March 3, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12

- 140

1200 New Jersey Avenue, SE.

Washington, DC 20590

Re: Exemption No. 4901, as amended; Docket No. FAA

- 2001

- 9282

Ladies/Gentlemen:

In accordance with Title 14 of the Code of Federal Regulations (14 CFR) § 11.61, the Air

Transport Association of America, Inc. (ATA)

, dba Airlines for America, on behalf of its

member airlines 1 and other similarly situated Part 121 operators, operators of Part 63

flight engineer training schools, and Part 142 training center certificate holders, petitions

the Administrator for an extension of Exemption No. 4901, Docket FAA

- 2001

- 9282.

This exemption is sch eduled to expire on May 31, 2013

.

Exemption No. 4901 provides relief, under certain conditions and limitations, from

specific provisions of 14 CFR § 63.39 (b )(1) and (2) and § 1 21.425 (a)(2) (i) and (ii).

Under flight engineer training programs approved under part 121, the qualification

requirements of § 121.425 (a)(2)(i) and (ii) may be met concurrently with the certification

requirements of § 63.39 (b)(1) and (2) in a single fli ght check.

The exemption also grants relief to the extent necessary to permit applicants in training

for that flight check to take the airplane preflight inspection portion of that flight check

using an advanced pictorial means instead of an airplane, and normal procedures portion

of that flight check in an approved flight simulation device. Also, all qualifying operators

of part 63 flight engineer courses and all part 142 training center certificate holders

conducting flight engineer training courses i n accordance with part 63 requirements be

granted an exemption from § 63.39 (b)(2) to the extent necessary to allow applicants who

are training in preparation for the flight engineer practical test to take the normal

procedures portion of that test in an a pproved flight simulation device.

1 A4A airline members include: Alaska Airlines, Inc., American Airlines, Inc., (American Airlines and US

Airways) Atlas Air, Inc., Delta Air Lines, Inc., Federal Express Corp. , Haw aiian Airlines, JetBlue Airways

Corp., Southwest Airlines Co., United Continental Holding s, Inc., and United Parcel Service Co.

. A4A’s

associate airline member is Air Canada.U.S. Department of Transportation

Docket Operations

Docket No. FAA

- 2001

- 9282

March 3, 2015

Page Two

The conditions and circumstances, in regard to public interest and equivalent levels of

safety, which warranted the original grant of exemption, continue to exist. This petition

does not seek to change the conditions and limitations of the current exemption. This

exemption has been in use for over fifteen years with no known compromise of safety.

The renewal of this exemption is not a controversial issue. For this reason, and the

reasons stated above, ATA requests that a f inding of good cause be made for waiving

publication in the Federal Register (14 CFR §11.87). Granting the requested relief will

set no precedents. The existence of the exemption is well known and widely accepted.

A summary of this petition as required by 14 CFR §11.81 is attached. If you have any

questions or need additional information, please call me at (202) 626

- 4012.

Very truly yours,

AIR TRANSPORT ASSOCIATION

OF AMERICA , dba AIRLINES FOR AMERICA

By: ___________

/S/

_______________ Paul W. Railsback

Director

- Operations

1301 Pennsylvania Avenue, NW

Suite 1100

Washington, D.C. 20004

- 1707

(202) 626

- 4012

prailsback@airlines.org

AttachmentU.S. Department of Transportation

Docket Operations

Docket No. FAA

- 2001

- 9282

March 3, 2015

Attachment

SUMMARY OF ATA PETITION

To renew Exemption 4901M which allows flight engineer training programs approved

under part 121, the qualificatio n requirements of § 121.425 (a)(2) (i) and (ii) be met

concurrently with the certificat ion requirements of § 63.39 (b) (1) and (2) in a single flight

check. Also allows Part 121 operators, Part 63 flight engineer schools and Part 142

training center certificate holders to train and check flight engineer applicants in the

performance of preflight inspections using approved pictorial displays instead of the

airplane, and normal procedures portion of that flight check in an approved flight

simulation device.