__________________________________________________________________________________

1 Member airlines are: Alaska Airlines, American Airlines, Atlas Air, Federal Express, Hawaiian Airlines, 

JetBlue Airways, Southwest Airlines, United Airlines, United Parcel Service, Co. Associate member is: Air 

Canada 

February 4, 2016

U.S. Department of Transportation 

Docket Management System

400 7th Street SW, Plaza 401 

Washington, DC 20590 

Re: Exemption No. 5487K, (Docket No. FAA-2002-12455) 

Dear Sir or Madam: 

In accordance with the Code of Federal Regulations, 14 CFR §11.61, Airlines for America1

(A4A) on behalf of its member airlines and other similarly situated Part 121 certificate holders, 

petitions the Administrator for an extension of Exemption No. 5487K (Docket No. FAA-2002-

12455). The current exemption (5487K) will expire on July 31, 2016. 

14 CFR § 61.3(a) provides, in pertinent part, that no person may, within the United States, act 

as pilot in command or in any other capacity as a required flight crewmember of a U.S. civil 

aircraft unless he has in his personal possession a current pilot certificate issued under Part 61. 

Section 121.383(a)(2) establishes similar requirements for airmen engaged in operations under 

Part 121. 

Similarly, sections 61.3(c) and 121.383(a)(2) state that no person may act as pilot in command 

or in any other capacity as a required flight crewmember unless he has in his personal 

possession an appropriate current medical certificate issued under Part 67. Section 63.3(a) 

sets forth similar requirements (both medical and flight engineer certificate) for flight engineers. 

Exemption No. 5487K 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. 5487K 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. The operators’ record system’s capability to 

maintain the required information concerning medical and airmen certificates have also been 

tested, with success, for a number of years. Finally, there is no safety impact, as these 
crewmembers are fully qualified and current. For these reasons, this exemption should be 

extended. 

There is one request for clarification if a renewal to Exemption No. 5487K is approved. The 

exemption approval currently states under Conditions and Limitations (emphasis added):

1. Prior to utilizing any provision of this plan each air carrier must develop, submit to, and 

have approved by the FAA Principal Operations Inspector assigned to that carrier a plan 

outlining the procedures it expects to employ in issuing a temporary confirmation 

document to crewmembers who do not have in their personal possession the airmen or 

medical certificate required under 14 CFR 61.3 and/or 63.3 for a particular flight.

The term “document” has been construed by some Principal Operations Inspectors (POIs) to 

mean that the temporary confirmation must be on a sheet of paper (as a written document). We 

understand that other POIs may be allowing this “document” to be in electronic form, i.e. sent to 

the crewmember’s EFB. If the extension is approved, a clarification of what constitutes a 

document would be appreciated. With the flight deck becoming more and more paperless, A4A 

requests that the FAA allow the temporary confirmation to be provided through an electronic 

document. A4A would recommend changing the first paragraph to read (emphasis added on 

change made):

1. Prior to utilizing any provision of this plan each air carrier must develop, submit to, and 

have approved by the FAA Principal Operations Inspector assigned to that carrier a plan 

outlining the procedures it expects to employ in issuing a temporary confirmation 

document (either in paper or electronic form) to crewmembers who do not have in 

their personal possession the airmen or medical certificate required under 14 CFR 61.3 

and/or 63.3 for a particular flight.

As stated earlier, this exemption supports the interest of the flying public and provides for 

equivalent levels of safety. Also, the conditions and circumstances, which warranted the grant 

of exemption originally, continue to exist. This exemption has been used for over 10 years 

without any adverse effect on safety or the traveling public. 

Furthermore, the renewal of this exemption is not a controversial issue. The petition does not 

seek to establish a precedent, but merely would continue an accepted and established practice. 

Accordingly, A4A requests that publication in the Federal Register be waived as unnecessary 

(14 CFR § 11.87).
A summary of this petition is attached as required by 14 CFR § 11.81. If you have any questions 

or need additional information, please call me at (202) 626-4285.

Sincerely,

/s/

Jeff Miller

Managing Director Flight Operations

Airlines for America (A4A)

1275 Pennsylvania Avenue, NW

Suite 1300

Washington DC 20004

Phone: 202-626-4285
SUMMARY OF PETITION 

Airlines for America (A4A) 

Regulations affected 

14 CFR § 61.3(a) and (c) 

14 CFR § 63.3(a) 

14 CFR § 121.383(a)(2) 

Description of Relief Sought: 

The Airlines for America (A4A) petitions on behalf of its member airlines and other similarly 

situated Part 121 operators for an extension of Exemption No. 5487K. The exemption permits 

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.