Captain Ron Thomas

Managing Director

Flight Operations

December 19, 2015

Docket Management Facility US Department of Transportation

1200 New Jersey Avenue, SE West

Building Ground Floor Room W12-140

Washington, DC 20590

Subject: Related Aircraft Exemption Requests for American Airlines (AALA025A) 4333 Amon 

Carter Blvd. Fort Worth, Texas 76155

References:

▪ Title 14 CFR §121.438 Pilot Operating Limitations and Pairing Requirements

▪ Title 14 CFR §121.652 Landing Weather Minimum: IFR: All Certificate Holders

American Airlines requested and was granted related aircraft designation for the Boeing 757 

(Base Aircraft) and Boeing 767 (Related Aircraft) in accordance with 14CFR §121.418(b).

In response to the approval, American Airlines requests the following Exemptions in connection 

with the related aircraft approval.

Related Aircraft Exemption for Crew Pairing

In accordance with 14 CFR §121.438(b), either the Pilot in Command or Second in Command 

must have at least 75 hours of Line Operating Flight Time on the specific airplane type to 

conduct operations under Part 121. 

American Airlines is requesting exemption approval to pair crewmembers with less than 75 

hours in either the B757 or the B767, with the requirement that the pilot in command or second 

in command to have at least 75 hours of combined line operating flight time in the B757 and the 

B767 for the purposes of crew pairing requirements.

This request is based on an extensive review of American Airlines FOQA, ASAP, and LOSA 

safety data covering over 1.5 million flights with no issues combining B757 and B767 line 

operating flight time over the past 26 years. In addition, American Airlines Initial, Transition, 

and Recurrent Training for both the PIC and SIC are conducted in both B757 and B767 

Simulators, when possible. This results in the crews being highly familiar with the flight 

characteristics of both aircraft. Therefore, the combined flight time from the B757 and the B767 

is equivalent to the 75 hour requirement with non-designated related fleets.

4601 Highway 360 MD 843

Fort Worth, Texas 76155

Office 817-967-5156

Ronald.Thomas@aa.com
Related Aircraft Exemption for High Minimums

In accordance with 14CFR § 121.652 (a), the landing minimums must be increased by 100 feet 

and one-half mile at Regular, Provisional, and Refueling airports, if the pilot in command (PIC)

has not served at least 100 hours as PIC in the specific airplane type in part 121 operations.

American Airlines is requesting exemption approval to combine the PIC flight times from either 

the B757 or B767 or both to meet the required 100 hours of PIC time requirement and not be 

subject to higher minimums in either aircraft type once the combined flight time exceeds 100 

hours.

American Airlines is currently operating under Airlines for America (A4A) Exemption 5549M, 

Regulatory Docket No. FAA-2000-8434, which allows a new pilot in command of any A4A 

member airline, and of any other similarly situated Part 121 certificate holder, who is subject to 

higher landing weather minimum requirements to operate to the normal, lower Category I and 

Category II minimums under the conditions stipulated in the exemption. Under 5549M 

Conditions and Limitations:

1. Each operator using this exemption must comply with 14 CFR §121.438.

Since the condition for relief from high minimums is related to 14 CFR §121.438(b), the Related 

Aircraft Exemption for Crew Pairing and this exemption request for relief from high minimums, 

must be granted in conjunction, in order to satisfy the conditions and limitations of Exemption 

5549M.

American Airlines is requesting both exemptions as part of the Related Aircraft designation 

approval. This exemption request does not deviate from the number of hours required by 14 CFR 

Part 121 nor American Airlines current authorization, and therefore does not jeopardize safety. 

American Airlines believes that granting approval to operate the B757 (Base Aircraft) and B767 

(Related Aircraft) in conjunction with these exemptions meets the intent of the regulations and is 

in the public interest.

Equivalent Level of Safety

This exemption request is actually a request to continue the same crew pairing on the B757 and 

B767 used by American Airlines since we began operating both aircraft more than 26 years ago. 

American Airlines has an FAA approved SMS program. A B757/767 related aircraft safety risk 

assessment was completed, which included an extensive review of American Airlines FOQA, 

ASAP, AQP and LOSA safety data covering over 1.5 million flights. The review of ASAP and 

LOSA data confirmed there were no submissions associated with concerns or problems related to 

our current practices. The review of AQP and FOQA data confirmed that the B757/767 crews 

operate at or better than the same high level of safety of all our other fleets, including fleets with 

a common type rating like the A319/320/321. This safety risk assessment was presented to the 

American Airlines Certificate Management Office and Southwest Region Office. Both agreed 

with the conclusion that the B757/767 pilots operate at or better than the same high level of 

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safety of all the other American Airlines fleets. American Airlines will continue to monitor 

B757/767 operations through our SMS program to ensure we continue to operate at an equivalent 

or greater level of safety.

Public Interest

To meet the requirements of Regulation 121.438 Pilot Operation Limitations, and Pairing 

Requirements and Regulation 121.652 Landing Weather Minimums: IFR: All Certificate 

holders, for each of the related aircraft separately, American Airlines would be required to satisfy 

twice the regulatory requirement for operating experience for related aircraft than we have been 

required to comply with for the last 26 years. An extensive safety risk assessment confirmed that 

our operating practice for the past 26 years is as safe, or safer, than all our other fleets. The 

American Airlines Certificate Management Office and Southwest Region Office agreed to this 

confirmation. Requiring American Airlines to add substantial training and cost where it is not 

warranted will subject the public to increased pricing and potentially reduced service. Approving 

this exemption request is in the public interest, as it will allow American Airlines to continue to 

provide service to the public to the same locations at the same frequency as they receive today. 

If there is a consideration to add any conditions and/or limitations to this exemption request, 

American Airlines respectfully requests to discuss them prior to issuance to ensure we provide 

the most information possible to assist in decision-making.

For questions or comments regarding this deviation request, please contact Captain Jim Thomas, 

Managing Director Flight Training and Standards (Jim.Thomas@aa.com) or me.

Regards,

Ron Thomas

Managing Director, Flight Operations

Ecc: Mr. Jerry Barron, Front Line Manager/Operations Supervisor

Captain Jim Thomas, Managing Director Flight Training and Standards

Captain John Duncan, Director of Standards Flight Crew Training

Alan Clay, Director Flight Operations Support

Att: Summary of American Airlines Petitions for Exemptions

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SUMMARY OF AMERICAN AIRLINES PETITION FOR EXEMPTIONS

Petitioner: American Airlines, Inc.

Regulations Affected: 14 CFR §121.438 (b) and 14 CFR §121.652 (a)

Description of Relief Sought: American Airlines requests an exemption to use the combined 

line operating flight time from the Boeing 757 (Base Aircraft)

and Boeing 767 (Related Aircraft) for the purposes of satisfying 

the 75-hour line operating flight time requirement for crew 

pairing. In addition, American Airlines requests an exemption to 

combine the Pilot in Command flight time from either the B757 

or B767 or both to satisfy the requirement of 100 hours of PIC 

operational flight time, in order to operate to the normal

Category I and Category II minimums.

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