April 20, 2010

U.S. Department of Transportation 

Docket Management System

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

Washington, DC 20591-0001

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

Ladies/Gentlemen:

In accordance with the Code of Federal Regulations, 14 CFR § 11.25, the Air Transport 

Association of America (ATA) petitions on behalf of its member airlines1and other similarly 

situated Part 121 operators or an extension of Exemption No. 4416 (FAA Docket No. FAA2002012831). This exemption is scheduled to expire on September 30, 2010.

Exemption No. 4416 provides relief from Title 14, Code of Federal Regulations (CFR) § 

61.157(a) and Item I(b) of Appendix A of Part 61, §121.424(a) and (b), Item I(a) of Appendix E 

of Part 121 and § 121.424(d)(1) and Item I(b) of Appendix F of 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 (4416L), which includes training on an actual aircraft prior to the completion 

of operating experience required by 14 CFR §121.434. 

____________________________________

1 Operator Members: ABX Air, Alaska Airlines, Airtrans, American Airlines, ASTAR Air Cargo, Atlas Air, Continental Airlines, Delta Air Lines, 

Evergreen International, Federal Express, Hawaiian Airlines, JetBlue Airways, Polar Air Cargo, Southwest Airlines, United Airlines, UPS 

Airlines, US Airways. 

 Associate Members: Aeromexico, Air Canada, Air Jamaica, and Mexicana. 
U.S. Department of Transportation 

Docket Management System

April 20, 2010

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. ATA, in accordance with the 

provisions of 14 CFR § 11.27(j)(3)(i), Exceptions to Publication of Summary of Petition for 

Exemption, requests that a finding of good cause be made for waiving publication in the Federal 

Register. A summary of a previous ATA'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. ATA 

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

A summary of this petition as required by 14 CFR § 11.25 is attached. 

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

Very truly yours, 

Paul W. Railsback

Director of Operations

Air Transport Association 

1301 Pennsylvania Avenue NW

Suite 1100

Washington, D.C. 20004

(202) 626-4012

prailsback@airlines.org

Attachment
Attachment

SUMMARY OF ATA PETITION

Petitioner: Air Transport Association of America (ATA)

Regulation Affected: 14 CFR 61.157(a)

14 CFR 61 Appendix A Item I(b)

14 CFR 121.424(a) and (b)

14 CFR 121 Appendix E Item I(a)

14 CFR 121.424(d)(1)

14 CFR 121 Appendix F Item I(b)

Description of Relief Sought:

The Air Transport Association of America (ATA) 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.