June 27, 2012

U.S. Department of Transportation 

Docket Management System

400 7th 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 Federal Regulations, 14 CFR § 11.61, the Air 

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

behalf of its member airlines1 and other similarly situated Part 121 operators for 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 

Regulations (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 advanced 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 

§121.434. 

____________________________________

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 Parcel Service, 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1 We note that this petition to extend exemption no. 4416 excludes outdated references to part 61 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 exemption. We also note our intent is to request the exact same 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 § 11.87, 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 granting the requested relief. A4A 

therefore requests that publication and the associated comment period be waived.

A summary of this petition 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

Attachment
Attachment

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 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 advanced pictorial 

means.