4333 Amon Carter Blvd, MD 5425 Captain Al Madar

Fort Worth, TX 76155 MD Operations Safety

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- Cell Captain Ron Thomas

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– Fax MD Flight Operations

December 09, 2014

Mr Skip Whitrock , A merican/US Airways JTT Lead

American Airlines Certificate Management Office

8700 Freeport Parkway, Suite 200A

Irving , Texas 7 5063

Subject: Petition for Exemption

– Proving Runs

Dear Mr. Whitrock :

On January 3, 2014, American Airlines and US Airways received FAA acceptance of the Single Operating Certificate

Transition Plan and Operation Specification A502 has been granted and issued. Until issuance of a single operating

certificate, all 14CFR 119.65 and 119.67 personnel for each legacy carrier will remain in place.

With the activities associated with the transition now well under way, the purpose of this letter is to request an exemption

to the aircraft proving tests req uired by 121.163 (a) (b) and (c). Note the current plan is for the final operating certificate

to be the current American Airlines Air Carrier Certificate (Certificate No. AALA025A). American Airlines is following

the process outlined in 14 CFR 11, 14 CFR 121 in requesting a n exemption from the regulation listed below:

121.163 (a) (b) and (c) Aircraft proving tests.

(a) Initial airplane proving tests. No person may operate an airplane not before proven

for use in a kind of operation under this part or part 135 of this chapter unless an airplane

of that type has had, in addition to the airplane certification tests, at least 100 hours of

proving tests acceptable to the Administrator, including a representativ e number of flights

into en route airports. The requirement for at least 100 hours of proving tests may be

reduced by the Administrator if the Administrator determines that a satisfactory level of

proficiency has been demonstrated to justify the reduction. At least 10 hours of proving

flights must be flown at night; these tests are irreducible.

(b) Proving tests for kinds of operations. Unless otherwise authorized by the

Administrator, for each type of airplane, a certificate holder must conduct at least 5 0

hours of proving tests acceptable to the Administrator for each kind of operation it

intends to conduct, including a representative number of flights into en route airports.

(c) Proving tests for materially altered airplanes. Unless otherwise authorized by the

Administrator, for each type of airplane that is materially altered in design, a certificateholder must conduct at least 50 hours of proving tests acceptable to the Administrator for

each kind of operation it intends to conduct with that airplane, including a representative

number of flights into en route airports.

The extent of relief sought, is a n exemption to 121.163 (a) (b) and (c) ‘Aircraft proving tests’ for the A330 and EMB

- 190

aircraft type s that is not presently included on the final air carrier certificate, but is in full service on the merging US

Airways certificate. Additionally, no alterations have b een made to the A330 and EMB

- 190 aircraft being added to the

American Airlines certificate.

Based upon the following considerations, we request a reduction in hours from 121.163(b) and propose the following:

• Conduct a single round trip on revenue flights for each aircraft (A330 and EMB

- 190), over routes mutually

agreed upon by the Joint Transition Team (JTT).

• FAA observers located in the I ntegrat ed Operations Control Center in Pittsburgh

.

• FAA observers in the jumpseat and in the cabin during revenue operations

.

• FAA observers located at the ‘outstation’ observing revenue operations

.

• Scenarios, mutually agreed upon by both the FAA and the Car rier, to occur during revenue flight and/or on the

ground at the outstation

.

• Once flights and dates are agreed upon, the resumes for the crewmembers assigned to the flight will be

p rovided. Resumes will include:

o Certificates

o Total flight time

o Previou s experience in aircraft being tested

o Years of experience with the applicant

o Any other experience

o Any other transport experience

The granting of this exemption request will not set a precedent and, it is not required to be published in the Federal

R egister for comment.

Previous mergers (i.e., Delta Air Lines & Northwest Airlines, Continental Airlines & United Airlines, Atlantic Southeast

Airlines & ExpressJet Airlines) have been granted similar relief.

Factors for consideration supporting this exem ption request include:

• US Airways’ extensive operating experience with these aircraft. All city pairs that might be considered for

proving runs are currently be ing operated in revenue service.

• No crewmember movement between legacy carriers will occur until post

- Single Operating Certificate and

merging of all training programs has been completed for these crewmembers.

• The carrier's flight deck crews and cabin crews will operate these aircraft types in accordance with the FAA

approved proc edures in place at SOC issuance.

• Any shift of aircraft types on existing routes or the addition of new routes are currently (and will continue to be)

managed under the existing and already

- approved new route/new destination standard practices.

• Integ rated Operations Contr ol functions will continue as separate and ‘fenced’ until such time as a joint

collective bargaining agreement is reached with the affected labor groups.Expediting the movement to a Single Operating Certificate provides:

• A reduced period of time mainta ining two ‘parallel’ certificates including carrier 119 positions and separate

individual carrier accountability and oversight by the FAA.

• Increased operational flexibility with respect to the use of aircraft and markets serviced. This enables

adjustment o f service to ensure appropriate service levels to the public in all cities served.

Failure to obtain this deviation would result in:

• Extensive disruption to the carrier's operations as aircraft and crews are pulled from current line operations to

support these activities. These activities may have a negative effect on the traveling public.

• Disruption to ramp operations as the additional proving flights must be accommodated as though they were

revenue flights. This may result in disruptions to revenue fligh ts being conducted with a negative effect on the

traveling public.

• Significant additional workload for the FAA in the supervision and conduct of such proving tests.

Based upon the legacy U S Airways extensive experience in operating these aircraft types and the high level of

experience of the crews, such an exercise would not provide any increase in the level of safety of the merged carrier’s

operation.

For Legacy US Airways For Legacy American Airlines

Ron Thomas Al Madar

Managing Director Flight Operations Managing Director of Operations Safety and Compliance