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 Exten d 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, 1 petitions for th e 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 t he FAA AES online system, show s an ex piration date of April 30, 2013, which

we believe is an error. )

A4A is th e 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 Technic al Operations

, telephone: (202) 626

- 4228.

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

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

with out these documen ts 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 cert ificate

loss/mutilation since A4 A’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

p rotection methods, the re lief 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 a ircraft 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, A4 A therefo re 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

Airl ines for America

202

- 626

- 4228 rireland@airlines.orgAttachment

U.S. Department of Transportation Docket Management System

Docket No. FAA

- 2001

- 9348

December 21 , 2012

SUMMARY OF ATA PETITION

To extend Exemption 5318K , wh ich authorizes A4A member airlines to dispatch aircraft without registration and/or airworthiness certificates on board with certain conditions, otherwise required by 14 CFR s ections 91.203 and 47.49

.

.