### April 6, 2016

U.S . Department of Transportation , Docket Operations

West Build ing Ground Floor, Room W12

- 140 1200 New Jersey Av enue, SE Washington, DC 20590

Subject: Re

- grant / Extension of Exemption 10576 A Regulatory Docket No. FAA

- 2003

- 16403

Dear Sir/ Madam:

Pursuant to Title 14, Code of Federal Regulations, Part 11.61 (b) , PSA Airlines, Inc. petitions the

Administrator for an extension or re

- grant of Exemption 10576 which permits PSA Airlines, Inc. an exemption from 14 CFR 121.434(c)(1)(ii) to the exte nt necessary to substitute a quali fied and authorized check pilot or aircrew program designee in place of an FAA Inspector to observe a qualifying pilot in command (PIC) while that PIC is performing prescribed duties during at least one flight leg that inc ludes a takeoff and landing when completing initial or upgrade training as specified in 14CFR 121.434. Our current Exemption 10576 A will ex pire on June 30, 2016

.

Section of the Federal Aviation Regulation (FAR) affected:

14 CFR 121.434(c)(1)(ii) Operatin g Experience, Operating Cycles, and Consol idation of Knowledge and Skills in pertinent part:

“In addition, if a qualifying pilot in command is completing initial or upgrade training specified in §121.424, be observed in the performance of prescribed dutie s by an FAA inspector during at least one flight leg which includes a takeoff and a landing.”

Relief Requested :

The petition seeks relief from FAR 121.434(c)(1)(ii) when an FAA Inspector is unavailable to observe a qualifying pilot in command during any of the scheduled operating experience flights subject to the following conditions and limitations:

1. A PSA check pilot or aircrew program designee may conduct a PIC observation in place of an FAA inspector when

a. The Administrator pre

- approves that substitu tion for each observation of a qualifying PIC candidate, thus reserving first right of refusal to the FAA in each

case; b. The qualifying PIC candidate has completed no less than 10 hours of supervised operating experience (OE) and accomplished no fewer than two takeoffs and landings; andc. The qualifying PIC candidate is performing PIC duties during a complete flight leg, including flight deck preparation, before starting engines checklist, taxi, takeoff, all other flight phases, landing, taxi, and securing checklist.

2. Each PSA check pilot or aircrew program designee conducting a PIC observation in place of an FAA Inspector must:

a. Be approved by the Administrator to conduct the observation;

b. Have served as a check pilot or aircrew program designee for PSA for no less than 6 months; and

c. Not supervise the OE or conduct the initial line check for the qualifying PIC candidate being observed.

3. PSA mus t maintain student, check pilot , and aircrew program designee records that demonstrate compliance with the conditions and limitations of the exemption.

Discussion

The FAA has the authority to observe any pilot any time it wishes; and the FAA does so routinely. However, the FAA conducts these routine observations on a schedule the local office

sets without the burden of having to observe a particular pilot on specific flights necessitated by the airline’s training and service schedule. Relieving FAA Inspectors form 121.434(c)(1)(ii) will allow the FAA to focus their efforts on higher priority safety concerns.

PSA Airlin es expects 24 new PIC’s per month to complete training indefinitely due to attrition and addition of new aircraft. Previous experience with this volume of training has had PSA waiting for up to 30 days waiting for an Inspector to observe a new PIC. Because of recent budgetary and travel constraints imposed on the FAA, our Certificate Management Office has struggled at times to provide personnel on a timely basis. Other FSDOs and national resources have been unable to support the volume of work that has been required. Delays in getting observations performed have been costly to the airline resulting in undue economic and operational burdens.

Grant of Original Exemption

PSA was previously granted this exemption on November 14, 2003 (Exemption No. 8175), June 20, 2007 (E xemption No. 8175A), June 29, 2012 (Exemption 10576, Regula tory Docket N o FAA

- 2003

- 16403), and again on May 15, 2014 (Exemption 10576 A , Regulatory Docket No

FAA

- 2003

- 16403)Benefits

Benefits to the FAA, PSA Airlines, and the traveling public remain the same as in the original application.

No Adverse Effect on Safety

Granting or using this proposed exemption would have no adverse effect on safety because:

1. The Check Pilot and Aircrew Program Designees authorized to conduct the observation will be approved by the FAA and will be highly trained and experienced with the particular airplane type.

2. The Check Pilot and Aircrew Program Designees will only be used to fulfill the requirements of 14 CFR 121.434(c)(1)(ii) when a qualified FAA Inspector is not available; and

3. The FAA continues to have the authority to obser ve any pilot at any time during normal line operations

Request To Waive Publication of Petition

Since the FAA has previously granted this exemption to PSA Airlines, and the granting of this exemption is not precedent setting, PSA Airlines requests that p ublication of our petition in the Federal Register be waived in accordance with 14 CFR 11.87(b). Any delay in granting this exemption will have an adverse impact on PSA Airlines’ flight operations.

Summary

In summary, the exemption focuses on the timely and competent completion of the observation flight and better utilization of qualifying pilots in command.

PSA Airlines petitions for an exemption from 14 CFR 121.434(c)(1)(ii), to permit them, at their discretion, when an FAA Inspector is not immediately available; to provide observation of a qualifying PIC when completing initial or upgrade training as specified in 14 CFR 121.434. PSA Airlines will substitute a quali fied and authorized check pilot or aircrew program designee to observe the qualifying pil ot in command in the performance of prescribed duties subject to certain

conditions and limitations.

Sincerely,

Darren M Hall Director of Training

PSA Airlines Inc.