_________________ _______________________________________________________________ __ 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. 54 87 K, (Docket No. FAA

- 200 2

- 12455 )

Dear Sir or Madam:

In accordance with the Code of Federal Regulations, 14 CFR §11. 6 1, Airlines for America 1 (A4A) on behalf of its member airlines and other similarly situated Part 121 certificate holders, petitions the Administrator for an extension of Exemption No. 54 87 K (Docket No. FAA

- 200 2

- 12455 ). The current exemption (54 87 K) will expire on J uly 31, 2016.

14 CFR § 61.3(a) provides, in pertinent part, th a t 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, s ections 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 requ irements (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 specia l 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 ha ve also been
tested

, with success , for a number of years

. Finally, there is no safety impact, as thesecrewmembers are fully qualified and current. For th ese reason s
, 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 Operat ion s Inspector assigned to that carrier a plan outlining the procedures it expects to employ in issuing a temporary confirmation
doc ument to crewmembers who do not have in their personal possession the airmen or

medical certi fi cate required under 14 CFR 61.3 a nd/or 63.3 for a particular flight.

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

m ean 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 clarificat ion 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 fir st 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 proc edures 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 c onditions and circumstances, which warranted the grant of exemption originally, continue to exist . T his 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

- 4285S UMMARY 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) pe titions on behalf of its member airlines and other similarly situated Part 121 operators for an extension of Exemption No. 5487 K . The exemption permits establishment of special procedures that enable an operator to issue to its flight crewmembers,

on a tem porary basis, confirmation of any required crewmember certificates based upon information contained in the operator's approved record system subject to certain conditions
and limitations.