® 

## Express 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

Legal Department 3620 Hacks Cross Road Building

B, 3rd Floor Memphis, TN 38125 US 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

# the mixed-fleet flying B757/B767 bid pack once seniority allows. Currently, 50% of pilots in training
to become pilot-in-command (PIC) of the 767 are PICs transitioning from the B757. In addition, 65% ofB767 second-in-command (SIC) pilots are transitioning from the B757 SIC pilot seat. These pilots are experienced,

as evidenced by the fact that on average, FedEx B767 PICs have over 7,000 hours ofFedEx flight experience, and SIC pilots have over 3,200 hours of FedEx flight experience.

1 

# These pilots have extensive operating experience with the procedures required
to safely fly the related aircraft. Since October 2013, dual-qualified pilots have flown 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 FedExdualqualified 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.To the extent that ALPA asserts the common aircraft flight manual for these aircraft
is confusing,

in March 2016, the FedEx B757/B767 Flight Training and Flight Standards published an enhancement

to the manual
to provide an easily accessible reference tool highlighting
the main performance differences between the B757 and B767. This Training Standardization Guide
is a clear supplement

to the Pilot Hand Book (PHB) and Pilot Handbook Supplement (PHS). Content

is presented

as related
to the PHB/PHS and hyperlinked fi·om the table of contents
to facilitate easier reference. This standardization guide is available

to all B757/B767 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.For questions

or comments regarding this exemption petition, please contact Kevin Keilty
at Kjkeilty@fedex.com

or at (901)224 -5547. Respectfully submitted, Anne Bechdolt Senior Attorney, Regulatory Affairs F edEx Express