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 extension to exemption 9962 (referred to as the 

1-1-3 exemption) 

 

At the request of the FAA, we then followed 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 Delta 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 approach authorization, OpSpec C059, for those 

fleets to which this exemption applies, and 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 requisite minimum hours specified in 14 CFR 

§ 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 

requirements of that exemption, and all of the conditions specified by exemption 

No. 5549 are met. “ 

 

 

Missing from the combination exemption issued to Delta is the relief for CAT I 

aircraft/crews. Delta’s exemption 9962 (1-1-3) states: “The air carrier must have at least 

CAT I approach authorization (Operations Specifications C053 and C074) for those fleets 

to which this exemption would apply.” 

 

The unintended consequences of this is a more 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 (OpSpec C074)/CAT II/CAT III (OpsSpec C059) 

ILS approach authorization (as applicable) for 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 qualified 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 requirements of that exemption, and all of 

the conditions specified by Exemption No. 5549 are met. 

 

 

 

For your convenience and review, I’ve attached both Exemption 10332 (Delta) and 

Exemption 10000 (American) 

 

Please contact myself or Chuck Schramek if you have any questions. 

 

Best Regards, 

 

 

Casey Seabright 

Manager, Regulatory Compliance 

Delta Air Lines, Inc. 

wk: 404-715-1536 

BB: 612-207-5612