Exemption Request 

B757/B767 Designated Related Aircraft 

November 3, 2015 

Revised December 15, 2015 

1 | Page

Docket Management Facility US Department of Transportation 

1200 New Jersey Avenue, SE West 

Building Ground Floor Room W12-140 

Washington, DC 20590

Regarding: Related Aircraft B757/B767 Exemption Requests (FAA-2015-5566)

14 C.F.R. References: § 121.438 Pilot Operating Limitations and Pairing Requirements 

§ 121.652 Landing Weather Minimum: IFR: All Certificate Holders 

Dear Madam/Sir: 

United Airlines (CALA014A) requested and was granted related aircraft designation for the Boeing 757 

(Base Aircraft) and Boeing 767 (Related Aircraft) in accordance with §121.418(b). In response to that 

approval, and in accordance with the Code of Federal Regulations, 14 C.F.R. § 11.25, United Airlines 

petitions the Administrator for exemptions to provide relief from §§121.438 and 121.652 for B757 and 

B767 designated related aircraft pairing and high minimums landing requirements. This exemption 

would apply to United Airlines, Inc. worldwide operations. 

Related Aircraft Exemption for Crew Pairing 

In accordance with 14 CFR §121.438(b), either the Pilot in Command (PIC) or Second in Command 

(SIC) must have at least 75 hours of line operating flight time on the specific airplane type to conduct 

operations under Part 121. United requests exemptive authority to pair crewmembers with less than 75 

hours in either the B757 or the B767, conditioned on United requiring that the pilot in command or 

second in command must have at least 75 hours of combined line operating flight time in the B757 and 

the B767 for the purposes of crew pairing requirements. 

Related Aircraft Exemption for High Minimums 

In accordance with 14CFR § 121.652(a), the landing minimums must be increased by 100 feet and onehalf mile at Regular, Provisional, and Refueling airports, if the PIC has not served at least 100 hours as 

PIC in the specific airplane type in part 121 operations. United requests exemptive authority to combine 

PIC flight times logged on either the B757 or B767 (or both) to meet the 100 hours of PIC time required 

in order to avoid being subject to higher minimums in either aircraft type once the combined flight time 

exceeds 100 hours. 

United Airlines is currently operating under Airlines for America (A4A) Exemption 5549M, Regulatory 

Docket No. FAA-2000-8434, which allows a new pilot in command of any A4A member airline, and of 

any other similarly situated Part 121 certificate holder, who is subject to higher landing weather minimum 

requirements to operate to the normal, lower Category I and Category II minimums under the conditions 

stipulated in the exemption. Under 5549M Conditions and Limitations: 

1. Each operator using this exemption must comply with 14 CFR §121.438. 

Since the condition for relief from high minimums is related to 14 CFR §121.438(b), the Related Aircraft 

Exemption for Crew Pairing and this exemption request for relief from high minimums, must be granted 

in conjunction, in order to satisfy the conditions and limitations of Exemption 5549M. 
Exemption Request 

B757/B767 Designated Related Aircraft 

November 3, 2015 

Revised December 15, 2015 

2 | Page

This exemption request does not deviate from the number of hours required by 14 CFR Part 121 nor 

United Airlines’ current authorizations. United Airlines believes that granting approval to operate the 

B757 (Base Aircraft) and B767 (Related Aircraft) in conjunction with these exemptions meets the intent 

of the regulations and is in the public interest. 

 

Public Benefits 

Granting these exemptions is in the public interest. United and other carriers have safely operated the 

B757 and B767 as a combined fleet for nearly 30 years, subject to rigorous training and oversight 

programs for related aircraft. The two aircraft share a common type rating, near identical cockpits, and 

common aerodynamic characteristics. Over decades of safe operations of B757 and B767 as related 

aircraft, and decades of FAA oversight, United has made fleet, crew scheduling and basing, and training 

decisions premised on the assumption that crews were effectively interchangeable. Granting these 

exemptions is consistent with the FAA’s historical approach. The FAA already allows credit between the 

two aircraft for flightcrew member training, checking, recent experience, operating experience, operating 

cycles, and line operating time for consolidation of knowledge and skills. 

Without these exemptions, United will have to revise its crew pairing, basing and scheduling processes 

and systems, and potentially rebid crew assignments and renegotiate labor agreements. The additional 

costs incurred in making these changes could reach $300 million and result in higher ticket prices without 

any increase in safety or service. Without these exemptions, some crews would be constrained in adverse 

weather, meaning that they would be precluded from flying certain precision approaches using high 

quality flight guidance and forced to expend time and fuel to divert to other less capable airports. 

Granting these exemptions will continue to afford the flying public the high levels of safety and service 

regularity experienced on these two aircraft for the past three decades. 

Equivalent Level of Safety 

Safety risk management has been applied per United’s SMS policy for operating the B757 and B767 as a 

combined fleet. Hazard mitigation is monitored through continued evaluation of training and operational 

data in addition to participation in multiple voluntary safety programs. The combination of voluntary 

programs employed at United provides the Administrator with targeted operational oversight through 

continued surveillance with the AQP, SMS, FSAP (ASAP), LOSA, FOQA, and VDRP processes. These 

programs provide United and FAA leadership with regular opportunities for continuous monitoring, 

critical analysis and review of safety trends. The goal of these programs is to identify safety-related 

problems within an air carrier’s operation, including operational and procedural errors, and to develop 

corrective actions. The key to all of these programs is the inclination to proactively seek safety solutions, 

rather than wait and react to an accident or serious incident. The combination of these programs 

incorporated at United Airlines promotes safety across the industry and mitigates risk. 

United has participated in, and used the data gathered from, these safety programs throughout the 

company’s nearly 30 year history of combined B757/B767 fleet operations. Any problematic issues have 

been identified and resolved using applicable risk mitigation; whether through training, operating 

procedures, sub-fleet methodology, or technology solutions. As a mature operator of a common 

B757/B767 fleet, United’s robust programs have proven to adequately meet and address any issues 

identified while conducting mixed fleet operations. Therefore, operations in accordance with this 

deviation will provide an equivalent level of safety for continued operations of the B757 and B767 as a 

combined fleet. 
Exemption Request 

B757/B767 Designated Related Aircraft 

November 3, 2015 

Revised December 15, 2015 

3 | Page

Reasons Exemptions are Requested 

On March 9, 2015, the FAA issued National Policy Notice 8900.286 directing principal operations 

inspectors (POI) to identify and correct Part 121 training programs that include credit between airplanes 

with different type certificates without (1) approved related aircraft designations and (2) approved aircraft 

related aircraft deviations, as required, from the FAA Headquarters (AFS-200, Air Transportation 

Division). In accordance with this policy, United Airlines requested and received Administrator approval 

of Boeing 757 (Base Aircraft) and Boeing 767 (Related Aircraft Designation) for the purposes of 

conducting related aircraft differences training and to pursue allowable flight crew training credits 

between airplanes with designated related aircraft approval. The B757/B767 common characteristics and 

type rating provide additional basis for these exemptions. Other considerations include: 

 United’s Qualification, Continuing Qualification, Requalification, Differences, Upgrade and 

Transition curricula incorporate exposure to a mixed combination of B757 and B767 Flight 

Simulation Training Devices (FSTDs) for both training and checking. Pilots in training are 

continuously assessed to ensure that performance is meeting standard and that course construct is 

validated. This approach provides all United B757/B767 pilots the opportunity to train and check 

in multiple FSTD configurations and aircraft variants. 

 At least one flying leg in each type aircraft is provided per United Airlines pilot scheduling OE 

guidelines for B757/B767; however, actual flight time in a specific type is not prescriptive. This 

allows one leg of OE to be conducted with a Check Airman in each aircraft type, B757 and B767. 

 United operates mixed B757 and B767 aircraft across the system and does not designate one type 

for a specified pilot domicile. This provides United B757/B767 pilots the opportunity to fly 

both/either aircraft type. 

 All Qualification and Continuing Qualification B757/B767 differences computer based training 

(CBT) courses are available to pilots on demand. This provides United B757/B767 pilots an 

additional refresher resource whenever desired. 

 All United pilots operating as PIC have a minimum of 1000 hours in air carrier operations. 

 All active United Airlines pilots hold an unrestricted ATP certificate with an appropriate aircraft 

type rating. 

Conditions and Limitations Consultation 

Because even seemingly-negligible implementation modifications resulting from disapproval of this 

exemption request pose the potential for significant impact to United’s training programs and business 

practices, and could therefore obviate the utility of the requested deviation itself, United respectfully 

requests the opportunity to discuss with the FAA any conditions and limitations the Administration may 

consider imposing on its grant of this deviation request prior to its issuance. 

Please contact United Airlines Managing Director Flight Operations Bryan Quigley (872-825-1275, 

bryan.quigley@united.com) or me if any further information is required for your approval. 

Sincerely, 

Ellen Birmingham 

Director Flight Operations Regulatory Compliance & Quality Control