Leo Hollis Aviation Safety Inspector Aircraft Dispatcher Air Transportation Division - AFS-220 (202) 493-5508

Subj: Request for Amendment to Exemption #10332

Dear Leo,

Delta Air Lines recently petitioned for an ex tension to exemption 9962 (referred to as the 1-1-3 exemption)

At the request of the FAA, we then followe d up with a petition to combine exemptions 9962 and 8575 (referred to as the 1-1-2 exemption).

The FAA recently issued exemption 10332 to De lta Air Lines and in our review of the

conditions and limitations and we discovered an omission that is of concern. We believe it was likely a simple oversight and request re -issuance of the exemption to correct this.

In exemption 10332, only references to CAT II requirements are listed in the Conditions

and Limitations section:

“6. Delta must maintain at least CAT II a pproach authorization, OpSpec C059, for those fleets to which this exemption applies, a nd each aircraft must have fully operating equipment needed for CAT II ILS approaches for that aircraft to operate under this exemption”.

“7. At the time of dispatch, the flightcrew must be qualified to conduct at least a CAT II approach. PICs with less than the requis ite minimum hours specified in 14 CFR § 121. 652 cannot be used in operations under th is exemption unless the operator also holds exemption No. 5549, the PIC has been trained in accordance with the requirements of that exemption, and all of the conditions specified by exemption

No. 5549 are met. “

Missing from the combination exemption issu ed to Delta is the relief for CAT I aircraft/crews. Delta’s exempti on 9962 (1-1-3) states: “The air carrier must have at least CAT I approach authorization (Operations Spec ifications C053 and C074) for those fleets to which this exemption would apply.”

The unintended consequences of this is a mo re conservative requirement and no further

relief for CAT I aircraft.Delta requests that the exemption be modified to use the same language that exists in other carriers’ exemptions. For example, American Airlines exemption 10000 Conditions

and Limitations 5 & 6:

5. American must maintain CAT I (OpS pec C074)/CAT II/CAT III (OpsSpec C059) ILS approach authorization (as applicable) fo r those aircraft to which this exemption would apply, and each aircraft must have fully operating equipment needed for the appropriate CAT I/CAT II/CAT III ILS approach for that aircraft to operate under this exemption.

6. At the time of dispatch, the flightcrew must be qualif ied to conduct a CAT I/CAT II/ CAT III ILS approach to published minimums (as applicable). PICs with less than the requisite minimum hours specified in § 121.652 cannot be used in operations under this exemption, unless the operator also holds Exemption No. 5549, the PIC

has been trained in accordance with the re quirements of that exemption, and all of the conditions specified by Exemption No. 5549 are met.

For your convenience and review, I’ve at tached both Exemption 10332 (Delta) and Exemption 10000 (American)

Please contact myself or Chuck Sc hramek if you have any questions.

Best Regards,

Casey Seabright Manager, Regulatory Compliance Delta Air Lines, Inc.

wk: 404-715-1536

BB: 612-207-5612