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 Regulatio ns (FAR) Part 11.63, United Air Lines, Inc. (United Airlines or United) petitions the Admi nistrator for an extens ion of the termination date of Exemption No. 6570H, as amended, from January 31, 2011, to January 31, 2013.

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

FAA-authorized United check airman to subs titute 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 init ial or upgrade training.

Without this exemption, United Airlines woul d have to delay completion of OE awaiting the availability of an FAA inspector. Th is 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, Un ited notes that during the approximately 13 years during which we have used the provisi ons of this exempti on there have been

numerous occasions when United Airlines was ab le to complete a PIC’s initial OE despite the unavailability of an FAA inspector.

Public Interest

FAR Part 11.81 requires that th e petitioner for an exempti on 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 duri ng the normal course of OE. Moreover, some number of days might elapse before that addi tional flight leg could be accomplished, all the while the qualifying PIC would be unavailable for f light duty. It is in the public interest to control costs to the extent possible without a dverse impact on flight safety. Experience gained through the use of this exemption dem onstrates 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 no tice 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. Public ation of notice in the Federal Register would cause unnecessary delay to the petitioner. Gr anting 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 pl ace. 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 r easons 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 Operati ons Regulatory Compliance