April 7, 2014

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 

type rating to be added to an airline transport pilot certificate or (ii) a type rating to be 

concurrently completed with an airline transport pilot certificate. 

Previously, FAR 61.39(b)(1)(i) and (ii) provided 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 accomplished 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) provided for an exception 

from the requirements of FAR 61.157(b). Thus, an aircraft type 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 type 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 type 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 new 
ATP 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 costs 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. A delay 

in granting this exemption would result in hardship to Part 121 air carriers and their 

customers inasmuch as otherwise qualified SICs would not be able 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