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# Express January 19, 2016 Docket Management Facility, U
.S
. Department ofTransportation 1200 New Jersey Ave. , S.E. West Building Ground Floor Room W12-140 Washington, DC 20590 L egal Department 3020 Hacks Cross Roa d BuildinR B, 3rd Floor Memnhis,TN3R I75 liS

Subject: Related Aircraft B757/B767 Exemption Requests for Federal Express Corporation References: Title 14 CFR §121.438 Pilot Operating Limitations and Pairing Requirements Title 14 CFR §121.652 Landing Weather Minimum: IFR: All Certificate Holders Federal Express Corporation ("FedEx") has been granted related aircraft designations for the Boeing 757 (Base Aircraft) and Boeing 767 (Related Aircraft) and Boeing 767 (Base Aircraft) and Boeing 757 (Related Aircraft) in accordance with 14 CFR §121.418(b)
. FedEx petitions the Administrator for exemptions from the requirements of 14 CFR §§ 121.438 (crew pairing) and 121.652 (high minimum landing requirements). Related Aircraft Exemption for Crew Pairing Pursuant to 14 CFR §11.81, FedEx petitions for an exemption from 14 CFR §121.438(b) to allow pilots who are dual qualified in the B757 and B767 aircraftto count the hours flown in both airplanes toward the 75 hours offlight time required by 14 CFR §121.438(b)
. This requested exemption would grant approval for the pairing ofcrewmembers with less than 75 hours in either the B757 orthe B767, but would require the pilot in command (PIC) or second in command to have at least 75 hours of combined line operating flight time in the B757 and the B767 for the purposes of crew pairing requirements
. Related Aircraft Exemption for High Minimums Pursuant to 14 CFR §11.81, FedEx petitions for an exemption from 14 CFR §121
.652(a), to combine PIC flight times logged on either the B757 or B767 (or both) to meetthe 100 hours of PIC time required in order to avoid being subjectto higher minimums in either aircraft type once the combined flight time exceeds 100 hours. Withoutthe exemption, landing minimums must be increased by 100 feet and onehalf mile at Regular, Provisional,and Refueling airports, ifthe PIC has not served at least 100 hours as PIC in the specific airplane type in Part 121 operations
. FedEx was previously granted a deviation from 14 CFR §121.434(g) that permits hours from both the B757 and B767 to count towards the 100 hour requirement for consolidation ofskills and knowledge. By stipulating that a specific number of hours be achieved in each type, the deviation requirements ensure familiarization with both types during consolidation of knowledge and skills
. FedEx is currently operating underAirlines for America (A4A) Exemption 5549M, Regulatory Docket No. FAA-2000-8434, which allows a new PIC ofany A4A member airline, and ofany other similarly situated Part 121 certificate holder subject to higher landing weather minimum requirements, to operate to the normal, lower Category I and Category II minimums underthe conditions stipulated in the exemption
.Equivalent Level ofSafety On March 9, 2015, the FAA issued National Policy Notice 8900
.286 directing principal operations inspectors (POl) to identify and correct Part 121 training programs that include credit between airplanes with different type certificates without (1) approved related aircraft designations and (2) approved aircraft related aircraft deviations, as required, from the FAA Headquarters (AFS-200, Air Transportation Division). In accordance with this policy, FedEx requested and received Administrator approval of Boeing 757 (Base Aircraft) and Boeing 767 (Related Aircraft) and Boeing B767 (Base Aircraft) and Boeing B757 (Related Aircraft) for the purposes ofconducting related aircraft differences training and to pursue allowable flight crew training credits between airplanes with designated related aircraft approval. The B757/B767 common characteristics and type rating provide additional basis for these exemptions. Safety risk management has been applied per FedEx's SMS policy for operating the B757 and B767 as a combined fleet. Hazard mitigation is monitored through continued evaluation oftraining and operational data in addition to participation in multiple voluntary safety programs. The combination ofvoluntary programs employed at FedEx provides the Administrator with targeted operational oversight through continued surveillance with the AQP, SMS, ASAP, LOSA, FOQA, and VDRP processes. These programs provide FedEx and FAA leadership with regular opportunities for continuous monitoring, critical analysis and review ofsafety trends. The goal ofthese programs is to identify safety-related problems within an air carrier's operation, including operational and procedural errors, and to develop corrective actions
.The key to all ofthese programs is the inclination to proactively seek safety solutions, rather than wait and react to an accident or serious incident. The combination ofthese programs incorporated at FedEx promotes safety across the industry and mitigates risk
. FedEx analyzes data from these safety programs and any problematic issues are identified and resolved using applicable risk mitigation, whether through training, operating procedures, sub-fleet methodology, ortechnology solutions. Reasons Exemptions are Requested These requests are based on a Safety Risk Assessment and a review of FedEx AQP, FOQA, ASAP, SMS, Pilot Ops Reporting and safety data covering over 115,000 flight hours and 50,000 flights with no issues combining B757 and B767 line operating flight time
. FedEx Operating Experience (OE) (B757) and Supervised Line Flying (SLF) (B767) are conducted in both the B757 and B767 aircraft. FedEx B767 SLF is conducted using 4 flight segments, two more than recommended by the Flight Standardization Board Report (Rev 9)
. (Two ofthe required flight segments may be satisfied in the B767 Level B simulator, as approved in the AFS-200 granted deviation from 14 CFR §121.434(c)(3)(i),dated July 9, 2015
.) The FedEx Safety Risk Assessment finds, based on operating experience, no significant risk associated with operating the two types together
. Specifically: • The FedEx AQP training program adequately addresses the differences between the two aircraft via differences training and SLF as recommended by the FSBR Master Differences Requirements (MDR) Tables and Operator Differences Requirements (ODR) tables
. There have been no significant findings that would indicate that the differences result in confusion of requirements or an excessive level ofcomplexity for pilots to adjust to or retain important differences information. • A common Aircraft Flight Manual is used for both types for limitations and flight crew procedures. • Separate Aircraft Systems Manuals and Quick Reference Handbooks are used for each type but the organization and the methodology for use are identical. • Boeing and the Aircraft Evaluation Group have determined that the flight characteristics of all variants are the same or equivalent.• Design differences in the 8757ADV and 8767LDS results in the number of display panels to be different (8757-6 flat panel displays and 8767-3 flat panel displays), but the flight information and symbology is displayed in the same location and similar format. 1
• The Flight Management Systems are near identical and the automation is procedurally the same. This results in the crews being highly familiar with the flight characteristics of both aircraft
. Therefore, the combined flight time from the 8757 and the 8767 is equivalentto the 100 hour requirement with nondesignated related fleets. Granting the Exemptions is in the Public Interest The 8757 and 8767 with substantially similar cockpits have been safely and efficiently operated as a combined fleet for decades. Without the relief afforded by these exemptions, FedEx will need to manage the fleet aircrews separately, which will complicate basing and aircraft allocation decisions
. Some ofthe benefits gained by operating the 8757 and 8767 with substantially similar cockpits as a combined fleet include reductions in pilot training time and overall pilot manning, and combined reserves and lower support personnel costs. These benefits can be accomplished without diminishing safety,while resulting in a more efficient, flexible and dependable global linehaul system . Continuing to obtain the equivalent level ofsafety while maintaining the historical levels ofefficiency, flexibility and cost furthers global business and is in the public interest. For questions or comments regarding this exemption petition, please contact Kevin Keilty at Kjkeilty@fedex
.com or at (901) 224-5547
. Respectfully submitted,



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rk Hansen Counsel - Regulatory Affairs FedEx Express

1This petition does not seek relief forthe 8767 "classic flight deck" aircraft with "steam gauge" cockpits, which will continue to be crewed separately consistent with 

### §§ 121.438(b) and 121
.652
.

### SUMMARY OF FEDERAL EXPRESS CORPORATION PETITION FOR EXEMPTIONS Petitioner: Federal Express Corporation, dba FedEx Express Regulations Affected: 14 CFR §121.438(b) and 14 CFR §121.652(a) Description of Relief Sought: Federal Express requests an exemption to use the combined line operating flight time from the Boeing 757 and Boeing 767 for the purposes of satisfying the 75-hour line operating flight time requirement for crew pairing. In addition, Federal Express requests an exemption to combine the Pilot in Command flight time from either the B757 or B767, or both, to satisfy the requirement of 100 hours of PIC operational flight time, in order to operate to the normal Category I and Category II minimums.