BEFORE THE FEDERAL AVIATION ADMINISTRATION WASHINGTON D.C.

Petition of: DELTA AIR LINES, INC. OPERATING CERTIFICATE DALA026A For exemption of certain requirements of 14CFR 121 Appendix H & 61.157 Docket FAA-2015-

PETITION OF DELTA AIR LINES, INC. FOR AN EXEMPTION December 14, 2015
In accordance with the Code ofFederal Regulations, 14 CFR §11.81, Delta Air Lines petitionsfor an exemption to use a Phase II (Level 

### C) simulatorfor pilot-in-command {PIC) training and checking in accordance with the requirements of Part 121, Appendix H, amended, provided certain conditions and limitationsare met. Also, underthe terms ofthe exemption, upgrade training and the certification check required by 14 CFR §61.157 can be accomplished in a Phase II (Level C) simulator. Delta Air Lines has been operating underthe authority ofa similar exemption (5400) granted to Airlines for America (A4A) member airlines since September20, 2000. Historically, A4A has petitioned for an extension of 5400 (Docket FAA-2001-10676) "on behalfof its member airlines and other similarly situated Part 121 certificate holders." However, the FAA has granted exemption extensions to "member airlines ofA4A" and has not included the language "and othersimilarly situated Part 121 certificate holders." As a result Delta now requests the same reliefon an individual carrier basis. Section ofthe Federal Aviation Regulations Affected Appendix H to Part 121-Advanced Simulation; Level CTraining and Checking Permitted, and §61.57 Recentflight experience: Pilot in command. Requested Relief Specifically, Delta Air Lines, Inc. is seeking the same relief as granted in exemption 5400 for pilot in command (PIC) initial and upgrade training and checking and reduces the upgrade/transition pilot experience requirements ofpart 121, Appendix H to allow: 

### 1. Upgrade training and the certification check required by§ 61.157, when thepilota. Has previously qualified as second in command (SIC) in the type airplane to which the pilot is upgrading; andPetition for Exemption - 14 CFR Part 121 Appendix H Delta Air Lines, Inc. December 14, 2015 Page 2
b. Is currently serving as SIC with that operator in an airplane in the same group as thetype airplane to which the pilot is upgrading. 2. Initial training and certification check required by§ 61.157, when the pilot

### Background a. Is employed by an airplane operator; b. Is currently serving as SIC with that operator in an airplane ofthe same group; and c. Has a minimum of500 flight-hours as SIC in airplanes ofthe same group with that operator.

The FAA has previously determined thatthejustification forthe issuance of Exemption No. 5400, as valid and is in the public interest. The FAA Administrator has granted reliefthrough exemption to Airlines forAmerica from part 121, Appendix H, Level CTraining and Checking Permitted, subparagraphs 2b, 3b, and 3cthat allows member airlines ofA4A to use Level C simulatorsfor pilot in command (PIC) initial and upgradetraining and checking and reduces the upgrade/transition pilot experience requirements of part 121, Appendix H, subjectto conditions and limitations. Delta Air Lines has been successfully training and checking under itsAdvance Qualification Training Program (AQP) and exemption 5400 since September20, 2000. The only changeto the reliefto which Delta requests is foran individual exemption be issued as Delta is no longera member ofA4A. 

### Requestfor Expedited consideration Delta is also requesting that, as part ofthis Petition for Exemption request, the public comment phase be waived as perTitle 14 CFR Part 11.87(a), which states: "The FAA maynotpublish a summary ofyourpetition forexemption andrequest comments ifyou presentor we findgoodcause why we shouldnotdelayaction on your petition. The factors we considerin deciding not to requestcommentinclude: (a) Whethergranting yourpetition wouldseta precedent

... It is the opinion of Delta thattraining and checking has been conducted underthe previous reliefgranted by exemption 5400 forfifteen years and the conditions and limitations ofthat exemption remain in place, there is no precedent being set with our request. 

### No Adverse Effecton Public Safety The conditions and circumstances, in regard to public interestand equivalent levels of safety, which warranted the original grant ofexemption 5400, continue to exist. Exemption 5400 has been in use by Delta forfifteen years with no known compromise ofsafety.Petition for Exemption - 14CFR Part 121 Appendix H Delta Air Lines, Inc. December 14, 2015 Page 3
Conclusion Based on the information provided in this petition, granting Delta the same relief as permitted in Exemption No. 5400, will allow Delta to continue to provide the same level of training and checking under our approved AQP without interruption. The only change is that Delta Air Lines is no longer an active memberofA4A. Please contact Chuck Schramek, General Manager - Flight Operations Quality Assurance & Compliance at 404-715-1112 (office) ifyou have questions or require additional information. Sincerely,

# ~~M Stephen M. Dickson SeniorVice President Flight Operations Delta Air Lines, Inc.
cc: David Gerken, Acting Office Manager, Delta Certificate Office
- FAA James T. Giles, Jr, Principal Operations Inspector, Delta CMU- FAAPetition for Exemption - 14CFR Part 121 Appendix H Delta Air Lines, Inc. December 14, 2015 Page 4



### Summaryfor Federal Register Petitioner: Affected Regulations: Delta Air Lines, Inc. 14 CFR Part 121 Appendix H -Advanced Simulation; LEVEL C TRAINING and Checking Permitted, and 61.57 Recent flight experience: Pilot in command. 

### summaryof Relief Sought: Delta Air Lines, Inc., Operating Certificate DALA026A, petitionsthe Administratorfor relief from Appendix Hto Part 121 and §61.57 to use a Phase II (Level 

### C) simulatorfor pilot-incommand (PIC) training and checking in accordance with the requirements of Part 121, Appendix H, amended, provided certain conditions and limitationsare met. Also, underthe terms ofthe exemption, upgrade training and the certification check required 

### by 14 CFR §61.157 can be accomplished in a Phase II simulator.