Leslie

Leslie C. Abbott

Senior Attorney

Southwest Airlines Co.

1901 L Street, NW, Suite 640

Washington, DC 20036

202.263.6285 (phone)

202.263.6291 (fax)

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 SOUTHWEST AIRLINES CO.

 Leslie C. Abbott

 Senior Attorney

 1901 L Street, N.W., Suite 640

 Washington, D.C. 20036

(202) 263-6285

 (202) 263-6291 - Fax

 leslie.abbott@wnco.com

____________________________________________________________________________

August 19, 2013

VIA EMAIL

John M. Allen

Director, Flight Standards Service

Federal Aviation Administration

AFS-1, Flight Standards Service, Room 821

800 Independence Avenue, S.W. 

Washington, DC 20591

john.allen@faa.gov

FILED ELECTRONICALLY

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue

Room W12-140

Washington, DC, 20590

Re: Withdrawal of Petition for Relief from 14 CFR § 121.436(d); Pilot 

Certification and Qualification Requirements for Air Carrier 

Operations; Docket No. FAA-2010-0100

Dear Sir:

On July 23, 2013, Southwest Airlines Co. (“Southwest”) filed a Petition with 

the Federal Aviation Administration (FAA) in this docket requesting limited relief from 

the Final Rule FAA enacted on July 15, 2013 entitled Pilot Certification and 

Qualification Requirements for Air Carrier Operations.

1 Among other things, the 

Final Rule requires that second-in-command (SIC) pilots hold an airline transport 

pilot certificate with an airplane type rating for the aircraft being flown. 

In recognition of the burden that these new requirements place on airline pilot 

training resources, the Final Rule extends the compliance date “for those pilots who 

are employed as second in command in part 121 operations on July 31, 2013” from 

August 1, 2013 until January 1, 2016. Southwest’s Petition requested the same 

extended compliance period for its pilots currently employed in pilot-in-command 

(PIC) positions that will be transitioning to second-in-command positions on different 

aircraft during 2014. Because Southwest has approximately 350 AirTran Boeing 

 

1 The full text of the Final Rule can be found at 78 Fed. Reg. 42324 (July 15, 2013).
Withdrawal of Petition for Relief from 14 CFR 121.436(d) 

August 19, 2013

Page 2

717 PICs that will be transitioning to Boeing 737 SIC positions that do not possess a 

Boeing 737 type rating, this relief would provide the Company with additional time to 

train and type rate these pilots, thereby contributing to a smooth transition process 

and full compliance with the new Final Rule requirements. 

Since the filing of its Petition, Southwest has had subsequent discussions 

with the FAA and the Southwest Certificate Management Office (CMO) in particular. 

Southwest has been reassured that the FAA will work in partnership with Southwest 

and will be able to provide the support, expertise and assistance that Southwest

needs to meet the additional type-rating requirements for its PICs transitioning to 

SIC positions in the timeframe necessary to support its operations. Based on these 

assurances, Southwest hereby withdraws its Petition. 

Respectfully submitted,

___________________

Leslie C. Abbott

cc: Robert Burke (FAA)