May 21 , 2012

Federal Aviation Administration U.S. Department of Transportation, Docket Operations, West Building Ground Floor,

Room W12

– 140, 1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Petition for Exemption

Dear Sir or Madam:

Th e Air Transport Association of America, Inc

. , dba Airlines for America, on behalf of member Part 121 air carriers, petitions pursuant to 14 CFR s ections 11.61 and 11.63 for an exemption from the regulatory requirements of 14 CFR sections 61.39(a) and (b) a nd 61.157(b) and (c) with regards to applicants for (i) an aircraft type rating to be added to an airline transport pilot certificate or (ii) a type rating to be concurrently completed with an airline transport pilot certificate.

Currently, sections 61. 39(b)( 1)(i) and (ii) provide for an exception from the requirements of section 61.39(a)(1) insofar as it allows the use of an expired knowledge test so long as the applicant is an employee of a Part 121, 125, or 135 certificate holder

and “has satisfactori ly accomplished that operator’s approved pilot in command aircraft qualification training program and qualification training requirements for the certificate and rating sought.” See s ection 61.39(b). In addition, section 61.157(c) provides for an exception f

rom the requirements of section 61.157(b). Thus, an aircraft type rating applicant is exempt from ground and flight training, as well as practical test, on the areas of operation under 61.157(e) so long as the applicant is an employee of a Part 121 or 135 certificate holder and “presents a training record that shows completion of the certificate holder’s approved pilot in command training program for the aircraft type rating.” See

s ection 61.157(c).

In contemplation of the fast

- approaching August 2, 2013 d eadline for compliance with the statutory requirement contained in the Airline Safety and Federal Aviation Administration Extension Act of 2010 (the “Act”) that all Part 121 flightcrew members must hold an ATP certificate, A4A requests that participants in an approved second in command training program also be able to take advantage of the exceptions in sections 61.39(b) and 61.157(c) , upon presenting a training record showing completion of the certificate holder’s approved second in command training progr am for the aircraft type rating. As a condition for accepting this relief, A4A member air carriers will agree not toallow their SICs to operate as PICs under their new ATP certificate until they have

completed the air carrier’s approved PIC training prog ram. To the extent necessary to

receive the benefits of the above

- mentioned requests, A4A also seeks a parallel exemption under FAR 61.51.

Approval of the exemption requested herein is in the public interest because it seeks to utilize existing regulato ry exceptions to facilitate compliance with the statutory requirements of the Act and reduce unnecessary burdens . The FAA has acknowledged in Notice N8900.184 that delays in the ATP certification process of SICs “could pose significant challenges” to air carriers and the FAA itself due to the number of SICs who currently only h old a commercial pilot certificate and the training hours and certification activities required to provide ATP certification. Granting this narrowly tailored exemption request w ill provide an equivalent level of safety because it would extend safe,

well

- t ested existing regulatory exceptions to participants in an approved second in command training program. This exemption would also facilitate carrier compliance

with the Act, reduce the burdens identified in Notice N8900.184, and alleviate some air

car riers’ concerns about meeting the compliance deadline without compromising aviation safety.

A4A respectfully requests that the exemption be granted expeditiously. A delay in granting this exemption would result in hardship to Part 121 air carriers and their customers inasmuch as otherwise qualified SICs would not be able to perform their duties, causing a loss of revenue to airlines that would ultimately affect the price of air transportation.

Please do not hesitate to contact me if you have any ques tions or require additional information in order to act on this petition.

Respectfully submitted,

/S/

Paul W. Railsback Director, Operations

Airlines for America 1301 Pennsylvania Avenue

Suite 1100 Washington, DC 20004 (202) 626

- 4012 prailsback@airlines.org