April 7 , 201 4

Federal Aviation Administration U.S. Department of Transportation, Docket Operations, West Building Ground Floor, Room W12

– 140, 1200 New Jersey

Avenue, SE., Washington, DC 20590

Re: Petition for Exemption
Dear Sir or Madam:
The Air Transport Association of America, Inc,. dba Airlines for America (A4A) , on behalf of member Part 121 air carriers, petitions pursuant to applicable sections of Title 14 of the Code of Federal Regulations with regards to applicants for (i) an aircraft ty pe rating to be added to an airline transport pilot certificate or (ii) a ty pe rating to be concurrently

completed with an airline transport pilot certificate. Previously, FAR 61.39(b)( 1)(i) and (ii) provide d for an exception from the requirements of FAR 61.39(a)(1) insofar as it allows the use of an expired knowledge test
so long as the applicant is an employee of a Part 121, 125, or 135 certificate holder and “has satisfactorily

accomp lished that operator’s approved pilot in command aircraft qualification training program and qualification training requirements for the certificate and rating sought.” FAR 61.39(b). In addition, FAR 61.157(c) provide d for an exception from the requirements of FAR 61.157(b). Thus, an aircraft ty pe rating applicant is exempt from ground and flight training, as well as practical test, on the areas of operation under 61.157(e) so long as the applicant is an employee of a Part 121 or 135 certificate holder and “presents a training record that shows completion of the certificate holder’s approved pilot in command training program for the aircraft ty pe rating.” FAR 61.157(c). On July 15, 2013, the FAA published the Pilot Certification and Qualification Requirements for Air Carrier Operations Final Rule which renumbered or removed certain regulations that impact this exemption. Therefore, A4A respectfully requests the FAA update Exemption No. 10556 to reflect the correct regulatory references. A4A requests that participants in an approved second in command training program also be able to take advantage of the applicable regulations upon presenting a training record showing completion of the certificate holder’s approved second in command training program for the aircraft ty pe rating. As a condition for accepting this relief, A4A member air carriers will agree not to allow their SICs to operate as PICs under their newATP certificate until they have completed the air carrier’s approved PIC training

program. Approval of the exemption requested herein is in the public interest inasmuch as it would reduce unnecessary c osts and facilitate compliance with new pilot qualification statutory requirements. The FAA has acknowledged in Notice N8900.184 that delays in the ATP certification process of SICs “could pose significant challenges” to air carriers and the FAA itself due to the number of SICs who currently only hold a commercial pilot certificate and the training hours and certification activities required to provide ATP certification. Granting this narrowly tailored exemption request would alleviate some air carriers’ concerns about meeting the compliance deadline without compromising aviation safety.
A4A respectfully requests that the exemption be granted expeditiously

. Adelay in granting this exemption would result in hardship to Part 121 air carriers and their customers inasmuch as otherwise qualified SICs would not be a ble to perform their duties, causing a loss of revenue to airlines that would ultimately affect the price of air transportation.
Please do not hesitate to contact me if you have any questions or require additional information in order to act on this petition.

Respectfully

submitted,

Donald R. Dillman Managing Director, Flt. Operations Airlines for America 1301 Pennsylvania Avenue Suite 1100 Washington, DC 20004 (202) 626

- 4285 ddillman@airlines.org