® 

Express 

January 19, 2016 

Docket Management Facility, U.S. Department of Transportation 

1200 New Jersey Ave. , S.E. 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

Legal Department 

3020 Hacks Cross Road 

BuildinR B, 3rd Floor 

Memnhis, TN 3R 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 ("Fed Ex") 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). Fed Ex 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, Fed Ex petitions for an exemption from 14 CFR §121.438(b) to allow pilots 

who are dual qualified in the B757 and B767 aircraft to count the hours flown in both airplanes toward the 

75 hours of flight time required by 14 CFR §121.438(b). 

This requested exemption would grant approval for the pairing of crewmembers with less than 75 hours in 

either the B757 or the 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 meet the 100 hours of PIC time required in 

order to avoid being subject to higher minimums in either aircraft type once the combined flight time 

exceeds 100 hours. Without the exemption, landing minimums must be increased by 100 feet and onehalf mile at Regular, Provisional, and Refueling airports, if the 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 of skills 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 under Airlines for America (A4A) Exemption 5549M, Regulatory Docket No. 

FAA-2000-8434, which allows a new PIC of any A4A member airline, and of any 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 under the conditions stipulated in the exemption. 
Equivalent Level of Safety 

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, Fed Ex 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 of conducting 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 Fed Ex's SMS policy for operating the B757 and B767 as a 

combined fleet. Hazard mitigation is monitored through continued evaluation of training and operational 

data in addition to participation in multiple voluntary safety programs. The combination of voluntary 

programs employed at Fed Ex provides the Administrator with targeted operational oversight through 

continued surveillance with the AQP, SMS, ASAP, LOSA, FOQA, and VDRP processes. These programs 

provide Fed Ex and FAA leadership with regular opportunities for continuous monitoring, critical analysis 

and review of safety trends. The goal of these 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 of these programs is the inclination to proactively seek safety solutions, rather than wait and 

react to an accident or serious incident. The combination of these programs incorporated at Fed Ex 

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, or technology 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 of the 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 Fed Ex 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 of complexity 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 8757 ADV 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 equivalent to 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, Fed Ex will need to manage 

the fleet aircrews separately, which will complicate basing and aircraft allocation decisions. Some of the 

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 of safety while maintaining the historical levels of efficiency, 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, 

~~ rk Hansen 

Counsel - Regulatory Affairs 

FedEx Express 

1 This petition does not seek relief for the 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.