October 10, 2013

U.S. Department of Transportation 

Docket Operations, M-30

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590-0001

Subject: Petition for Exemption, 14 CFR Part 117 Flight Crewmember Duty and Rest Requirements

Docket FAA-2013-0655

Dear Sir or Madam: 

In accordance with the provisions of Title 14, Code of Federal Regulations (14 CFR) §11.63 and §11.81, 

American Airlines Inc. (American) petitions for an exemption from 14 CFR 121 subparts Q, R and S (part 

121 FDT), which prescribe flight time limits and rest requirements for U.S. carriers, in order to make an 

orderly transition to operate under pending 14 CFR part 117 flight crewmember duty and rest 

requirements. Specifically, we request that FAA permit American to implement 14 CFR part 117 early, 

during a phased-in transition period beginning on January 1 through January 4, 2014 as further described 

below. Doing so will provide an orderly process for transitioning our flightcrew members to the new 

requirements, provide an adequate period for planning and execution of our scheduling processes and 

reduce the potential impact on the flying public.

Background 

On January 4, 2012, the Federal Aviation Administration (FAA) published a final rule adopting new 

flightcrew duty and rest rules applicable to U.S. passenger carrying airlines. The FAA provided a two-year 

implementation period, with an effective date of January 4, 2014. American and all U.S. passenger 

airlines have been working diligently to implement part 117 over the past 20 months and will continue to 

do so until the effective date of the regulation. 

By Notice dated September 26, 2013 (78 FR 59226), in lieu of granting an A4A and RAA petition for 

exemption on behalf of its member airlines, the FAA made certain findings with regards to potential 

individual certificate holders petitions for exemption asking for early implementation of part 117. More 

specifically, for the stated reasons the FAA found that granting an individual certificate holder’s petition for 

exemption allowing for early implementation of part 117 would not have an adverse effect on safety and 

would be in the public interest. Similarly, the FAA found that the individual certificate holder’s exemption 

petitions would not need to be published in the Federal Register. Specifically the FAA asked that an 

exemption petition: (1) specify whether the petition is seeking early implementation of part 117, an early 

transition to part 117, or both; and (2) specify the dates for the early implementation and/or early 

transition to part 117. 

The Applicable Regulations and Relief Sought 

U.S. airlines that carry passengers currently operate under part 121 flight time limitation FDT regulations. 

American seeks exemption from 14 CFR subparts Q, R and S, which prescribe the flight time limits and 

rest requirements for U.S. carriers. 

Similar to the A4A and RAA petition, our reasons for seeking the relief include: 

1) The exemption is narrowly focused seeking a short window for American to implement part 117. 

2) Permitting American to implement during a phased in transition period will reduce the impact and 

system vulnerability of our entire operation rather than switching crew planning software and 

crewmembers the same day. 

4) It will ease the burden of building two different crew schedules to accommodate two different 

regulations in the same month. 
Therefore, American seeks an exemption to allow it to commence an early transition to part 117, through 

a phased-in transition period beginning on January 1 through January 4, 2014. As illustrated in the 

attachment, flight crewmembers assigned trip sequences that begin on or before December 31, 2013 will 

be scheduled and operated in accordance with Part 121 regulations, with scheduled completions to occur 

on or prior to January 4. Flight crewmembers assigned to trip sequences that begin on and after January

1 will be scheduled and operated in accordance with part 117 requirements. At the conclusion of this 

transition period, all assignments to trip sequences after January 4 will be scheduled and operated in 

accordance with part 117, completing American’s transition period to part 117. As stated in the Federal 

Register notice, once a flight crewmember has been switched to part 117, the flight crewmember will not 

be permitted to switch back to part 121 rules.

Granting the Exemption Would be in the Public Interest 

FAA previously found granting individual exemption petition asking for early transition period would be in 

the public interest. (See 78 FR 59227, September 26, 2013)

Granting the Exemption Would Not Adversely Affect Safety 

FAA previously found granting individual exemption petition asking for early transition period would not 

adversely affect safety. (See 78 FR 59227, September 26, 2013)

A Summary of this Petition that FAA Could Publish in the Federal Register 

FAA previously found granting individual exemption petition asking for early transition period would not 

need to be published in the Federal Register because delaying action on the petition would result in an 

adverse effect. (See 78 FR 59227, September 26, 2013)

Reasons for Exercising the Privileges of the Requested Exemption Outside the United States.

Application of this exemption outside the U.S. is required because new FAA pilot duty time and rest 

regulations that apply to U.S. airlines that carry passengers do not distinguish between domestic and 

international operations. Part 117 applies to scheduling of flight crewmembers worldwide. 

Conclusion 

For the foregoing reasons, American respectfully requests an exemption from the requirements of 14 

CFR 121 subparts Q, R, and S for the period of January 1 through January 4, 2014 in order to transition 

to new part 117 as described. 

Respectfully submitted,

FRANCIS C. HEIL

Senior Attorney

American Airlines

202 496-5642

francis.heil@aa.com

Attachment: American’s Transition to Part 117 Schedule

-2-
American’s Transition to Part 117 Schedule

12/30 12/31 1/1 1/2 1/3 1/4 1/5 1/6

1-day trips

←AA/FOS Effective Date ←FAR 117 Effective Date

Transition Period

2-day trips

3-day trips

4-day trips

2013 2014

 FAR 121 FAR 117