April 7, 2014

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 Aviation 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 rating 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 accomplished 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 requirements 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 and “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 command 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 rating. 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 with 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 challenges” 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 hardship 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 hesitate 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