June 27 , 2012

U.S. Department of Transportation

Docket Management System

400 7 th Street, S.W., Plaza 401

Washington, DC 20591

- 0001

Re: Exemption No. 4416 FAA Docket No. FAA

- 2002

- 12831

Ladies/Gentlemen:

In accordance with the Code of Fed eral Regulations, 14 CFR § 11.61 , the Air

Transport Association of America (ATA) dba Airlines for America, petitions on

behalf of its member airlines 1 and other similarly situated Part 1 21 operators f or an

extension of Exemption No. 4416 in FAA Docket No. FAA

- 2002

- 12831. This

exemption is scheduled to expire on September 30, 2012.

Exemption No. 4416 provides relief from Title 14, Code of Federal

Regulati ons ( CFR) § 121.424(a) and (b) and Part 121, Appendix E, Item I(a) to the

extent necessary to permit operators to conduct training and checking of pilots of

airplanes requiring only two flight crewmembers on the required preflight

inspection, both interior and exterior, using approved advan ced pictorial means. 1

This petition for extension does not seek to change the conditions and

limitations of the current exemption (4416N ), which includes training on an actual

aircraft prior to the completion of operating experience required by 14 CFR

§1 21.434.

____________________________________

1 Operator Members : Alaska Airlines, American Airlines, Atlas Air, Inc., Delta Air Lines, Federal Express,

Hawaiian Airlines, JetBlue Airways, Southwest Airlines, United Continental Holdings, Inc.

, United P arcel S ervice, Co., US Airways. Air Canada is an associate member.

1 We note that this petition to extend exemption no. 4416 excludes outdated references to part 61

and §121.424(d) and part 121 appendix F, consistent with FAA’s October 26, 2010 amendment to

this exempt ion. We also note our intent is to request the exact s ame relief granted under earlier

exemption extension requests. If FAA determines this petition does not request the exact same relief

we ask you to contact us immediately and incorporate prior extension requests into this petition.U.S. Department of Transportation

Docket Management System

June 19 , 2012

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 exemption has been in use many years with no known compromise of safety.

The renewal of this exemption is not a controversial issue. A4A, in

accordance with the provisions of 14 CFR § 11. 8 7, requests that a finding of good

cause be made for waiving publication in the Federal Register . A summary of a

previous ATA's petition was published in the Federal Register on May 3, 1993 (58 FR

26379) and only one comment was filed, and it had no objection to an extension of

the exemption. No precedents will be set by gr anting the requested relief. A4 A

therefore requests that publication and the as sociated comment period be waived.

A summary of this petiti on as required by 14 CFR § 11.81(f) is attached.

If any further information or discussion is required, please contact me.

Very truly yours,

/s/

Paul W. Railsback

Director of Operations

Airlines for America

1301 Pennsylvania Ave NW

Suite 1100

Washington, D.C. 20004

(202) 626

- 4012

prailsback@airlines.org

At tachmentAttachment



### SUMMARY OF A4A PETITION

Petitioner : Air Transport Association of America (ATA) dba Airlines for America

Regulation Affected :

14 CFR 121.424(a) and (b)

14 CFR 121 Appendix E Item I(a)

Description of Relief Sought :

The Airlines for America (A4A) petitions on behalf of its member airlines

and other similarly situated Part 121 operators for an extension of

Exemption No. 4416 with no changes to the existing terms. The

exemption permits o perators to conduct training and checking of pilots of

airplanes requiring only two flight crewmembers on the required preflight

inspection, both interior and exterior, using approved advanced pictorial

means.