December 21, 2012

Docket Management Facility 

U.S. Department of Transportation 

Attention: Docket FAA-2001-9348 

Docket Operations, West Building Ground Floor, 

Room W12-140, 

1200 New Jersey Avenue, SE, 

Washington, DC 20590

Submitted electronically to: http://www.regulations.gov/

Subject: Petition to Extend Exemption No. 5318K to Permit Operation of Certain Registered Airline 

Aircraft without the Registration and Airworthiness Certificates on Board 

Ladies/Gentlemen: 

In accordance with the provisions of Title 14, Code of Federal Regulations (14 CFR), Part 11, 

the Airlines for America (A4A), on behalf of its member air carriers,1petitions for the renewal of 

Exemption No. 5318K, Docket Number FAA-2001-9348. Exemption No. 5318K expires on July 

31, 2011 according to the written correspondence received on April 22, 2009. (We are aware, 

however, that the FAA AES online system, shows an expiration date of April 30, 2013, which 

we believe is an error.)

A4A is the trade and service organization of the U.S. scheduled air carriers located at 1301 

Pennsylvania Avenue, NW, Suite 1100, Washington, D.C. 20004-1707. The appropriate 

technical contact for the purposes of this application is Robert Ireland, Director Technical 

Operations, telephone: (202) 626-4228.

Sections 91.203 and 47.49 require aircraft to have certificates of registration and/or airworthiness 

on board and Exemption No. 5318K, extended on April 22, 2011, authorizes aircraft to dispatch 

without these documents under certain conditions and limitations.

The justification for the requested extension of Exemption 5318K is the same as the justification 

for the original exemption. In addition, airline efforts to reduce incidents of certificate 

loss/mutilation since A4A’s original filing – e.g., hardened pouches – have been only partially 

successful. The need for this exemption continues, and we have seen no foolproof designs 

offering a permanent solution to the problem. While we will continue to examine improved 

protection methods, the relief afforded by Exemption 5318K is still needed. Extension of this 

exemption will be in the public interest because strict enforcement of the registration/

 

1 A4A's members are Alaska Airlines, Inc., American Airlines, Inc., Atlas Air, Inc., Delta Air Lines, Inc., Federal 

Express Corporation, Hawaiian Airlines, JetBlue Airways Corp., Southwest Airlines Co., United Continental 

Holdings, Inc., United Parcel Service Co., and US Airways, Inc. Our associate member is Air Canada.
airworthiness certificate requirements would result in the grounding of aircraft at times and 

places where substitute aircraft are not available. This would unnecessarily greatly 

inconvenience the traveling and shipping public. The renewal of this exemption is not a 

controversial issue and is not precedent setting, A4A therefore requests that publication of this 

exemption request in the Federal Register be waived (14 CFR §11.87). 

Your consideration and approval of this request is appreciated. 

Sincerely,

______/S/________

Robert L Ireland 

Director, Technical Operations 

Airlines for America 

202-626-4228 

rireland@airlines.org 
Attachment

U.S. Department of Transportation

Docket Management System

Docket No. FAA-2001-9348

December 21, 2012

SUMMARY OF ATA PETITION

To extend Exemption 5318K, which authorizes A4A member airlines to dispatch aircraft without 

registration and/or airworthiness certificates on board with certain conditions, otherwise required

by 14 CFR sections 91.203 and 47.49.

.