Exemption Request 

B757/B767 Designated Related Aircraft 

November 3, 2015 

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Docket Management Facility US Department of Transportation 

1200 New Jersey Avenue, SE West 

Building Ground Floor Room W12-140 

Washington, DC 20590

Regarding: Related Aircraft B757/B767 Exemption Requests

14 C.F.R. References: § 121.438 Pilot Operating Limitations and Pairing Requirements 

§ 121.652 Landing Weather Minimum: IFR: All Certificate Holders 

Dear Madam/Sir: 

United Airlines requested and was granted related aircraft designation for the Boeing 757 (Base Aircraft) 

and Boeing 767 (Related Aircraft) in accordance with §121.418(b). In response to that approval, and in 

accordance with the Code of Federal Regulations, 14 C.F.R. § 11.25, United Airlines petitions the 

Administrator for exemptions to provide relief from §§121.438 and 121.652 for B757 and B767 

designated related aircraft pairing and high minimums landing requirements. 

Related Aircraft Exemption for Crew Pairing 

In accordance with 14 CFR §121.438(b), either the Pilot in Command (PIC) or Second in Command 

(SIC) must have at least 75 hours of line operating flight time on the specific airplane type to conduct 

operations under Part 121. United requests exemptive authority to pair crewmembers with less than 75 

hours in either the B757 or the B767, conditioned on United requiring that the pilot in command or 

second in command must have at least 75 hours of combined line operating flight time in the B757 

and the B767 for the purposes of crew pairing requirements. 

Related Aircraft Exemption for High Minimums 

In accordance with 14CFR § 121.652(a), the landing minimums must be increased by 100 feet and 

one-half mile at Regular, Provisional, and Refueling airports, if the PIC has not served at least 100 

hours as PIC in the specific airplane type in part 121 operations. United requests exemptive authority 

to combine PIC flight times logged on either the B757 or B767 (or both) to meet the 100 hours of 

PIC time required in order to avoid being subject to higher minimums in either aircraft type once the 

combined flight time exceeds 100 hours. 

United Airlines is currently operating under Airlines for America (A4A) Exemption 5549M, 

Regulatory Docket No. FAA-2000-8434, which allows a new pilot in command of any A4A member 

airline, and of any other similarly situated Part 121 certificate holder, who is subject to higher 

landing weather minimum requirements to operate to the normal, lower Category I and Category II 

minimums under the conditions stipulated in the exemption. Under 5549M Conditions and 

Limitations: 

1. Each operator using this exemption must comply with 14 CFR §121.438. 

Since the condition for relief from high minimums is related to 14 CFR §121.438(b), the Related 

Aircraft Exemption for Crew Pairing and this exemption request for relief from high minimums, 

must be granted in conjunction, in order to satisfy the conditions and limitations of Exemption 

5549M. 
Exemption Request 

B757/B767 Designated Related Aircraft 

November 3, 2015 

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This exemption request does not deviate from the number of hours required by 14 CFR Part 121 nor 

United Airlines’ current authorizations. United Airlines believes that granting approval to operate 

the B757 (Base Aircraft) and B767 (Related Aircraft) in conjunction with these exemptions meets the 

intent of the regulations and is in the public interest. 

 

Equivalent Level of Safety 

Safety risk management has been applied per United’s SMS policy for operating the B757 and B767 

as a combined fleet. Hazard mitigation is monitored through continued evaluation of training and 

operational data in addition to participation in multiple voluntary safety programs. The combination 

of voluntary programs employed at United provides the Administrator with targeted operational 

oversight through continued surveillance with the AQP, SMS, FSAP (ASAP), LOSA, FOQA, and 

VDRP processes. These programs provide United and FAA leadership with regular opportunities for 

continuous monitoring, critical analysis and review of safety trends. The goal of these programs is to 

identify safety-related problems within an air carrier’s operation, including operational and 

procedural errors, and to develop corrective actions. The key to all of these programs is the 

inclination to proactively seek safety solutions, rather than wait and react to an accident or serious 

incident. The combination of these programs incorporated at United Airlines promotes safety across 

the industry and mitigates risk. 

United has participated in, and used the data gathered from, these safety programs throughout the 

company’s nearly 30 year history of combined B757/B767 fleet operations. Any problematic issues 

have been identified and resolved using applicable risk mitigation; whether through training, 

operating procedures, sub-fleet methodology, or technology solutions. As a mature operator of a 

common B757/B767 fleet, United’s robust programs have proven to adequately meet and address 

any issues identified while conducting mixed fleet operations. Therefore, operations in accordance 

with this deviation will provide an equivalent level of safety for continued operations of the B757 

and B767 as a combined fleet. 

Reasons Exemptions are Requested 

On March 9, 2015, the FAA issued National Policy Notice 8900.286 directing principal operations 

inspectors (POI) to identify and correct Part 121 training programs that include credit between airplanes 

with different type certificates without (1) approved related aircraft designations and (2) approved aircraft 

related aircraft deviations, as required, from the FAA Headquarters (AFS-200, Air Transportation 

Division). In accordance with this policy, United Airlines requested and received Administrator approval 

of Boeing 757 (Base Aircraft) and Boeing 767 (Related Aircraft Designation) for the purposes of 

conducting related aircraft differences training and to pursue allowable flight crew training credits 

between airplanes with designated related aircraft approval. The B757/B767 common characteristics and 

type rating provide additional basis for these exemptions. Other considerations include: 

 United’s Qualification, Continuing Qualification, Requalification, Differences, Upgrade and 

Transition curricula incorporate exposure to a mixed combination of B757 and B767 Flight 

Simulation Training Devices (FSTDs) for both training and checking. Pilots in training are 

continuously assessed to ensure that performance is meeting standard and that course construct is 

validated. This approach provides all United B757/B767 pilots the opportunity to train and check 

in multiple FSTD configurations and aircraft variants. 
Exemption Request 

B757/B767 Designated Related Aircraft 

November 3, 2015 

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 At least one flying leg in each type aircraft is provided per United Airlines pilot scheduling OE 

guidelines for B757/B767; however, actual flight time in a specific type is not prescriptive. This 

allows one leg of OE to be conducted with a Check Airman in each aircraft type, B757 and B767. 

 United operates mixed B757 and B767 aircraft across the system and does not designate one type 

for a specified pilot domicile. This provides United B757/B767 pilots the opportunity to fly 

both/either aircraft type. 

 All Qualification and Continuing Qualification B757/B767 differences computer based training 

(CBT) courses are available to pilots on demand. This provides United B757/B767 pilots an 

additional refresher resource whenever desired. 

 All United pilots operating as PIC have a minimum of 1000 hours in air carrier operations. 

 All active United Airlines pilots hold an unrestricted ATP certificate with an appropriate aircraft 

type rating. 

Conditions and Limitations Consultation 

Because even seemingly-negligible implementation modifications in the areas addressed by this 

exemption request pose the potential for significant impact to United’s training programs and business 

practices, and could therefore obviate the utility of the requested deviation itself, United respectfully 

requests the opportunity to discuss with the FAA any conditions and limitations the Administration may 

consider imposing on its grant of this deviation request prior to its issuance. 

Please contact United Airlines Managing Director Flight Operations Bryan Quigley (872-825-1275, 

bryan.quigley@united.com) or me if any further information is required for your approval. 

Sincerely, 

Ellen Birmingham 

Director Flight Operations Regulatory Compliance & Quality Control 

cc: Kirk Baldin 

Howard Attarian 

Tracy Lee 

Bryan Quigley 

John Weigand