MD 235 June 29

, 201 5

U .S. Department of Transportation

Docket Operations, M

- 30

West Building G round F loor, Room W12

- 140

1200 New Jersey Avenue, SE

Washington, DC 20590

Subject: Renewal of Exemption Number 6853 F

- 14 CFR § 121.317

- Control of Passenger Information



## . Reference: 1) FAA i ssue Paper “No S moking” Limitations in the passenger compartment

- from the

Transport Airplane Directorate

- Aircraft Certification Service

2) Exemption 6853 (original issue) Docket Number 29448

3) Exemption 6853 B (second extension) Docket Number FAA

- 2000

- 8153

4) Exemption 6853C (third extension) Docket Number FAA

- 2000

- 8153

5) Exemption 6853D (fourth extension) Docket Number FAA

- 2000

- 8153

6) Exemption 6853E (fi f th extension) Docket Number FAA

- 2000

- 8153

7 ) Exemption 6853 F ( sixth extension) Docket Number FAA

- 2000

- 8153

Dear Sir or Madam:

American Airlines' Exemption number 6853 F , which permits American Airlines to operate our Boeing 737

and 777 aircraft with the "No Smoking" signs always illuminated

, terminates on August 31, 201 5

. American Airlines has had no negative or detrimental circumstance since the original issue and respectfully

requests this exemption be renewed and to extend it to all of American Airlines’ fleets

. The reason for

extending this exemption to the other fleets is that modifications are replacing the lighted signs with

placards. Listed below are the rules from which the relief is requested under 14 CFR § 11.25.

A Renewal to Exemption number 6853 F is sought that applies to:

14 CFR § 121.317(a) " ...no person may operate an airplane unless it is equipped with passenger

information signs that meet the requirements of §25.791...” and “ t he sign must be constructed so

that the crew member can t urn them “ on ” and “ off."

The Renewal exemption would:

Permit American Airlines to operate its fleets

, in the delivered condition from a Type

Certificate Holder or modified version to be in the condition new fleets are delivered

. 14 CFR

§ 25.791 (a.) states : “ If smoking is to be prohibited, there must be at least one placard so stating

that is legible to each person seated in the cabin.” 14 CFR § 121.317 (a.) states : passenger

information signs “..

. mus t be constructed so that crew members can turn them “ on ” and “ off."

With the "No Smokin g Signs" hardwired "on" or a placard that is legible to each person seated

in the cabin ; 14 CFR § 121.317 is no longer relevant with respect to the " No Smokin g Signs"

needed to be turned “ on ” or “ off ” by the crew

, since American Airlines does not allow smoking on

any of its flights.

The referenced FAA Issue Paper indicates that a continuously lighted sign meets the requirements of a

placard. Furthermore

, the FAA I ssue P aper advises operators with the "No Smokin g Signs" hardwired to

the "on" configuration to petition for an exemption to 14 CFR § 121.317.MD 235 Docket Management System

Renewal Exemption No. 6853E

June 29 , 201 5

- Page 2

R ather than modifying each aircraft allowing a crew to turn the "No Smoking Signs" "on" and "off ” to

comply with 14 CFR § 121.317 (a) , we suggest the "No Smoking Signs" being continuously illuminated or a

permanent placard that is legible to each person seated in the cabin meets or exceeds the spirit and intent

of the regulation a nd is an equivalent level of safety

.

This renewal exemption will continue to allow American Airlines to operate aircraft, in revenue service, with

the "No Smoking Signs" continuously illuminated and being incapable of having the "No Smoking Signs"

extinguished.

Renewing this exemption would be in the public interest in that:

1) There would be greater assurance that the: "No Smoking Signs" would always be illuminated

and legible to each person seated in the cabin.

2) Passengers are accustomed to s eeing the "No Smoking Signs" illuminated and understand the

meaning.

3) By allowing the "No Smoking Signs" to be hardwired to the "on" position

, it will ensure the

avoidance of unnecessary modification cos t that would be passed on to the traveling public in the

price of the ticket.

4) American Airlines currently conducts revenue service using this exemption and a denial

of this renewal would clearly be detriment to the flying public as well as American Ai rlines.

Renewing this exemption will not adversely affect s afety in that the "No Smoking Signs" will be illuminated at

all times or a placard that is legible to each person seated in the cabin

. U nder no circumstan c es does

American Airlines allow smoking on any of o ur flights; therefore, there is no need to be able t o switch the "No

Smoking Sign" from "on" to "off”

.

Questions or comments regarding this petition may be directed to Michael Keller

, Lead Engineer, Compliance

Engineering at (918) 292

- 2 416

.

Sincerely,

Mark Loyd

Managing Director

Regulatory & Engineering Support

ML/MJK