July 1, 2014

U.S. Department of Transportation 

Docket Management System

400 7th Street, S.W., Plaza 401

Washington, DC 20591-0001

Re: Exemption No. 4416O, FAA Docket No. FAA-2002-12831

Ladies/Gentlemen:

In accordance with the Code of Federal Regulations, 14 CFR § 11.8125, 

Airlines for America (A4A) petitions on behalf of its member airlines1 and other 

similarly situated Part 121 operators for an extension of Exemption No. 4416 (FAA 

Docket No. FAA-2002-12831). This exemption is scheduled to expire on September 

30, 2014.

Exemption No. 4416 provides relief from 14CFR § 61.157(a); Item I(b) of 

Appendix A toPart 61; §121.424(a), and (b), and (d)(1); Item I(a) of Appendix E to 

Part 121; Item I(b) of Appendix F to Part 121 to the extent necessary to permit 

operators to conduct training and checking of pilots of airplanes requiring only two 

flight crewmembers on the required preflight inspection, both interior and exterior, 

using approved advanced pictorial means.

This petition for extension does not seek to change the conditions and 

limitations of the current exemption (4416O), which among other things includes 

training on an actual aircraft prior to the completion of operating experience 

required by 14 CFR §121.434. 

____________________________________

1 Operator Members: Alaska Airlines, American Airlines, Atlas Air, Delta Air Lines, Federal Express, Hawaiian Airlines, JetBlue 

Airways, Southwest Airlines, United Airlines, UPS Airlines, US Airways. 

 Associate Members: Air Canada. 
U.S. Department of Transportation 

Docket Management System

July 1, 2014

Page Two

The conditions and circumstances, in regard to public interest and equivalent 

levels of safety, which warranted the original grant of exemption, continue to exist. 

This exemption has been in use for sixteen years with no known compromise of 

safety.

The renewal of this exemption is not a controversial issue. A4A, in 

accordance with the provisions of 14 CFR § 11.87 requests that a finding of good 

cause be made for waiving publication in the Federal Register. A summary of a 

previous A4A's petition was published in the Federal Register on May 3, 1993 (58 FR 

26379) and only one comment was filed, and it had no objection to an extension of 

the exemption. No precedents will be set by granting the requested relief. A4A 

therefore requests that publication and the associated comment period be waived.

A summary of this petition as required by 14 CFR § 11.81(f) 25 is attached. 

If any further information or discussion is required, please contact me.

Very truly yours, 

Donald R. Dillman

Managing Director, Flight 

Operations

Airlines for America

1301 Pennsylvania Ave NW

Suite 1100

Washington, D.C. 20004

(202) 626-4285

ddillman@airlines.org

Attachment
Attachment

SUMMARY OF A4A PETITION

Petitioner: Airlines for America (A4A)

Regulation Affected: 14 CFR 61.157(a)

14 CFR 61 Appendix A Item I(b)

14 CFR 121.424(a) and (b) and (d)(1)

14 CFR 121 Appendix E Item I(a)

14 CFR 121 Appendix F Item I(b)

Description of Relief Sought:

Airlines for America (A4A) petitions on behalf of its member airlines and 

other similarly situated Part 121 operators for an extension of Exemption 

No. 4416 with no changes to the existing terms. The exemption permits 

operators to conduct training and checking of pilots of airplanes requiring 

only two flight crewmembers on the required preflight inspection, both 

interior and exterior, using approved advanced pictorial means.