SOUTHWEST AIRLINES CO.

Leslie C. Abbott

Senior Attorney

919 18 th Street, N.W., Suite 60 0

Washington, D.C. 2000 6

(202) 263

- 6285

(202) 263

- 6 291

- Fax

leslie.abbott @wnco.com

_______________________________________________ _____________________________

February 20 , 201 4

Filed Electronically V ia E

- Mail

U.S . Department of Transportation Mr. John Duncan

Docket Operations, M

- 30 Director, Flight Standards Service

West Building ground floor, Federal Aviation Administration

Rm W12

- 140 AFS

- 1, Flight Standards Service,

1200 New Jersey Avenue, SE. Rm 821

Washington, DC 20590 800 Independence Avenue, S.W.

Washington, DC 20591

John.s.duncan@faa.gov

Re: Revised Petition for Renewal of Exemption from

14 CFR § 121.434(c)(1)(ii); FAA

- 2002

- 11485

Dear Sir:

Pursuant to Federal Aviation Regulation 14 CFR §11.61(b), Southwest Airlines

Co. (“Southwest”) hereby petitions the FAA for the seventh renewal of Exemption No.

7132

, which permits Southwest to substitute a qualified and authorized check airman in

place of an FAA inspector to observe a qualifying pilot in command (“PIC”) while that

PIC is completing the initial or upgrade training specified in FAR §121.424 (FAA

- 2002

- 11485, previously Docket No. 29836). 1

The FAA initially granted Exemption No. 7132 on February 28, 2000 and has

extended it for six consecutive two

- year periods. Unless this exemption is extended

once again, it will terminate on February 28 , 20 14 . Southwest requests that the FAA

renew Exemption No. 7132 for at least two additional years. This request is consistent

with the exemption renewals that the FAA has already granted to Southwest , as well as

to other airlines . A copy of the original Exemption No. 7132, and the most recent

Exemption Renewal No. 7132 G , a re attached as Exhibit s A and B

.

On November 13, 2013, Southwest filed a similar Petition for Renewal in this

docket seeking both a renewal and an amendment of the exemption . However,

1 Southwest’s acquisition of AirTran Airways, Inc. (“AirTran”) on May 2, 2011 is not relevant to this exemption

application because AirTran continues to employ a separate pilot training program from Southwest and AirTran’s

Training Manual is a separate appen dix to Southwest’s Training Manual. The separate training structure will remain

in place until Southwest absorbs all AirTran pilots into its existing training program , which is expected to take pla c e at

the end of 2014

. Therefore, there is no ne ed to consider AirTran in this exemption application.Federal Aviation Administration

November 13, 2013

Page 2

Southwest submits this Revised Petition for Renewal seeking only a ren ewal of the

exemption, and will submit a separate request for an amendment in this docket.

I. FAA HAS CONSISTENTLY FOUND T HAT EXEMPTION 7132 I S IN THE

PUBLIC INTEREST AND PROVIDES A COMPA RABLE LEVEL OF SAFET Y.

Exemption No. 7132 grants Southwest relief from 14 CFR §121.434(c)(1)(ii) to

the extent necessary to permit Southwest to substitute a qualified and authorized check

airman in place of an FAA inspector to observe a qualifying PIC who is completing the

initial or upgrade training sp ecified in FAR §121.424 during at least one flight leg that

includes a takeoff and a landing. Exemption No. 7132 at p. 2.

In granting Southwest’s exemption request and the subsequent renewals, FAA

determined that such an exemption was in the public interest. Specifically, FAA found

that for Southwest and other similarly situated commercial air carriers, “permitting a

limited number of qualified and authorized check airmen to conduct certain PIC

observations would benefit the public by reducing unnec essary costs that may influence

the price of services to the public and by improving the airlines’ ability to provide on

time, dependable air service.” Exemption No. 7132 at p. 1. The FAA also found that the

exemption “would not reduce the level of safety , provided the petitioner complies with

certain conditions and limitations.” Id. These findings continue to hold true and

Southwest’s multi

- year, uninterrupted safe operation pursuant to the exemption strongly

supports its renewal.

II. SOUTHWEST IS IN FUL L COMPLIANCE WITH ALL OF THE EXEMPTION

CONDITIONS AND LIMIT ATIONS

.

Southwest is in full compliance with all of the conditions and limitations specified

in Exemption No. 7132 and its subsequent renewals. Southwest believes that its

performance under the e xemption has been satisfactory to the FAA, as no indication to

the contrary has been received.

I II

. CONCLUSION

All of the circumstances stated in Southwest’s original request for this

exemption and the preceding requests for its renewal, remain the same

. There has

not been any material change in the findings relative to public interest and safety

that were the basis for granting the original exemption. As the FAA has noted,

granting this exemption (and by extension the renew al of the exemption requested

here in ), would have no adverse effect on safety. Instead, it will allow Southwest to

continue efficient and competent completion of observation flights through

appropriate utilization of FAA resources and qualifying PIC’s. To minimize theFederal Aviation Administration

November 13, 2013

Page 3

administrative burden on all parties, Southwest seeks a renewal for a minimum of

two years , with a longer extension preferred

.

We appreciate the FAA’s consideration of this request.

Respectfully submitted,

_________________ Leslie C. Abbott

CC: Joe Marott, Southwest Director Flight Training Center

Jim Stieve, Southwest Senior Manager Operational Certification & Compliance

Bob Kneisley, Southwest Associate General Counsel

Attachments

Attachment A

– Southwest Exemption No. 7132, February 28, 2000

Attachment B

– Southwest Exemption Renewal No. 7132G, February 8, 2010.