BEFORE THE 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON D.C. 

Petition of: 

DELTA AIR LINES, INC. 

OPERATING CERTIFICATE DALA026A 

For exemption of certain requirements of 

14 CFR 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 of Federal Regulations, 14 CFR §11.81, Delta Air Lines 

petitions for an exemption to use a Phase II (Level C) simulator for pilot-in-command {PIC) 

training and checking in accordance with the requirements of Part 121, Appendix H, 

amended, provided certain conditions and limitations are met. Also, under the terms of the 

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 under the authority of a similar exemption (5400) 

granted to Airlines for America (A4A) member airlines since September 20, 2000. 

Historically, A4A has petitioned for an extension of 5400 (Docket FAA-2001-10676) "on 

behalf of its member airlines and other similarly situated Part 121 certificate holders." 

However, the FAA has granted exemption extensions to "member airlines of A4A" and has 

not included the language "and other similarly situated Part 121 certificate holders." As a 

result Delta now requests the same relief on an individual carrier basis. 

Section of the Federal Aviation Regulations Affected 

Appendix H to Part 121-Advanced Simulation; Level C Training and Checking Permitted, 

and §61.57 Recent flight 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 of part 121, Appendix H to allow: 

1. Upgrade training and the certification check required by§ 61.157, when the 

pilota. Has previously qualified as second in command (SIC) in the type airplane 

to which the pilot is upgrading; and 
Petition 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 the type airplane to which the pilot is upgrading. 

2. Initial training and certification check required by§ 61.157, when the pilotBackground 

a. Is employed by an airplane operator; 

b. Is currently serving as SIC with that operator in an airplane of the same 

group; and 

c. Has a minimum of 500 flight-hours as SIC in airplanes of the same group 

with that operator. 

The FAA has previously determined that the justification for the issuance of Exemption No. 

5400, as valid and is in the public interest. The FAA Administrator has granted relief through 

exemption to Airlines for America from part 121, Appendix H, Level C Training and Checking 

Permitted, subparagraphs 2b, 3b, and 3c that allows member airlines of A4A to use Level C 

simulators for pilot in command (PIC) initial and upgrade training and checking and reduces 

the upgrade/transition pilot experience requirements of part 121, Appendix H, subject to 

conditions and limitations. 

Delta Air Lines has been successfully training and checking under its Advance Qualification 

Training Program (AQP) and exemption 5400 since September 20, 2000. 

The only change to the relief to which Delta requests is for an individual exemption be 

issued as Delta is no longer a member of A4A. 

Request for Expedited consideration 

Delta is also requesting that, as part of this Petition for Exemption request, the public 

comment phase be waived as per Title 14 CFR Part 11.87(a), which states: 

"The FAA may not publish a summary of your petition for exemption and request 

comments if you present or we find good cause why we should not delay action on your 

petition. The factors we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent ... 

It is the opinion of Delta that training and checking has been conducted under the previous 

relief granted by exemption 5400 for fifteen years and the conditions and limitations of that 

exemption remain in place, there is no precedent being set with our request. 

No Adverse Effect on Public Safety 

The conditions and circumstances, in regard to public interest and equivalent levels of 

safety, which warranted the original grant of exemption 5400, continue to exist. Exemption 

5400 has been in use by Delta for fifteen years with no known compromise of safety. 
Petition for Exemption - 14 CFR 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 member of A4A. 

Please contact Chuck Schramek, General Manager - Flight Operations Quality Assurance & 

Compliance at 404-715-1112 (office) if you have questions or require additional 

information. 

Sincerely, 

~~M Stephen M. Dickson 

Senior Vice 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- FAA 
Petition for Exemption - 14 CFR Part 121 Appendix H 

Delta Air Lines, Inc. 

December 14, 2015 

Page 4 

Summary for 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. 

summary of Relief Sought: 

Delta Air Lines, Inc., Operating Certificate DALA026A, petitions the Administrator for relief 

from Appendix H to Part 121 and §61.57 to use a Phase II (Level C) simulator for pilot-incommand (PIC) training and checking in accordance with the requirements of Part 121, 

Appendix H, amended, provided certain conditions and limitations are met. Also, under the 

terms of the exemption, upgrade training and the certification check required by 14 CFR 

§61.157 can be accomplished in a Phase II simulator.