Petition of: DELTA AIR LINES, INC. BEFORE THE FEDERAL AVIATION ADMINISTRATION WASHINGTON D.C.

OPERATING CERTIFICATE DALA026A For exemption of certain requirements of 14 CFR 121.915(d)

PETITION OF DELTA AIR LINES, INC. FOR AN EXEMPTION Docket FAA-2016-

January 

### 14, 2016

In accordance with the Code of Federal Regulations, 14 CFR §11.81, Delta Air Lines petitions the Administrator for an exemption from 14 CFR 121.915(d) to the extent necessary to permit Delta Air Lines to implement its currently approved Continuing Qualification training program for fleets new to the operator. Delta asks to implement this training program withoutwaiting 24 calendar months to petition for a 36 month cycle. Section ofthe Federal Aviation Regulations Affected 14 CFR Section 121.915(d). (SubpartY- Advanced Qualification Program- Continuing Qualification Curriculum), in pertinent part: (d) "Duration ofcycles andperiods. Initiafly 1 the continuing qualification cycle approvedforan AQPmustnotexceed24 calendarmonths in duration, andmustinclude two ormore evaluation periods ofequal duration. Afterthat, upon demonstration bya certificate holderthat an extension is warranted, the FAA mayapprove an extension ofthe continuing qualification cycle to a maximum of36 calendarmonths in

**duration.~~** Nature and Extentof Relief Requested This petition seeks relieffrom 14 CFR 121.915(d) to allow all Delta fleets, new as well as incumbent, to utilize the currently approved Delta Continuing Qualification training program. The current program for all Delta fleets consists of a 36 month cycle with two 18 month evaluation periods further segmented into four 9 month return intervals for pilot training and checking. Approval would sanction entry of any new fleet, such as the A-350, into the proven and common Continuing Qualification training program long used for all Delta fleets regardless of make, model, or manufacturer (e.g. MD88, 8717, 8737, 8757, B767, B777, B747, A320, and A330).Petition for Exemption- 14 CFR Part 12L915(d) Delta Air Unes, Inc. January 14, 2016 Page 2 Background Delta Air Lines entered the Advanced Qualification Program (AQP) Continuing Qualification training program in 1995. That Continuing Qualification program provided for each pilot to train as a crew and consisted ofground school and 2 simulator sessions everytwelve (12) months. The program provided one day of simulator training followed on the second day by a combination of a Maneuvers Validation and a Line Operational Evaluation. In 

### 2000, Delta modified its Continuing Qualification Program for international and domestic/narrow body fleets. The domestic fleets returned for training every 12 months with one visit consisting of 2 simulator days followed by 3 simulator days 12 months later. International fleets returned for 2 simulator days and then returned 6 months later for anotherday ofsimulator training. In 2010, following the merger with Northwest Airlines, Delta, in concert with AFS-230 and CMU-27, conducted a study focused on improving the effectiveness of its Continuing Qualification program while integrating the two airlines' training. As a result of this effort, in January 2011 Delta received FAA approval to transition to a 36 month Continuing Qualification cycle consisting of two 18 month evaluation periods. Importantly, each 18 month evaluation period cons'1sts oftwo returns for pilot training placed nine months apart. The first return consists of a day of training followed on the subsequent day with training and an LOE. The second return (nine months later) is comprised of a day of training followed on the subsequent day by a Maneuvers Validation. On the training days Delta employs the Special Purpose Operational Training (SPOT) methodology which allows Delta to utilize inputs from its mature Safety Management System to develop training tasks and scenarios reflective of real world line operations. Using this approach Delta has been able to focus more heavily on data-driven (e.g. LOSA, FOQA, ASAP) line flying oriented tasks as well as tasks derived from other sources including FAA INFOs, SAFOs, and Advisory Circulars, while still incorporating the requirements of traditional maneuvers training and checking. This approach has proven highly successful in providing Delta pilots with more frequent and targeted training. Delta is now nearing completion of the second of its 36 month Continuing Qualification cycles using this methodology and results derived from its SMS clearly show that the program provides a better training and checking experience than that of a traditional 24 month cycle.
In addition to the continuous 9 month returns for ground and simulator training, Delta's current Pilot Continuing Qualification cycle also includes a robust and continuous quarterly eLearning/distance learning component. Using advanced and interactive electronic learning media this pilot quarterly training addresses both traditional FAA-required subjects (e.g. aircraft systems) and a range oftargeted line flying and other data-derived topics (e.g. runway incursion prevention) delivered using a quarterly "just in time" methodology (i.e. seasonal subjects such as cold weather operations are addressed immediately prior to the start ofthe winter flying season). Importantly, Delta has established a comprehensive plan to collect performance/proficiency data on hardware, courseware, and peopleware. Delta conducts stringent internal analyses of this Performance/ Proficiency Database (PPDB) data for the purpose of refining and validating its curricula content and associated pilot proficiency intervals. The PPDB is a relational database that receives inputs from flight training and flight operations instructor/evaluators. Both sources use common taskings and conditions to allow for robust analysis across data streams. The results of PPDB analyses are a cornerstone ofPetition for Exemption- 14CFR Part 121.915(d) Delta Air Lines, Inc. January 14, 2016 Page 3 the varied data inputs used in Delta's Safety Management System. When coupled with the results of FOQA, ASAP, LOSA, and Line Check data inputs, Delta's Safety Management System demonstrably shows the effectiveness of Delta's 36 month Continuing Qualification program.
Justification 1. Delta Air Lines conducts its pilottraining and checking program in accordance with the precepts ofan AQP as provided for in FAR 121.915 SubpartY. Consequently, all pilot training programs are based on a singular proven training program and guidance philosophy. In particular, Delta's fleets are operated using a combined Qualification Standards approach which incorporates fleet specific differences into a standardized document. As a result ofthis approach 1 Qualification Standard criticality and currency determinations, which drive the intervals overwhich all Continuing Qualification tasks are trained, validated, or evaluated, are the same for all Delta fleets. Accomplishing these tasks using the intervals derived from Delta's 36 month cycle has proven fully successful for Delta's entire range ofaircraft manufacturers and types. In short, Delta believes approval ofthis exemption is in keeping with the guidance provided in AC 120- 54A which states, "To determine an equivalentlevel ofsafetyofan airline'sAQP, the entire training system mustbe examinedas a comprehensive whole rather than considering anyone componentin isolation". 2. Delta is applying for an exemption to FAR 121.915(d) in order to use the proven and approved 36 month Continuing Qualification program for any new aircrafttype. 3. In 2010 Delta invested heavily in the current Continuing Qualification training program in an effort to provide more and higher quality training for its pilots. Under Delta's current program pilots accomplish 8 simulator periods in three years versus 6 under a traditional cycle and 48 hours of Instructor Led Training instead of 36. Adopting the prescriptive FAR 121.915(d) 24 month cycle would result in Delta reverting to a less robust and effective training model.
4. Delta's experience with its current Continuing Qualification training program has validated its value over that of a more traditional approach. As noted, this very successful program provides more and better targeted training more frequently. The initial 24 month training cycle was originally designed to allow carriers to gain experience and data under the 24 month cycle before adopting other Continuing Qualification methodologies. It is more important and relevant that the carrier has experience and demonstrated success with an AQP program than a specific fleet type or manufacturer.
5. Delta Air Lines believes strongly in standardization and invests heavily in standardization in line operations and training. Delta goes to great lengths to ensure all programs and instructors are standardized and focused on the common and proven set of training and checking events and milestones. The prospect of individual fleets conducting training under a different program cycle opens the door to unanticipated consequences. Specifically, there is no assurance that pilots returning less frequently to the schoolhouse for training and checking will performPetition for Exemption- 14 CFR Part 121.915{d) Delta Air Lines, Inc. January 14, 2016 Page 4 to the same standard as those come more Frequently. This is all the more true given the high probability that reversion to a 24 month program with two returns requiring both a Maneuvers Validation and Line Operational Evaluation upon each return {as opposed to a 36 month program with four returns) would provide little or no t1me for SMS/data-driven operationally derived training. Further, it is worthy to note that under Delta's AQP a validation/evaluation event is accomplished under the auspices of an FAA-certified evaluator pilot every 9 months versus 12 months under the traditional cycle. Implementation of the current 36 month program required significant investment of money and time to ensure instructors and evaluators were fully trained on the new program, Continuing Qualification information technology (IT) solutions redesigned, and associated systems (such as the eLearning/Distance Learning program described earlier). Again, while reversion to a program requiring 12 month returns instead of 9 month returns would conceivably save the company money, there appears to be no other value-added. Changing the established and proven program and standards introduces risk in the areas ofscheduling and regulatory compliance as well. Importantly, as new fleet types are added at Delta all pilots will undergo initial or transition training to include an Initial Qualification Maneuvers Validation and an Qualification Line Operational Evaluation followed by a Operational {on aircraft) Evaluation. Nine months later they 

### will return for training and receive either a Maneuvers Validation or a Continuing Qualification Line Operational Evaluation providing them with more training than provided for under FAR 121.915(d). 6. Risk mitigation

- Delta employs a sophisticated grading methodology and First Look strategy that provides empirical insight into the performance of pilots attending the Continuing Qualification curriculum. If approved, adopting Delta's 36 month cycle with 9 month returns ensures that this vital and reported data, used to validate the Continuing Qualification training and checking intervals, is collected and analyzed within Delta's SMS even more frequently than provided for underthe standard 24 month cycle with 12 month returns. Request for Expedited Consideration Delta is also requesting that, as part ofthis Petition for Exemption request, the public comment phase be waived as perTitle 14 CFR Part 11.87(a), which states: "The FAA maynotpublish a summary ofyourpetition for exemption andrequest comments ifyoupresentor we findgoodcause why we shouldnotdelayaction on your petition. The factors we considerin deciding not to request commentinclude: (a) Whethergranting yourpetition wouldseta precedent

... It is the opinion of Delta that allowing new fleets to fold into the continuing standard training format and cycle as currently approved in the AQP does not set a precedent.Petition for Exemption- 14 CFR Part 121.91S(d) Delta Air Lines, Inc. January 14, 2016 Page 5 Public Interest Granting ofthis petition for exemption to 14 CFR 121.915(d) provides the following benefits to the public:
1. Compliance with a recurrenttraining schedule that returns pilots for schoolhouse training more frequently than provided for under a traditional 24 month program. In turn, this ensures pilots receive training and checking on required knowledge and skills as well as new and revised regulatory issues more often.
2. Immediate implementation of Delta's already proven and effective Pilot Continuing Qualification training program for all fleets with a commensurate increase in level of safety provided by the common program. 3. Adherence by Pilots, Instructors, Schedulers, and Administrators to a common single program standardized for all Delta Air Lines fleets.
4. Integration into a proven data-driven recurrent training/checking program underpinned by a mature Safety ManagementSystem providing empirical data results fasterthan from a traditional program.

No Adverse Effect on Public Safety The granting and use ofthis exemption would have no adverse effect on safety because:
1. The current Continuing Qualification program has proven to be effective and has been in place for nearly 5 years. 2. This program provides Delta pilots more training, more frequently. Training programs conducted under Part 121, Appendix H require a Captain to receive training and a Proficiency Check each year (as little as two simulator sessions every 12 months) and First Officers a Proficiency Check each 24 months (as little as two simulator sessions every 24 months). Under 121.441(a), a proficiency check for a pilot in command (Captain) is required within the preceding 12 months and within the preceding 24 months for all other pilots (SIC or First Officer). The Delta program, in contrast, provides a minimum oftwo simulatorsessions every nine months in a crew environment, thereby exceeding the level ofsafety ofthe more traditional program. Additionally, Delta pilots, pilots in command andseconds in command receive a Validation (Maneuvers Validation) or Evaluation (Line Operational Evaluation) every nine months. Under Delta's AQP protocols, a Maneuvers Validation is virtually identical to the traditional Proficiency Check.
3. While there are less expensive alternatives that fall within the scope of regulation, Delta desires to continue to invest in the current comprehensive program for all fleets. This decision is based on experience, feedback, and SMS derived data.Petition for Exemption- 14CFR Part 121.915(d) Delta Air Lines, Inc. January 14, 2016 Page 6


### Note

- Figures 1and2following depictDelta'scurrent36monthContinuingQualificationcycle. 

### (Figure 1) PILOTCONTINUINGQUALIFICATIONCURRICULUM 

### (1 Jan 

### 14-30 Jun 

### 15)
Delta's36month PilotContinuingQualificationcycl e is summarizedinthediagram shownbelow followedbya depictionofthefirst 18monthEvaluation Period ofthe cycle

. Notes: SPOT

## =SpecialPurposeOpera tionalTraining; SET

## =SelectedEventTra ining 

### 36 MonthCycle

18 Mo. Evaluation PeriodA 18Mo. Evaluation PeriodB 

# ..------------------

# --·
9Mo. 9Mo

. 601 641 602 642

eleamlng elearning elearnlng elearning 

# t----------------------------------------t

18 Month Evaluation PeriodA
Jan 14 Sep 14Retyrn Oct 14-Jyn 15 Return Qil£.1 Qil£.1 Module Briefing Module Briefing FirstLook First Look SPOT/SET SPOT

SPOT

**~**

**~** Module Briefing/SV (Ops) Module Briefing/SV(Ops) SPOT MV LOEPetition for Exemption- 14CFR Part 121.91S(d) Delta Air Lines, Inc. January 14, 2016 Page 7 

## (Figure2) PILOTCONTINUING QUALIFICATIONCURRICULUM (1 Jul15-31 Dec 16)
Delta's36 month PilotContinuing Qualificationcycl e is summarized in thediagram shownbelow followed bya depictionofthe second 18 month EvaluationPeriodofthecycle. Notes: SPOT

## =SpecialPurposeOperationalTraining; SET

## =Sel ectedEventTraining 

### 36 MonthCycle

18Mo. Evaluation PeriodA 18 Mo. Evaluation Period B 

# ...------------- _..,.. 9Mo

. 9Mo

. 9Mo. 603 643 604 644

elearning elearning elearnlng elearnlng 

# +----------------------------------------
....

18 Month Evaluation Period B Jyt 15- Mar 16Return Apr16 pee 16 Betyrn

Module Briefing Module Briefing

--...



### ~ First Look FirstLook SPOT/SET SPOT

Module Briefing/SV (Ops) Module Briefing/SV (Ops) SPOT 

### MV LOEPetition for Exemption- 14 CFR Part 121.915(d) Delta Air Lines, Inc. January 14, 2016 Page 8

Conclusion The relief requested in this petition for exemption focuses on the quality, volume, and frequency of Continuing Qualification training for pilots on fleets new to Delta Air Lines. This request is predicated on the conditions and experience shown under the "Nature and Extent of Relief Requested", the "Supportive Information" and "Public Interest" discussion listed above which, when considered in their entirety, will provide a higher level of safety than what is provided by the existing rule while improving Delta's ability to provide quality air service with greater benefits to the public, the FAA, and Delta Air Lines.

Please contact Chuck Schramek, Director- QA, Compliance, & Business Support at 404- 715-1112 (office) ifyou have questions or require additional information.
Sincerely,

S hen M. Dickson SeniorVice President Flight Operations Delta Air Lines, Inc.Petition for Exemption- 14CFR Part 121.915(d) Delta Air lines, Inc. January 14, 2016 Page 9 Summary for Federal Register Petitioner: Delta Air Lines, Inc. Affected Regulations: 14 CFR Section 121.915(d). (SubpartY- Advanced Qualification Program

- Cont'muing Qualification Curriculum), in pertinent part: (d) "Duration ofcycles andperiods. Initially, the continuing qualification cycle approved foran AQPmustnotexceed24 calendarmonths in duration, andmust include two ormore evaluation periods ofequal duration. Afterthat, upon demonstration bya certificate holderthatan extension is warranted, the FAA may approve an extension ofthe continuing qualification cycle to a maximum of36 calendarmonths in duration."
Summary of Relief Sought:

Delta Air Lines, Inc., Operating Certificate DALA026A, petition for relief from 14 CFR 121.915(d) to allow all Delta fleets, new as well as incumbent, to utilize the currently approved Delta Continuing Qualification training program. The current program for all Delta fleets consists ofa 36 month cycle with two 18 month evaluation periods further segmented into four 9 month return intervals for pilot training and checking. Approval would sanction entry of any new fleet, such as the A-350, into the proven and common Continuing Qualiftcation training program long used for all Delta fleets regardless of make, model, or manufacturer (e.g. MDBB, 8717, 8737, 8757, 8767, 

### 8777, 8747, A320, and A330).