AFS-16-13061-E

September 20, 2016

 Exemption No. 9755D

 Regulatory Docket No. FAA-2006-24996

Ms. Anne Shaw

Manager of Flight Operations Regulatory Compliance and Certificate Management

Alaska Airlines, Inc.

P.O. Box 68900

Seattle, WA 98168

Dear Ms. Shaw:

This letter is to inform you that we have granted your petition to extend Exemption No. 9755,

as amended. It explains the basis for our decision, describes its effect, and lists the conditions 

and limitations.

The Basis for Our Decision

By letter dated July 5, 2016, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Alaska Airlines, Inc. (Alaska), for an extension of Exemption No. 9755, as 

amended. That exemption from § 121.434(c)(1)(ii) of Title 14, Code of Federal Regulations 

(14 CFR) allows Alaska to substitute a qualified and authorized check airman or aircrew 

program designee for an FAA inspector to observe a qualifying pilot in command (PIC) who 

is completing initial or upgrade training specified in § 121.424 during at least one flight leg 

that includes a takeoff and a landing.

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption. In 

response to a request for clarification from the FAA dated July 20, 2016, Alaska confirmed 

that it requests to use the exemption outside of U.S. airspace because a significant portion of 

its daily operation involves flights to Hawaii and Alaska that cross international airspace. The 

FAA has amended the conditions and limitations to clarify that Alaska may operate outside of 

the United States under this exemption, unless otherwise prohibited by a foreign country.
2

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to Alaska.

Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 9755, as 

amended, remains valid with respect to this exemption and is in the public interest. Therefore, 

under the authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, Alaska Airlines, Inc. is granted an extension to its 

exemption from § 121.434(c)(1)(ii) that allows Alaska to substitute a qualified and authorized 

check airman or aircrew program designee for an FAA inspector to observe a qualifying PIC 

who is completing initial or upgrade training specified in § 121.424 during at least one flight 

leg that includes a takeoff and a landing, subject to the following conditions and limitations.

Conditions and Limitations 

1. An Alaska check airman or aircrew program designee may conduct a 

PIC observation in place of an FAA inspector when––

a. The Administrator preapproves that substitution for each observation of a 

qualifying PIC candidate, thus reserving first right of refusal to the FAA in 

each case. Alaska, therefore, must contact an appropriate FAA office, in each 

instance, before substituting that check airman or aircrew program designee;

b. The qualifying PIC candidate has completed no less than 10 hours of 

supervised operating experience (OE) and accomplished no fewer than two 

takeoffs and landings; and

c. The qualifying PIC candidate is performing PIC duties during a complete flight 

leg, including flightdeck preparation, before starting engines checklist, taxi, 

takeoff, all other flight phases, landing, taxi, and securing checklist.

2. Each Alaska check airman or aircrew program designee conducting a PIC 

observation in place of an FAA inspector must––

a. Be approved by the Administrator to conduct the observation;

b. Have served as a check airman or aircrew program designee for Alaska for no 

less than 6 months;

c. Not supervise the OE or conduct the initial line check for the qualifying 

PIC candidate being observed; and

d. Conduct the observation from the observer seat only (i.e. not a required 

flightcrew member seat).
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Alaska must maintain student, check airman, and aircrew program designee records that 

demonstrate compliance with the conditions and limitations of this exemption.

3. Alaska may operate outside of the United States under this exemption, unless 

otherwise prohibited by a foreign country.

The Effect of Our Decision

Our decision extends the termination date to September 30, 2019, unless sooner superseded or 

rescinded. 

Sincerely,

/s/

John S. Duncan

Director, Flight Standard Services