AIRBUS

AN EADS COMPANY AIRBUS AMERICAS, INC. 1909 K STREET NW, SUITE 720

WASHINGTON, DC 20006-1169

PHONE (202) 467-5480

FAX (202) 467-5492

www.airbusamericas.com

May 26, 2011

U.S. Department of Transportation

Docket Management System

400 7

th 

Street, SW, Room PL-400 

Washington, DC 20591-0001 

RE: Request for extension of Exemption No. 6850 

Dear Sir or Madam: 

This letter is to request an extension of Exemption No. 6850, as amended, Regulatory Docket 

No. FAA-2001-9924, issued to Airbus Americas on April 30, 2009. The existing exemption 

terminates on May 31, 2011. 

In accordance with 14 CFR part 11, I am submitting the following information to request an 

extension of Exemption No. 6850, as amended. 

(a) Name and mailing address and other contact information.

William G. Bozin 

Vice President, Safety and Technical Affairs 

Airbus Americas, Inc. 

1909 K Street N.W., Suite 720 

Washington, DC 20006 

Fax: 202 467 5492 

Tel: 202 331 2239 

E-mail: bill.bozin@airbus.com

(b) The specific section or sections of 14 CFR from which we seek an exemption: 

14 CFR § 61.77(a) 

(c) The extent of relief we seek, and the reason: 

To permit pilots and flight engineers employed by Airbus to be eligible for the issuance 

of special purpose pilot and flight engineer authorizations, under parts 61 and 65, as 

appropriate, for the purpose of performing delivery flights of U.S. registered Airbus 

airplanes between foreign countries and from a foreign country to the United States. 

The term “delivery flights” is understood to include proving flights, test flights, 

maintenance flights, or similar activities conducted prior to final delivery to a U.S. 

operator. 
The current exemption, as amended, is specific to the Airbus A320 family of aircraft 

(A318, A319, A320, A321). Since the original grant of this exemption, A330 aircraft have 

been added to U.S. fleets and it is expected that additional models will also be operated 

under U.S. registry. Airbus is requesting that the capability to use special purpose pilot 

and flight engineer authorizations be extended to all makes and models of airbus 

aircraft to ensure their timely delivery and introduction into U.S. service. 

(d) The reasons why granting this request would be in the public interest; that is, how it would 

benefit the public as a whole: 

Airbus is requesting issuance of special purpose pilot authorizations for its pilot and 

flight engineer employees so these employees may ferry U.S. registered Airbus 

airplanes from Great Britain, France, Germany and Spain to the United States (U.S.) for 

delivery to its U.S. customers. Airbus sales and manufacturing contractual agreements 

with its U.S. customers provide for delivery of aircraft to U.S. purchasers at specified 

locations in the U.S. It is extremely difficult to find and position qualified and current 

pilots with appropriate U.S. licenses and qualifications to ferry these aircraft since it is 

very hard to predict when aircraft will be accepted and available for flight. By using 

qualified Airbus employed pilots, a prompt delivery of Airbus aircraft to the U.S. is 

possible following aircraft acceptance procedures. This expedited process provides a 

cost savings to U.S. operators and also enables these aircraft to be available for use by 

the traveling public sooner than is otherwise possible. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from which 

we seek the exemption: 

During these delivery flights no persons or property for hire will be carried. 

All pilots used for the subject delivery operations will be appropriately trained, qualified, 

and certificated, for flight operations in Airbus airplanes. In addition, one of the pilots 

used on each crew for these operations will be instructor qualified. 

All Pilots licensed by a foreign authority and used for these operations will have been 

trained by Airbus using a curriculum that meets ICAO and EASA standards. 

(f) A summary you can publish in the Federal Register, stating: 

(1) The rule from which we seek the exemption: 

14 CFR § 61.77(a) 

(2) A brief description of the nature of the exemption sought: 

To permit pilots and flight engineers employed by Airbus to be eligible for the 

issuance of special purpose pilot and flight engineer authorizations, under parts 

61 and 65, as appropriate, for the purpose of performing delivery flights of U.S. 

registered Airbus airplanes. 
(g) Additional information: 

After delivery to U.S. Companies these Airbus airplanes will be used to support the U.S. 

traveling public in air transportation service. The grant of exemption by FAA to Israel 

Aircraft Industries, LTD, No. 7406C, has been reviewed. This Airbus renewal request is 

believed to be consistent with the FAA provisions provided in response to the abovecited petition. 

(h) We desire to exercise the privileges of the exemption outside the United States: 

Airbus is requesting issuance of special purpose pilot authorizations for its pilot and 

flight engineer employees so these employees may ferry U.S. registered Airbus 

airplanes from Great Britain, France, Germany and Spain to the United States (U.S.) for 

delivery to existing and future U.S. customers. Purchase contracts with U.S. Air Carriers 

often require the delivery of aircraft to specified locations in the United States. 

If there are any questions concerning this request, please contact Captain Rudy Canto in this 

office at 202-331-2237. 

Thank you for your prompt attention to this request. 

Sincerely, 

 William G. Bozin 

Vice President 

Safety and Technical Affairs