## UNITED~ 1). CORPORATE QUALITY ASSURANCE
October 13, 2015

Docket Management Facility U.S. Department ofTransportation 1200 NewJerseyAvenue, SE West Building Ground Floor Room W12-140 Washington DC 20591

Re: Petition for Exemption Aircraft Dispatcher Duty Time Limitations

United Airlines, Inc. ("United") (Air Operators Certificate #CALA014) hereby petitions FAA for an exemption from the Aircraft Dispatcherdutytime limitations of 14 CFR §§ 121.465(b)(1) and (2) to provide relief in limited, prescribed circumstances. Applicable regulation 14 CFR § 121.465 provides dutytime limitations forAircraft Dispatchers in domestic orflag operations. Sub-paragraph (b)(1) prohibits a certificate holderfrom scheduling an Aircraft Dispatcherfor more than 10 consecutive hours ofduty. Paragraph (b)(2) stipulates that an Aircraft Dispatcher, who is scheduled for more than 10 hours of duty in 24 consecutive hours, must be provided a rest period ofat least 8 hours at or before the end ofthe 10 hours ofduty. Exempted duty assignment Forthe purposes ofthis exemption petition, an Aircraft Dispatcher is defined as a certificated airman who exercises operational control andjointauthority over initiating, conducting, orterminating aflight.
As part of United's FAA-approved training program, Aircraft Dispatchers must satisfactorily complete an operating familiarization thatfulfills the requirements of§ 121.463, to obtain and retain qualification to perform dispatch functions forflights in any areas ofenroute operation that are authorized by our Operations Specifications. Due to the length ofsome flight segments, the operating familiarization duty period may exceed 10 consecutive hours. United is seeking relieffrom application ofthe §121.465 limitations to these operating familiarization duty periods in orderto enable the Aircraft Dispatcherto complete the entire assignment.

United Airlines- Corporate QualityAssurance- WHQQA- 233 S. Wacker Drive, Floor 16

- Chicago, IL 60606Conditions and limitations United stipulates that the requested exemption from the limitations in §121.465 will only be applied to operating familiarization activitiesforwhich the duty assignment exceeds 10 hours. United further stipulates that the exemption will not be applied to classroom ordispatch desk-related training, norwill it be applied to performance of traditional Aircraft Dispatcherduties offlight planning, flight release, exercise of operational control, orflight monitoring.
In addition, Aircraft Dispatchers covered underthe requested exemption will be provided a rest period ofat least 8 hours priorto their next duty assignment. Safety Risk Assessment Using United's SMS risk matrix protocol, a risk ranking of 1A-Limited has been assigned in consideration ofthe following: • This exemption to the dutytime limitations of§ 121.465 meets the published guidance ofthe FAAAviation Rulemaking Advisory Committee's Training and Qualification IssueArea, 

### AirCarrier Working Group Task 3- CrewResource Management. • By limiting the application ofthe exemption to training scenarios involving operating familiarization, there is no flight safety risk associated with the extended duty period. • Foran operating familiarization flight segmentthat exceeds 8 hours, a seat in the aircraft cabin is blocked forthe Aircraft Dispatcher's use as a rest area. • When scheduled for a duty period that exceeds 10 hours underthe exemption, the Aircraft Dispatcherwill be provided a rest period ofat least 8 hours priorto the next duty assignment. Equivalent level ofsafety United Airlines' Network Operations has analyzed the safety and compliance risks associated with this exemption and determined it provides for a level ofsafetythat meets orexceeds the level ofsafety currently provided for in the applicable regulation. There is no impact on flight safety during the period ofthe operating familiarization becausethe Aircraft Dispatcher is observing flight operations, not dispatching aircraft. An equivalent level ofsafety is established for post-operating familiarization dispatcherduties by requiring a rest period ofat least 8 hours afteran operating familiarization duty period that exceeds 10 hours and before assumption of dispatcher duties. The exemption's requirementto provide a rest period ofat least 8 hours is equivalent (in fact, identical) to the rest period requirement currently provided for in the applicable regulation. Granting the exemption is in the public interest This exemption advances aviation safety. By its terms, dispatchers can become familiarwith long-range operations and be fit for subsequent duty as a dispatcher. The exemption thus promotes dispatcher proficiency and protects against dispatcher fatigue, both clearly in the public interest.

United Airlines- Corporate Quality Assurance- WHQQA

- 233 S. Wacker Drive, Chicago, IL 60606 2 WARNING: The Information in this Document is Protected from Disclosure under49 U.S.C., § 40123 and 14 CFR part 193Implementation strategy Once the exemption is granted, Network Operations will implement its provisions, conditions and limitations by: • Documenting the exemption's application, conditions, and limitations in the Dispatch Operations Manual, Dispatch Scheduling Reference and Procedure Manual, and the Dispatch Training Manual. • Fully brief Dispatch leadership and PAFCA safety representatives regarding the exemption's application, conditions, and limitations. • Network Operations will monitoroperating familiarization and application ofthe exemption through its SMS processes. Summary ifpublished in the Federal Register United Airlines, Inc. petitions for exemption from the dutytime limitations of 14 

### § CFR 121.465 so as to allowscheduling Aircraft Dispatchers to perform operating familiarization duty periods in excess of 10 consecutive hours, in orderto familiarize Aircraft Dispatchers with long-rangeflights. Aircraft Dispatchers covered underthe requested exemption will be provided a rest period ofat least 8 hours priorto their next duty assignment.

In consideration ofthe foregoing, United Airlines respectfully requests approval ofthis petition. Questions regarding this petition may be directed to Managing Director, Network Operations Center (NOC) atjim.deyoung@united.com.

Michael Quiello Vice President, Corporate Safety Part 119 Directorof Safety Cc: Tracy Lee Laura Allen Jim Conneely J.J. DeGiovanni Jim DeYoung

United Airlines- Corporate QualityAssurance- WHQQA- 233 S Wacker Drive. Chicago, IL 60606 3 WARNING: The Information in this Document is Protected from Disclosure under49 U S.C., § 40123 and 14 CFR part 193