September 13, 2010 

U. S. Department of Transportation 

Docket Operations, M-30 

West Building Ground Floor, 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

Exemption No. 6570H, as amended, Regulatory Docket No. FAA-2000-8454

Ladies and Gentlemen: 

In accordance with Federal Aviation Regulations (FAR) Part 11.63, United Air Lines, Inc. 

(United Airlines or United) petitions the Administrator for an extension of the termination 

date of Exemption No. 6570H, as amended, from January 31, 2011, to January 31, 2013. 

Exemption No. 6570H, as amended, grants relief from FAR 121.434(C)(1)(2) allowing an 

FAA-authorized United check airman to substitute for an FAA inspector in those cases 

where an inspector is not available to accomplish the required observation during the 

scheduled Operating Experience (OE) flight legs of a qualifying Pilot In Command (PIC) 

who is completing initial or upgrade training. 

Without this exemption, United Airlines would have to delay completion of OE awaiting 

the availability of an FAA inspector. This delay would place United Airlines at a 

significant operating disadvantage, as a highly skilled manpower resource remained idle. In 

petitioning for extension of this exemption, United notes that during the approximately 13 

years during which we have used the provisions of this exemption there have been 

numerous occasions when United Airlines was able to complete a PIC’s initial OE despite 

the unavailability of an FAA inspector. 

Public Interest

FAR Part 11.81 requires that the petitioner for an exemption explain why granting the 

request would be in the public interest. This exemption allows United to complete PIC 

operating experience without the time and expense of scheduling an additional flight leg 

when an FAA inspector is not available during the normal course of OE. Moreover, some 

number of days might elapse before that additional flight leg could be accomplished, all the 

while the qualifying PIC would be unavailable for flight duty. It is in the public interest to 

control costs to the extent possible without adverse impact on flight safety. Experience 

gained through the use of this exemption demonstrates that it is fulfilling its intended 

purpose and validates the original FAA conclusion of safety equivalency. 
2 

Waiver of Public Notice

FAR Part 11.87 allows the waiver of public notice of a petition if good cause for such 

waiver is found. United suggests that good cause exists for waiving publication of notice of 

this petition in the Federal Register. Publication of notice in the Federal Register would 

cause unnecessary delay to the petitioner. Granting the relief requested in this petition 

would not set a precedent, and the exemption would in all ways, other than the effective 

date, be identical to the exemption now in place. Delay in acting on the petition would be 

detrimental to the petitioner and to the public, as well. 

Summary

United Airlines petitions the Administrator for an extension of the termination date of 

Exemption No. 6570H, as amended, which permits United to substitute an FAA-authorized 

United check airman for the FAA inspector in those cases where an inspector is not 

available to accomplish the required observation during the scheduled OE flight legs of a 

qualifying PIC who is completing initial or upgrade training [FAR 121.434(C)(1)(2)]. 

There has been no change in the conditions and reasons relative to public interest and safety 

that were the basis for granting the original exemption. 

Thank you for your consideration of this petition. Please advise if any further information 

is required for your review. 

Sincerely, 

Juan de Mesa 

Staff Rep. Flight Operations Regulatory Compliance