SOUTHWEST AIRLINES PILOTS' ASSOCIATION 

August 1, 2016 

Ms. Nia Daniels 

Docket Operations, M-30 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Room W12-140, West Building, Ground Floor 

Washington, DC 20590-0001 

Subject: Southwest Airlines 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 comment period for Carrier's Petition for Exemption (Docket number F AA-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) of Title 14, Code of Federal Regulation (14 CFR). In Exemption 

7132, the Federal Aviation Administration ("FAA") agreed to let Southwest substitute a 

qualified and authorized check airman in lieu of an 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 of granting these exemptions, going back more than 

20 years. The FAA's design is not arbitrary or trivial. It is no coincidence that the FAA 

has had these requirements in place 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 to justify 

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 of flight time and flight 

legs, prior to the observation, is essential to the candidate's chances of success. Simply 

put, reducing the minimum experience requirements would deprive new pilots the time and 

practice needed to settle into the new and challenging role of commanding 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.org 
aircraft, 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 of check airmen. 

Such superficial convenience to the carrier must be contrasted with the heavy cost to the 

PIC candidate and air safety. Eliminating the minimum experience can result in no training 

benefit to the PIC. Short-circuiting a PIC's flying experience can result in no safety benefit 

to the flying public. If anything, Southwest's cost benefit analysis only highlights how it 

prioritizes added flexibility in scheduling check airmen over and above the minimum needs 

for PIC training and the safety of the flying public. SWAP A respectfully submits that 

Southwest should not be allowed this divergence. The cost is simply too great. 

For these reasons, SWAP A opposes Southwest's Petition for Amendment of Exemption 

and requests that it be DENIED in its entirety. 

Respectfully, 

Captain John Weaks 

President, SWAP A 

Brookview Plaza 1 1450 Empire Central Dr., Suite 737 I Dallas, TX 75247 

Phone: 214-350-9237 1 Tollfree: 800-969-7972 I Fax: 214-350-0647 I www.swapa.org