BEFORE THE

FEDERAL AVIATION ADMINISTRATION

WASHINGTON D.C.

Petition of:

AMERICAN AIRLINES, INC.

OPERATING CERTIFICATE AALA025A

For exemptio n 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

I n accordance with the Code of Federal Regulations, 14 CFR §11.81

, American Airlines (American)
Petitions fo r exemptions from § § 121.438 (b) and 121.652 (a) of Title 14 , Code of Federal Regulations (14 CFR) to allow America n 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 B 767. A nd 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) state s: “ 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 ope rations 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 aircr aft type once the combined flight time exceeds 100 hours.Petition f or Exemption

- 14 CFR 121.438 and 121.652

Amer ican 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 high ly 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 cur rently 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 er minimums, must be granted in conjunction, in order to satis fy 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 c onsider 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

E xemption 5549M, would not set a precedent.Petition f or Exemption

- 14 CFR 121.438 and 121.652

Amer ican 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 exempt ion 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)

an d B767 (Related Aircraft) in conjunction with these exemptions meets the intent of the regulations and is in the public interest.

For questions or c omments regarding this Exemption request , please contac t 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

.