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September 19, 2016

Docket FAA-2014-0818

Docket Management Facility

US Department of Transportation

1200 New Jersey Avenue, SE West 

Building Ground Floor Room 

W12-140

Washington, DC 20590

RE: Extension of Exemption No. 11152

Dear Sir or Madam:

The Regional Airline Association (“RAA”), on behalf of its Part 121 member airlines,

1 petitions

pursuant to Sections 11.63 and 11.81 of the Federal Aviation Regulations (“FARs”) for an extension of

Exemption No. 11152, which is scheduled to expire on January 31, 2017.

Exemption No. 11152 provides relief from 14 CFR §§ 61.3(a) and (c), 63.3(a), and 121.383(a)(2).

It permits the establishment of special procedures that enable an operator to issue to its flight

crewmembers, on a temporary basis, confirmation of any required crewmember certificates based upon 

information contained in the operator's approved record system subject to certain conditions and

limitations. Exemption No. 11152 has proved to be a useful device that benefits the commercial aviation

industry and the flying public by allowing qualified and current crews to fly if their certificate has been 

misplaced or stolen. 

Extending this exemption will not compromise or adversely affect safety, as the conditions and

circumstances pertaining to safety and public interest, which warranted the grant of the original request, 

continue to exist. The approved procedures, encompassing the conditions and limitations established by 

the original grant of this petition and the identical exemption previously used by RAA member airlines,

have been in use for over a decade with no known compromise of safety. The operators’ record system’s 

capability to maintain the required information concerning medical and airmen certificates has also been

tested, with success, for many years. It is also in the public interest as the exemption can prevent possible

and unnecessary delays or cancellations of scheduled air service. For these reasons, Exemption No. 

11152 should be extended. 

 

1 See Attachment A.
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In accordance with FAR 11.87, RAA requests that the requirement for publication and comment

be waived. The renewal of this exemption is not a controversial issue and this petition does not seek to 

establish a precedent, rather would merely continue an accepted and established practice. Although RAA 

requests waiver of publication, a summary of this petition is attached as required by FAR 11.87.

Please do not hesitate to contact me should you have any questions or require additional

information.

Respectfully submitted,

Stacey Bechdolt

VP, Safety & Operations/Regulatory Counsel

Regional Airline Association

2025 M Street, NW, Suite 800

Washington, DC 20036

202-367-1252

Bechdolt@raa.org
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Attachment A

RAA Part 121 Member Airlines:

Air Wisconsin Airlines Corp.

CommutAir

Compass Airlines

Endeavor Air

Envoy

ExpressJet Airlines

GoJet Airlines

Hawaii Island Air

Horizon Air

Jazz Aviation

Mesa Airlines

Piedmont Airlines

PSA Airlines

Republic Airlines

Seaborne Airlines

Shuttle America

SkyWest Airlines

Trans States Airlines
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SUMMARY

Petitioner: Regional Airline Association.

Sections of 14 CFR Affected:

14 CFR 61.3(a) and (c)

14 CFR 63.3 (a)

14 CFR 121.383 (a)(2)

Description of Relief Sought:

The Regional Airline Association petitions on behalf of its Part 121 member airlines for an extension 

of Exemption No. 11152. This exemption permits RAA Part 121 member airlines to establish

special procedures that enable an air carrier to issue to its flight crewmembers, on a temporary

basis, confirmation of any required crewmember certificate based on information contained in the

carrier’s approved record system.