SOUTHWEST AIRLINES CO.

 Leslie C. Abbott

 Senior Attorney

 919 18th Street, N.W., Suite 600

 Washington, D.C. 20006

 (202) 263-6285

 (202) 263-6291 - Fax

 leslie.abbott@wnco.com

____________________________________________________________________________

February 20, 2014

Filed Electronically Via 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, 2014. 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. 7132G, are attached as Exhibits 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 appendix 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 place at 

the end of 2014. Therefore, there is no need 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 renewal of the 

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

I. FAA HAS CONSISTENTLY FOUND THAT EXEMPTION 7132 IS IN THE 

PUBLIC INTEREST AND PROVIDES A COMPARABLE LEVEL OF SAFETY.

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 specified 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 unnecessary costs that may influence 

the price of services to the public and by improving the airlines’ ability to provide ontime, 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 FULL COMPLIANCE WITH ALL OF THE EXEMPTION 

CONDITIONS AND LIMITATIONS.

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 exemption has been satisfactory to the FAA, as no indication to 

the contrary has been received. 

III. 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 renewal of the exemption requested 

herein), 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 the 
Federal 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.