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 without waiting 24 calendar months to petition for a 36 month 

cycle. 

Section of the Federal Aviation Regulations Affected 

14 CFR Section 121.915(d). (Subpart Y- Advanced Qualification Program- Continuing 

Qualification Curriculum), in pertinent part: 

(d) "Duration of cycles and periods. Initiafly1 the continuing qualification cycle approved for an 

AQP must not exceed 24 calendar months in duration, and must include two or more 

evaluation periods of equal duration. After that, upon demonstration by a certificate holder that 

an extension is warranted, the FAA may approve an extension of the continuing qualification 

cycle to a maximum of 36 calendar months in duration.~~ 

Nature and Extent of Relief Requested 

This petition seeks 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 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 of ground school and 2 simulator sessions every twelve (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 another day of simulator 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 of two 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 of targeted 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 of the 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 of 
Petition for Exemption- 14 CFR 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 pilot training and checking program in accordance with the 

precepts of an AQP as provided for in FAR 121.915 Subpart Y. 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 of this approach1 Qualification Standard criticality and currency 

determinations, which drive the intervals over which 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 of aircraft manufacturers and types. In short, Delta 

believes approval of this exemption is in keeping with the guidance provided in AC 

120- 54A which states, 

"To determine an equivalent level of safety of an airline's AQP, the entire 

training system must be examined as a comprehensive whole rather than 

considering any one component in 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 aircraft type. 

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 perform 
Petition 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 of scheduling 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 under the 

standard 24 month cycle with 12 month returns. 

Request for Expedited Consideration 

Delta is also requesting that, as part of this Petition for Exemption request, the public 

comment phase be waived as per Title 14 CFR Part 11.87(a), which states: 

"The FAA may not publish a summary of your petition for exemption and request 

comments if you present or we find good cause why we should not delay action on your 

petition. The factors we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a 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 of this petition for exemption to 14 CFR 121.915(d) provides the following benefits to 

the public: 

1. Compliance with a recurrent training 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 Management System providing empirical data results faster than 

from a traditional program. 

No Adverse Effect on Public Safety 

The granting and use of this 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 of two simulator sessions every nine months in a crew 

environment, thereby exceeding the level of safety of the more traditional program. 

Additionally, Delta pilots, pilots in command and seconds 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- 14 CFR Part 121.915(d) 

Delta Air Lines, Inc. 

January 14, 2016 

Page 6 

Note - Figures 1 and 2 following depict Delta's current 36 month Continuing Qualification cycle. 

(Figure 1) 

PILOT CONTINUING QUALIFICATION CURRICULUM 

(1 Jan 14- 30 Jun 15) 

Delta's 36 month Pilot Continuing Qualification cycle is summarized in the diagram shown below 

followed by a depiction of the first 18 month Evaluation Period of the cycle. 

Notes: SPOT = Special Purpose Operational Training; SET = Selected Event Training 

36 Month Cycle 

18 Mo. Evaluation Period A 18 Mo. Evaluation Period B 

.. --------------------· 

9Mo. 9Mo. 

601 641 602 642 

eleamlng elearning elearnlng elearning 

t----------------------------------------t 

18 Month Evaluation Period A 

Jan 14 Sep 14 Retyrn Oct 14- Jyn 15 Return 

Qil£.1 Qil£.1 

Module Briefing Module Briefing 

First Look First Look 

SPOT/SET SPOT 

SPOT 

~ ~ 

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

SPOT MV 

LOE 
Petition for Exemption- 14 CFR Part 121.91S(d) 

Delta Air Lines, Inc. 

January 14, 2016 

Page 7 

(Figure 2) 

PILOT CONTINUING QUALIFICATION CURRICULUM 

(1 Jul15- 31 Dec 16) 

Delta's 36 month Pilot Continuing Qualification cycle is summarized in the diagram shown below 

followed by a depiction of the second 18 month Evaluation Period of the cycle. 

Notes: SPOT = Special Purpose Operational Training; SET = Selected Event Training 

36 Month Cycle 

18 Mo. Evaluation Period A 18 Mo. Evaluation Period B 

... ------------- _..,.. 

9Mo. 9Mo. 9Mo. 

603 643 604 644 

elearning elearning elearnlng elearnlng 

+----------------------------------------.... 

18 Month Evaluation Period B 

Jyt 15- Mar 16 Return Apr 16 pee 16 Betyrn 

Module Briefing Module Briefing 

--... ~ First Look First Look 

SPOT/SET SPOT 

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

SPOT MV 

LOE 
Petition 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) if you have questions or require additional information. 

Sincerely, 

S hen M. Dickson 

Senior Vice President Flight Operations 

Delta Air Lines, Inc. 
Petition for Exemption- 14 CFR 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). (Subpart Y- Advanced Qualification 

Program - Cont'muing Qualification Curriculum), in pertinent part: 

(d) "Duration of cycles and periods. Initially, the continuing qualification cycle 

approved for an AQP must not exceed 24 calendar months in duration, and must 

include two or more evaluation periods of equal duration. After that, upon 

demonstration by a certificate holder that an extension is warranted, the FAA may 

approve an extension of the continuing qualification cycle to a maximum of 36 

calendar months 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 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 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).