September 26, 2016 

Docket Management Facility, U.S. Department ofTranspotiation 

1200 New Jersey Ave., S.E. 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

Subject: Supplemental Infotmation Re: Related Aircraft B757/B767 Exemption Request for 

Federal Express Corporation (FAA Docket FAA-2016-1946) 

The following additional infmmation is intended to clatify and respond to comments 

provided by the Air Line Pilots Association, Intemational (ALPA) to FedEx Express' (FedEx) 

original exemption request associated with the Federal Aviation Administration (FAA) Docket 

Number FAA-2016-1946. Further, in accordance with 14 C.F.R. § 11.83, we respectfully 

request that the FAA permit FedEx to use the relief provided in the exemption in intemational 

operations. This is necessary because FedEx currently maintains a Boeing 757/767 pilot 

domicile in Hong Kong, People's Republic of China. In the future, FedEx may also operate the 

Boeing B767 out of the current Boeing 757 only domicile in Cologne, Germany. If the requested 

relief is not extended to these intemational operations, FedEx would need to manage the fleet 

flight crews separately, which will complicate basing and aircraft allocation decision-making, 

and would lead to a less efficient global operating environment. 

Supplemental Information: 

FedEx has operated the Boeing 757 ADV and Boeing 767 LDS for almost three years. 

As pati of our Safety Management System and robust quality assurance programs, we 

continuously monitor performance data of the mixed-fleet operation and have determined, 

contrary to ALP A's suggestions, that the data indicates that dual-qualified pilots have been able 

to maintain recency without performance issues within existing flight schedules. 

FedEx operates the B757/B767 under two separate pilot bid packs, with two separate pay 

scales: B757 only pilots (narrow body pay), and B757/B767 dual-qualified pilots (wide body 

pay). Currently, there are 628 pilots that are qualified to fly only the B757, and 488 pilots are 

dual-qualified on the B757 and B767. It is a natural progression for B757 pilots to upgrade to 
over 169,000 hours on the B767 (69,000 flight segments) and 43,000 hours on the B757 (30,000 

flight segments). We have analyzed ASAP reports filed by dual-qualified pilots for these flight 

segments and the analysis indicates that only 0.003% of all flight segments (approximately 3 

flight segments) have resulted in an ASAP report where recency in flying a particular variant 

was questioned as a possible contributing factor. 2 Based on this data, it is clear that FedEx dualqualified pilots have been able to maintain recency with existing flight schedules in both aircraft 

without issue. 

The FedEx Advanced Qualification Program (AQP) for these dual-qualified pilots is 

based on the FAA-recommended differences training set forth in the Flight Standardization 

Board Report (FSBR) for these related aircraft. FedEx has analyzed the AQP training data for 

1,600 B767 continuing qualification training events in the B757 simulator from January 2013 to 

November 2015. Ofthese events, only 0.37% (approximate 6 events) resulted in an overall 

unsatisfactory rate. This rate is consistent with training performance rates across the FedEx fleet 

and pilot population, further demonstrating that the dual-qualified pilot population is experienced 

and capable of performing in these related aircraft without issue. 

Currently, B767 initial, transition and upgrade training is conducted in only the B757 

flight simulator. The FedEx related aircraft B767 training program currently only consists of a 

B757 baseline course and B767 differences training. FedEx recently purchased one B757 

simulator from American Airlines that is in a "passenger configuration," and is slightly different 

than the FedEx "cargo configuration." This simulator is one of four simulators in the 757/767 

AQP program and is used only in initial training. Further, when used during initial training, it is 

used only for 6 out of the total22 FTD/SIM maneuvers in the curriculum. This simulator is 

scheduled to be upgraded to fully match the FedEx configuration within the next 18-24 months. 

Nevertheless, as evidenced by the AQP data discussed above, dual-qualified pilots have been 

able to demonstrate proficiency within the current program without issue. 

1 This does not include the flying experience gained from flying for regional can·iers, national carriers or military flight time In 

addition, as a general standard, FedEx Express requires all new hire pilot applicants to have at least 1,000 hours of PIC flying 

time. 

2 Contrary to ALP A's assertion regarding reliance on computer-based training to maintain recency, we note that less than 4% of 

all B757/B767 pilots utilized differences Computer Based Training (CBT) to maintain segment currency in accordance with the 

B757/B767 FSBR. The usage for the last 3 months has been 3.4% in May, 5.6% in June, and 2.2% in July. Per the Flight 

Standardization Board Report, pilots must fly 2 legs in each variant every 90 days to maintain segment cmrency. CBT cannot be 

used in consecutive 90 day periods to maintain segment cun·ency. If a pilot loses segment cunency, he must regain it in 

accordance with the FedEx approved AQP program. ALP A also asserts that these pilots will have difficulty remaining HUD 

cunent. This is also not the case, as all B757 advanced aircraft and all B767 LDS aircraft in revenue service are equipped with an 

operational HUD. 
pilots on their company iPads. This guide is not a substitute for procedural guidance contained in 

other company source documents. FedEx regularly reviews and updates the common aircraft 

flight manual for these aircraft as necessary to ensure consistency and accuracy. 

FedEx has been working for the past four years to improve our flight quality assurance 

(QA) program as part of our Safety Management System. The QA program is administered by 

FedEx Flight Operations and inflight QA observations are conducted by a trained team of 

designated first officers on line revenue flights. FedEx has permission from the Line Operations 

Safety Assessments (LOSA) vendor to use the same taxonomies for human factors and en·or 

threat management data collection in the QA observations. This program not only looks to 

identify inefficiencies in the FedEx line haul system but, similar to a LOSA, these QA 

observations collect data to identify potential risks to safety and negative human factors trends. 

The data is used to develop mitigating strategies to address deficiencies. ALP A has agreed to 

this voluntary program and it is part of the 2015 Collective Bargaining Agreement between 

FedEx and ALP A. Over 1,800 flight observations have been performed to date, including 590 

on the B757 and B767. FedEx temporarily halted these observations to finalize negotiations 

regarding the parameters for use with ALP A and refine the iPad app used by the observers. The 

QA program was launched again in August 2016, with observer refresher training, and 

observations resumed again in September 2016. The FedEx QA program is not a substitute for 

LOSA, but will instead serve as an ongoing complement to LOSA. 

Finally, ALP A asserts that FedEx pilots routinely operate in an environment that is prone 

to fatigue and that in reducing the operating experience threshold as requested in the exemption, 

there would be an increase in risk to cargo operations. FedEx actively monitors and manages 

fatigue issues via its fatigue risk management plan. Crew pairings and schedules are regularly 

monitored and adjusted to mitigate effects of fatigue in our operations. FedEx has implemented 

state-of-the art sleeping facilities at hub sites to provide for increased opportunities for rest for 

flight crews. Further, over the past two years, FedEx has developed and implemented an 

automated pilot wakeup call system that monitors potential delays to duty report time due to 

system sort or weather events and automatically adjusts a pilot's wakeup call time at the hub 

sleep facilities. This initiative has increased not only the quantity of sleep on a hub turn, but 

also the quality, as the pilot is not regularly interrupted with status updates, nor prematurely 

called to duty. In light of these robust and comprehensive activities, and the data analysis 

outlined above, we do not view a reduction in operating experience as inherently increasing risk 

to these operations. In light of this information, we respectfully request that the FAA grant the 

exemption request associated with FAA Docket FAA-2016-1946. 
Anne Bechdolt 

Senior Attorney, Regulatory Affairs 

F edEx Express