pursuant to Section 11.61 (b) of the Federal Aviation Regulation (FAR), ExpressJet Airlines Inc., holder of 

Operating Certificate ASOA029B, 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 ExpressJet 

to observe the pilots in qualification observation as required by the aforementioned rule. This exemption 

renewal is requested in order for 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 Check Airmen, in the employ of 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) 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 takeoff and landing. During the time that a qualifying pilot in command is 

acquiring the operating experience in paragraphs (c)(1) (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 ExpressJet Airlines Inc.; 

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

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PETITION FOR EXEMPTION 

12/17/2015 

c. Be approved by the FAA Aircrew Program Manager; and 

d. Have been employed by ExpressJet Airlines Inc. as a check airman for a minimum of 6 

months. 

2. ExpressJet Airlines Inc. must submit and have approved by its FAA principal operations 

inspector (POl), in a letter of approval, the name of each check airman to be used under this 

exemption before this use occurs. 

3. Before each observation conducted under this exemption, ExpressJet Airlines Inc. must contact 

its POl or the POl'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 PIC. 

6. The qualifying PIC candidate must be observed performing the duties of a PIC 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 ExpressJet Airlines Inc. 

approved training records. 

8. No observations may be conducted under this exemption until the qualifying PIC has completed 

no less than 10 hours of supervised OE and accomplished no fewer than two takeoffs and 

landings. 

9. ExpressJet Airlines Inc. must maintain the records necessary to demonstrate compliance with 

the conditions and limitations of this exemption. 

PUBLIC INTEREST 

Granting of this petition for exemption to permit an ExpressJet Airlines Inc. Check Airman to conduct the 

required observation as previously outlined is in the public interest for reasons of safety, economics and 

being able to complete the requirements of the FAR in a timely manner. With the current staffing of the 

Certificate holding District Office (CHDO), the FAA is not always available to conduct the observation as 

scheduled. Allowing ExpressJet Airlines Inc. to conduct the observation, when the FAA is unavailable, will 

allow for the completion of this pilot qualification element in a timely fashion, thereby reinforcing the 

training guidance given to the pilots in training. 

EQUIVALENT LEVEL OF SAFETY 

ExpressJet Airlines Inc. believes that this proposal for the requested exemption renewal, will not merely 

provide an equivalent level of safety to operations under this present 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 ExpressJet Airlines Inc. will allow yet another review of the FAA 

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PETITION FOR EXEMPTION 

12/17/2015 

approved pilot training program. These additional observations will provide valuable feedback to enhance 

the quality of the FAA approved pilot training program. 

In summary, this exemption, in addition to supplementing the FAA staffing, will provide valuable 

information on the preparedness of the newly trained pilots. This exemption, in addition to making 

available additional resources, will allow an ExpressJet Airlines Inc. 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 §11.87(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 

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 

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 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 of the petition is as follows: 

ExpressJet Airlines Inc. requests an exemption from FAR 121.434(1 )(c)(ii), (FAA observation), to the 

extent necessary to permit authorized ExpressJet Airlines Inc. Check Airmen to conduct the required pilot 

observation when a FAA inspector is unavailable. 

Sincerely, 

r eehan 

Senior Vice President, Operations 

cc: Inspector Billy Smith 

ExpressJet Airlines Inc. Principal Operations Inspector 

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