4333 Amon Carter Blvd, MD 5425 Captain Al Madar

Fort Worth, TX 76155 MD Operations Safety

480-287-0259 - Cell Captain Ron Thomas

817-967-9352 – Fax MD Flight Operations

December 09, 2014

Mr Skip Whitrock, American/US Airways JTT Lead

American Airlines Certificate Management Office

8700 Freeport Parkway, Suite 200A

Irving, Texas 75063

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 required 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 an 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 representative 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 50

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 certificate
 

holder 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 an exemption to 121.163 (a) (b) and (c) ‘Aircraft proving tests’ for the A330 and EMB-190 

aircraft types 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 been 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 Integrated 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 Carrier, 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 

provided. Resumes will include:

o Certificates

o Total flight time

o Previous 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 

Register 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 exemption request include:

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

proving runs are currently being 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 FAAapproved procedures 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.

• Integrated Operations Control 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 maintaining 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 of 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 flights 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 US 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