Captain Ron Thomas

Managing Director

Flight Operations

4601 Highway 360 MD 843

Fort Worth, Texas 76155

Office 817-967-5156

Ronald.Thomas@aa.com

September 9, 2015

Docket Management Facility US Department of Transportation

1200 New Jersey Avenue, SE West

Building Ground Floor Room W12-140

Washington, DC 20590

Subject: Related Aircraft Exemption Requests for American Airlines (AALA025A) 4333 Amon 

Carter Blvd. Fort Worth, Texas 76155

References:

▪ Title 14 CFR §121.438 Pilot Operating Limitations and Pairing Requirements

▪ Title 14 CFR §121.652 Landing Weather Minimum: IFR: All Certificate Holders

American Airlines requested and was granted related aircraft designation for the Boeing 757 

(Base Aircraft) and Boeing 767 (Related Aircraft) in accordance with 14CFR §121.418(b).

In response to the approval, American Airlines requests the following Exemptions in connection 

with the related aircraft approval.

Related Aircraft Exemption for Crew Pairing

In accordance with 14 CFR §121.438(b), either the Pilot in Command or Second in Command 

must have at least 75 hours of Line Operating Flight Time on the specific airplane type to 

conduct operations under Part 121. 

This exemption would grant approval for the pairing of crewmembers with less than 75 hours in 

either the B757 or the B767, but would require the pilot in command or second in command to 

have at least 75 hours of combined line operating flight time in the B757 and the B767 for the 

purposes of crew pairing requirements.

This request is based on an extensive review of American Airlines FOQA, ASAP, and LOSA 

safety data covering over 1.5 million flights with no issues combining B757 and B767 line 

operating flight time over the past 26 years. In addition, American Airlines Initial, Transition, 

and Recurrent Training for both the PIC and SIC are conducted in both B757 and B767 

Simulators, when possible. This results in the crews being highly familiar with the flight 

characteristics of both aircraft. Therefore, the combined flight time from the B757 and the B767 

is equivalent to the 75 hour requirement with non-designated related fleets.
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Related Aircraft Exemption for High Minimums

In accordance with 14CFR § 121.652 (a), the landing minimums must be increased by 100 feet 

and one-half mile at Regular, Provisional, and Refueling airports, if the pilot in command (PIC)

has not served at least 100 hours as PIC in the specific airplane type in part 121 operations.

This exemption would grant approval to combine the PIC flight times from either the B757 or 

B767 or both to meet the required 100 hours of PIC time requirement and not be subject to 

higher minimums in either aircraft type once the combined flight time exceeds 100 hours.

American Airlines is currently operating under Airlines for America (A4A) Exemption 5549M, 

Regulatory Docket No. FAA-2000-8434, which allows a new pilot in command of any A4A 

member airline, and of any other similarly situated Part 121 certificate holder, who is subject to 

higher landing weather minimum requirements to operate to the normal, lower Category I and 

Category II minimums under the conditions stipulated in the exemption. Under 5549M 

Conditions and Limitations:

1. Each operator using this exemption must comply with 14 CFR §121.438.

Since the condition for relief from high minimums is related to 14 CFR §121.438(b), the Related 

Aircraft Exemption for Crew Pairing and this exemption request for relief from high minimums, 

must be granted in conjunction, in order to satisfy the conditions and limitations of Exemption 

5549M.

American Airlines intension is that the FAA would consider granting both exemptions as part of 

the Related Aircraft designation approval. This exemption request does not deviate from the 

number of hours required by 14 CFR Part 121 nor American Airlines current authorization, and 

therefore does not jeopardize safety. American Airlines believes that granting approval to 

operate the B757 (Base Aircraft) and B767 (Related Aircraft) in conjunction with these 

exemptions meets the intent of the regulations and is in the public interest.

For questions or comments regarding this deviation request, please contact Captain Jim Thomas, 

Managing Director Flight Training and Standards (Jim.Thomas@aa.com) or me.

Regards,

Ron Thomas

Managing Director, Flight Operations
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Ecc: Larry Mayes, Assistant Principal Operations Inspector FAA

Captain Jim Thomas, Managing Director Flight Training and Standards

Captain John Duncan, Director of Standards Flight Crew Training

Alan Clay, Director Flight Operations Support

Att: Summary of American Airlines Petitions for Exemptions
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SUMMARY OF AMERICAN AIRLINES PETITION FOR EXEMPTIONS

Petitioner: American Airlines, Inc.

Regulations Affected: 14 CFR §121.438 (b) and 14 CFR §121.652 (a)

Description of Relief Sought: American Airlines requests an exemption to use the combined 

line operating flight time from the Boeing 757 (Base Aircraft)

and Boeing 767 (Related Aircraft) for the purposes of satisfying 

the 75-hour line operating flight time requirement for crew 

pairing. In addition, American Airlines requests an exemption to 

combine the Pilot in Command flight time from either the B757 

or B767 or both to satisfy the requirement of 100 hours of PIC 

operational flight time, in order to operate to the normal

Category I and Category II minimums.