BEFORE THE

FEDERAL AVIATION ADMINISTRATION

WASHINGTON D.C.

Petition of:

AMERICAN AIRLINES, INC.

OPERATING CERTIFICATE AALA025A

For exemption of certain requirements 

of 14 CFR §§121.438 and 121.652

PETITION OF AMERICAN AIRLINES, INC.

FOR AN AVIATION EXEMPTION

July 8, 2016

Summary for Federal Register

In accordance with the Code of Federal Regulations, 14 CFR §11.81, American Airlines (American)

Petitions for exemptions from §§ 121.438(b) and 121.652(a) of Title 14, Code of Federal Regulations (14 

CFR) to allow American Airlines to pair crew members with less than 75 hours in either the B757 or B767 

aircraft but have a minimum of 75 hours when combined with the B757 and B767. And grant approval to 

combine the Pilot in Command flight times from either the B757 or B767 aircraft to meet the 100 hour 

requirement and not be subject to higher minimums.

Section of the Code of Federal Regulations Affected

14 CFR §121.438(b) states: “ No person may conduct operations under this part unless, for that type 

airplane, either the pilot in command or the second in command has at least 75 hours of line operating 

flight time, either as pilot in command or second in command. “

14CFR §121.652(a) States: “If the pilot in command of an airplane has not served 100 hours as pilot in 

command in operations under this part in the type of airplane he is operating, the MDA or DA/DH and 

visibility landing minimums in the certificate holder's operations specification for regular, provisional, or 

refueling airports are increased by 100 feet and one-half mile (or the RVR equivalent)”

Requested Relief from 14 CFR §121.438(b)

This exemption would grant approval for the pairing of crewmembers with less than 75 hours in either 

the B757 or the B767 aircraft, but would require the pilot in command or second in command to have at 

least 75 hours of combined line operating flight time in the B757 and the B767 for the purposes of crew 

pairing requirements.

Requested Relief from 14 CFR §121.652(a)

This exemption would grant approval to combine the PIC flight times from either the B757 or B767 or 

both to meet the required 100 hours of PIC time requirement and not be subject to higher minimums in 

either aircraft type once the combined flight time exceeds 100 hours.
Petition for Exemption - 14 CFR 121.438 and 121.652

American Airlines, Inc.

Jul 8, 2016

pg. 2

Background 14 CFR §121.438(b)

This request is based on an extensive review of American Airlines FOQA, ASAP, and LOSA safety data 

covering over 1.5 million flights with no issues combining B757 and B767 line operating flight time over 

the past 26 years. In addition, American Airlines Initial, Transition, and Recurrent Training for both the 

PIC and SIC are conducted in both B757 and B767 Simulators, when possible. This results in the crews 

being highly familiar with the flight characteristics of both aircraft. Therefore, the combined flight time 

from the B757 and the B767 is equivalent to the 75 hour requirement with non-designated related 

fleets.

Background 14 CFR §121.652(a)

American 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 higher minimums, must be 

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

International Operations

In accordance with 14CFR 11.81(h), American Airlines is requesting that both exemptions be expanded 

to include international operations, due to the fact that flights accomplished to meet the requirements 

of 14 CFR § 121.438(b) and 121.652(a)are conducted to international destinations.

Request for Expedited Consideration

American Airlines requests that, as part of this Petition for Exemption, the public comment phase be 

waived as per Title 14 CFR Part 11.87(a), which states:

“The FAA may not publish a summary of your petition for exemption and request comments if 

you present or we find good cause why we should not delay action on your petition. The factors 

we consider in deciding not to request comment include:

(a) Whether granting your petition would set a precedent...”

It is the opinion of American Airlines that granting the same relief as has been previously allowed by

Exemption 5549M, would not set a precedent.
Petition for Exemption - 14 CFR 121.438 and 121.652

American Airlines, Inc.

Jul 8, 2016

pg. 3

No Adverse Effect on Public Safety and Public Interest

The conditions and circumstances, in regard to public interest and equivalent levels of safety, which 

warranted the original grant of Exemption 5549M, continue to exist. Exemption 5549M is currently in 

use by American Airlines with no known compromise in safety. 

Conclusion

American Airlines intension is that the FAA would consider granting both exemptions as part of the 

Related Aircraft designation approval. This exemption request does not deviate from the number of 

hours required by 14 CFR Part 121 or American Airlines current authorization, and therefore does not 

jeopardize safety. American 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.

For questions or comments regarding this Exemption request, please contact me at the following 

mailing address: 4601 Highway 360 MD 843, Fort Worth, Texas 76155 or by phone at 817-967-5156 or 

Email at Ron.Thomas@aa.com.

Regards,

Captain Ronald Thomas

Managing Director, Flight Operations

American Airlines, Inc.