Mr. Pendergrass,

In response to your questions below regarding American Airlines request for an exemption to the CPDLC 

datalink recorder mandate, American Airlines would like to submit the following answers / clarifying 

information:

I ask that you please provide the following information. Specifically:

1) Why does American Airlines require the petition? That is to say, is AA unable to comply with 

regulations without being granted an exemption?

American Airlines requires the exemption as the hardware we need to be compliant, the revised 

datalink recorders have been ordered but are not yet available. Once parts are available, AAL is 

required to initiate an Engineering Change Order (ECO) and then schedule the dock time and 

space for this equipment to be installed. Due to the size of American’s operation and the 

stringent aircraft scheduling, this is impossible to do in a brief time frame and many of these 

aircraft will have the FANS capabilities activated and available for use. If the exemption cannot 

be grated, then these aircraft will have FANS / CPDLC installed and then deactivated with the 

associated lower safety level.

2) How does granting the petition serve the public interest, specifically?

Granting the Exemption Would be in the Public Interest

FAA has invested significant public funds and time readying their systems for this important step 

forward in the NextGen effort. Granting this Exemption assures that FAA’s investment has been 

both timely and usable by operators, and allows it to maintain its NextGen schedule. The limited 

time frame assures FAA that AAL will comply with the rule in a finite time period. 

Granting this Exemption would help to ensure that air service safety is enhanced which serves 

the public interest.

Granting the Exemption Would Not Adversely Affect Safety

Safety will not be adversely impacted if the FAA grants this petition because FAA would utilize 

airplane voice communication methods used safely today. The 2012 FAA analysis on the 

potential safety benefits arising from the implementation of CPDLC states, “These preliminary 

results indicated a significant potential for enhancing safety ... and a reduction in the duration of 

loss of communication between aircraft and air traffic control (ATC) when transferring ATC 

contact by using a reviewable message”.

The ability to send reviewable messages is expected to significantly reduce several 

communications errors, such as read-back and hear-back errors, lack of read-back and hearback, and audio interruptions. These types of communications errors impact ATC operations. As 

an example, failure to comply with an assigned altitude may result from not hearing the 

communication, hearing it incorrectly, or ATC not hearing a reply.
During the period of this exemption, datalink messages will be ground recorded and will provide 

the majority of information that is communicated between the aircraft and ATC. This 

information is available for post flight review and analysis. As CPDLC messaging is currently 

limited there is no risk of essential information not being ground recorded. As the message sets 

mature, American Airlines will be in a position to record these post our requested exemption 

date.

3) What aircraft (specific N-numbers) would be affected?

The following 111 aircraft will be affected by this exemption:

N864NN

N865NN

N866NN

N867NN

N868NN

N869NN

N871NN

N872NN

N870NN

N874NN

N873NN

N875NN

N876NN

N877NN

N878NN

N879NN

N880NN

N881NN

N882NN

N883NN

N884NN

N885NN

N886NN

N887NN

N889NN

N890NN

N891NN

N892NN

N893NN

N894NN

N895NN

N896NN

N897NN

N898NN

N899NN

N901NN

N902NN

N903NN

N904NN

N905NN

N906NN

N907NN

N908NN

N909NN

N910NN

N912NN

N913NN

N914NN

N915NN

N916NN

N917NN

N918NN

N919NN

N920NN

N921NN

N922NN

N923NN

N924NN

N925NN

N926NN

N927NN

N928NN

N929NN

N930NN

N931NN

N932NN

N933NN

N934NN

N935NN

N936NN

N937NN

N938NN

N939NN

N940NN

N941NN

N942NN

N943NN

N944NN

N945NN

N946NN

N947NN

N948NN

N949NN

N950NN

N951NN

N952NN

N953NN

N954NN

N955NN

N956NN

N957NN

N958NN

N959NN
N960NN

N961NN

N962NN

N963NN

N964NN

N965NN

N966NN

N967NN

N968NN

N969NN

N970NN

N971NN

N972NN

N973NN

N976NN

N977NN

N978NN

N979NN

4) What is American’s plan, to include time frame, for bringing the aircraft into compliance?

American Airlines will begin the retrofit installation of the rule-compliant DLRs on approximately 1 July 

2016 to be completed no later than 30 June 2018.

Please submit the requested information and any other documents you feel appropriate to me as soon 

as possible.

Sincerely,

Captain Brian Will

Director Airspace and Aircraft Technology

American Airlines

817-967-5315