UNITED~ 1). 

CORPORATE QUALITY ASSURANCE 

October 13, 2015 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, 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 Dispatcher duty time limitations of 14 CFR §§ 

121.465(b)(1) and (2) to provide relief in limited, prescribed circumstances. 

Applicable regulation 

14 CFR § 121.465 provides duty time limitations for Aircraft Dispatchers in domestic 

or flag operations. Sub-paragraph (b)(1) prohibits a certificate holder from scheduling 

an Aircraft Dispatcher for more than 10 consecutive hours of duty. Paragraph (b)(2) 

stipulates that an Aircraft Dispatcher, who is scheduled for more than 1 0 hours of 

duty in 24 consecutive hours, must be provided a rest period of at least 8 hours at or 

before the end of the 10 hours of duty. 

Exempted duty assignment 

For the purposes of this exemption petition, an Aircraft Dispatcher is defined as a 

certificated airman who exercises operational control and joint authority over 

initiating, conducting, or terminating a flight. 

As part of United's FAA-approved training program, Aircraft Dispatchers must 

satisfactorily complete an operating familiarization that fulfills the requirements of§ 

121.463, to obtain and retain qualification to perform dispatch functions for flights in 

any areas of en route operation that are authorized by our Operations Specifications. 

Due to the length of some flight segments, the operating familiarization duty period 

may exceed 10 consecutive hours. 

United is seeking relief from application of the §121.465 limitations to these operating 

familiarization duty periods in order to enable the Aircraft Dispatcher to complete the 

entire assignment. 

United Airlines- Corporate Quality Assurance- WHQQA- 233 S. Wacker Drive, Floor 16 - Chicago, IL 60606 
Conditions and limitations 

United stipulates that the requested exemption from the limitations in §121.465 will 

only be applied to operating familiarization activities for which the duty assignment 

exceeds 10 hours. United further stipulates that the exemption will not be applied to 

classroom or dispatch desk-related training, nor will it be applied to performance of 

traditional Aircraft Dispatcher duties of flight planning, flight release, exercise of 

operational control, or flight monitoring. 

In addition, Aircraft Dispatchers covered under the requested exemption will be 

provided a rest period of at least 8 hours prior to 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 of the following: 

• This exemption to the duty time limitations of§ 121.465 meets the published 

guidance of the FAA Aviation Rulemaking Advisory Committee's Training and 

Qualification Issue Area, Air Carrier Working Group Task 3- Crew Resource 

Management. 

• By limiting the application of the exemption to training scenarios involving 

operating familiarization, there is no flight safety risk associated with the 

extended duty period. 

• For an operating familiarization flight segment that exceeds 8 hours, a seat in 

the aircraft cabin is blocked for the Aircraft Dispatcher's use as a rest area. 

• When scheduled for a duty period that exceeds 10 hours under the exemption, 

the Aircraft Dispatcher will be provided a rest period of at least 8 hours prior to 

the next duty assignment. 

Equivalent level of safety 

United Airlines' Network Operations has analyzed the safety and compliance risks 

associated with this exemption and determined it provides for a level of safety that 

meets or exceeds the level of safety currently provided for in the applicable 

regulation. There is no impact on flight safety during the period of the operating 

familiarization because the Aircraft Dispatcher is observing flight operations, not 

dispatching aircraft. An equivalent level of safety is established for post-operating 

familiarization dispatcher duties by requiring a rest period of at least 8 hours after an 

operating familiarization duty period that exceeds 10 hours and before assumption of 

dispatcher duties. The exemption's requirement to provide a rest period of at 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 

familiar with 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 under 49 U.S.C., 

§ 40123 and 14 CFR part 193 
Implementation 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 monitor operating familiarization and application of the 

exemption through its SMS processes. 

Summary if published in the Federal Register 

United Airlines, Inc. petitions for exemption from the duty time limitations of 14 § CFR 

121.465 so as to allow scheduling Aircraft Dispatchers to perform operating 

familiarization duty periods in excess of 10 consecutive hours, in order to familiarize 

Aircraft Dispatchers with long-range flights. Aircraft Dispatchers covered under the 

requested exemption will be provided a rest period of at least 8 hours prior to their 

next duty assignment. 

In consideration of the foregoing, United Airlines respectfully requests approval of this 

petition. Questions regarding this petition may be directed to Managing Director, 

Network Operations Center (NOC) at jim.deyoung@united.com. 

Michael Quiello 

Vice President, Corporate Safety 

Part 119 Director of Safety 

Cc: Tracy Lee 

Laura Allen 

Jim Conneely 

J.J. DeGiovanni 

Jim DeYoung 

United Airlines- Corporate Quality Assurance- WHQQA- 233 S Wacker Drive. Chicago, IL 60606 3 

WARNING: The Information in this Document is Protected from Disclosure under 49 U S.C., 

§ 40123 and 14 CFR part 193