SOUTHWEST AIRLINES PILOTS'ASSOCIATION August 1, 2016

Ms. NiaDaniels Docket Operations, M-30 U.S. Department ofTransportation 1200 NewJersey Avenue, SE Room W12-140, West Building, Ground Floor Washington, DC 20590-0001 Subject: SouthwestAirlines Pilots' Association's Objection to Southwest Airlines' Petition for Amendment of Exemption No. 7132 (Docket number FAA-2002-11485).
The Southwest Airlines Pilots' Association ("SW APA") represents approximately 8,300 pilots employed by Southwest Airlines Co. ("Southwest" or "Carrier"). In responding to the open commentperiod for Carrier'sPetitionfor Exemption (DocketnumberFAA-2002- 11485) we offer the following objections.

On February 22, 2016, Southwest was granted Exemption 7132, which was an exemption to 121.434(c)(1)(11) ofTitle 14, Code ofFederal Regulation (14 CFR). In Exemption 7132, the Federal Aviation Administration ("FAA") agreed to let Southwest substitute a qualified and authorized check airman in lieu ofan FAA inspector, and when authorized by the Administrator, to observe a new pilot upgrading to pilot in command ("PIC"). Therein, the FAA also set certain mandatory minimum experience. Specifically, the qualifying PIC candidate must have no less than 10 hours of supervised operational experience ("OE") and must have accomplished no fewer than two takeoffs and landings prior to the observation permitted by the exemption. These minimum requirements have been put in place by the FAA, as part ofgranting these exemptions, going back more than 20 years. The FAA's design is not arbitrary or trivial. Itis no coincidence that the FAA has had these requirements inplace without incident for such an extended period.
Now, Southwest seeks to depart from the FAA's well-established minimum experience requirement. This pilot group strongly objects. In its Petition, Southwest fails tojustify the need for this variance. Any benefit to the carrier is gravely outweighed by the cost to the PIC candidate and air safety in general.
The transition from first officer to captain, or PIC, is an in-depth process requiring extensive training. Ensuring the PIC candidate a minimal amount offlight time and flight legs, prior to the observation, is essential to the candidate's chances ofsuccess. Simply put, reducingthe minimum experiencerequirements woulddeprive newpilotsthe time and practice needed to settle into the new and challenging role ofcommanding not only the

Brookview Plaza 11450 Empire Central Dr., Suite 737 I Dallas, TX 7524i Phone: 214-350-9237 I Tollfree: 800-969-7972 I Fax: 214-350-0647 I www.swapa.orgaircraft, but the crew, as well as all associated responsibilities, before being observed. In exchange for this sacrifice, there is no arguable benefit, except to give Southwest added flexibly in its scheduling ofcheck airmen.

Such superficial convenience to the carrier must be contrasted with the heavy cost to the PIC candidate and air safety. Eliminatingtheminimumexperience canresult inno training benefitto the PIC. Short-circuiting a PIC'sflying experience canresult inno safetybenefit to the flying public. Ifanything, Southwest's cost benefit analysis only highlights how it prioritizes added flexibility in schedulingcheckairmenoverand abovethe minimumneeds for PIC training and the safety ofthe flying public. SWAPA respectfully submits that Southwest should not be allowed this divergence. The cost is simplytoo great.

For these reasons, SWAPA opposes Southwest's Petition for Amendment ofExemption and requests that itbe DENIED in its entirety. Respectfully,

Captain John Weaks President, SWAPA

Brookview Plaza 1 1450 Empire Central Dr., Suite 737 I Dallas, TX 75247 Phone: 214-350-9237 1Tollfree: 800-969-7972 I Fax: 214-350-0647 I www.swapa.org