April 7 , 201 4

Federal Aviation Administration U.S. Department of Transportation, Docket Operations, West Building Ground Floor,

Room W12

– 140, 1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Petition for Exemption

Dear Sir or Madam:

The Air Transport Association of America, Inc,. dba Airlines for America, on behalf of member Part 121 air carriers, petitions pursuant to Sections 11.61 and 11.63 of

the Federal Avi ation Regulations (“FARs”) for an exemption from the regulatory requirements of FARs 61.39(a) and (b) and 61.157(b) and (c) with regards to applicants for (i) an aircraft type rating to be added to an airline transport pilot certificate or (ii) a type rati ng to be concurrently completed with an airline transport pilot certificate.

Currently, FAR 61.39(b)( 1)(i) and (ii) provides for an exception from the requirements of FAR 61.39(a)(1) insofar as it allows the use of an expired knowledge test so long as the applicant is an employee of a Part 121, 125, or 135 certificate holder and “has satisfactorily accomp lished that operator’s approved pilot in command aircraft qualification training program and qualification training requirements for the certificate and rating sought.” FAR 61.39(b). In addition, FAR 61.157(c) provides for an exception from the requireme nts of FAR 61.157(b). Thus, an aircraft type rating applicant is exempt from ground and flight training, as well as practical test, on the areas of operation under 61.157(e) so long as the applicant is an employee of a Part 121 or 135 certificate

holder a nd “presents a training record that shows completion of the certificate holder’s approved pilot in command training program for the aircraft type rating.” FAR

61.157(c).

A4A requests that participants in an approved second in co mmand training program also be able to take advantage of the exceptions in FAR 61.39(b) and 61.157(c) , upon presenting a training record showing completion of the certificate holder’s approved second in command training program for the aircraft type ratin g. As a condition for accepting this relief, A4A member air carriers will agree not to allow their SICs to operate as PICs under their new ATP certificate until they have completed the air carrier’s approved PIC training program. To the extent necessary to receive the benefits

of the above

- mentioned requests, A4A also seeks a parallel exemption under FAR 61.51.Approval of the exemption requested herein is in the public interest inasmuch as it

would reduce unnecessary costs and facilitate compliance wit h new pilot qualification statutory requirements . The FAA has acknowledged in Notice N8900.184 that delays in the ATP certification process of SICs “could pose significant chall enges” to air carriers and the FAA itself due to the number of SICs who currently only hold a commercial pilot certificate and the training hours and certification activities required to provide ATP certification. Granting this narrowly tailored exemption request would alleviate some air carriers’ concerns about meeting the compliance deadline without compromising aviation safety.

A4A respectfully requests that the exemption be granted expeditiously. A delay in granting this exemption would result in h ardship to Part 121 air carriers and their customers inasmuch as otherwise qualified SICs would not be able to perform their duties, causing a loss of revenue to airlines that would ultimately affect the price of air transportation.

Please do not hesita te to contact me if you have any questions or require additional information in order to act on this petition.

Respectfully submitted,

Donald R. Dillman Managing Director, Flt. Operations

Airlines for America 1301 Pennsylvania Avenue

Suite 1100 Washington, DC 20004

(202) 626

- 4285

ddillman @airlines.org