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 Limita tions and Pairing Requirements § 121.652 Landing Weather Minimum: IFR: All Certificate Holders

Dear Madam/Sir:

United Airlines (CALA014A) requested and was grante d 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 Fede ral Regulations, 14 C.F.R. § 11.25, United Airlines petitions the Administrator for exemptions to pr ovide relief from §§121.438 and 121.652 for B757 and B767 designated related aircraft pa iring 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 th e 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 au thority 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 co mbined 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 operatio ns. United requests exemptive authority to combine PIC flight times logged on either the B757 or B767 (o r 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 Airlin es 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 Cate gory I and Category II mini mums under the conditions stipulated in the exemption. Unde r 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 requ est for relief from high minimums, must be granted in conjunction, in order to satisfy the co nditions 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 Air lines 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 shar e 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 we re 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, check ing, recent experience, operating experience, operating cycles, and line operating time for c onsolidation of kn owledge and skills.

Without these exemptions, United will have to revise its crew pairing, basing and scheduling processes and systems, and potentially rebid crew assignments a nd renegotiate labor agreem ents. The additional costs incurred in making these changes could reach $3 00 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 preclude d 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 th e flying public the high levels of safety and service regularity experienced on these two airc raft for the past three decades.

Equivalent Level of Safety

Safety risk management has been applied per Un ited’s SMS policy for operating the B757 and B767 as a combined fleet. Hazard mitigation is monitored th rough continued evaluation of training and operational data in addition to participation in multiple volun tary safety programs. The combination of voluntary programs employed at United provides the Administ rator 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 ser ious incident. The combination of these programs incorporated at United Airlines promotes saf ety across the industry and mitigates risk.

United has participated in, and used the data gath ered 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 pr oven 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 safet y 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 Polic y Notice 8900.286 directing principal operations inspectors (POI) to identify and correct Part 121 trai ning programs that include credit between airplanes with different type certificates without (1) approved rela ted 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 Ai rlines 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 Qualificati on, Requalification, Differences, Upgrade and Transition curricula incorporate exposure to a mixed combination of B757 and B767 Flight Simulation Training Devices (FSTDs) for both trai ning and checking. Pilots in training are continuously assessed to ensure that performance is meeting standard and th at course construct is validated. This approach provides all United B757/B767 pilots the opportunity to train and check in multiple FSTD configurati ons 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 Ch eck Airman in each aircraft type, B757 and B767.

 United operates mixed B757 and B767 aircraft acros s the system and does not designate one type for a specified pilot domicile. This provides Un ited B757/B767 pilots the opportunity to fly both/either aircraft type.

 All Qualification and Continuing Qualificati on 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 mini mum 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 th e 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 F light Operations Brya n Quigley (872-825-1275, bryan.quigley@united.com) or me if any furt her information is required for your approval.

Sincerely,

Ellen Birmingham Director Flight Operations Regulatory Compliance & Quality Control