Southwest Airlines Co. 

Alan Kasher 

Managing Director /Director of Operations 

Regulatory Programs & Compliance 

2702 Love Field Dr. I TOP-1 DO 

P.O. Box 3661 1 

Dallas, Texas 75235 

(469) 603-0948 

November 12, 2015 

Filed Electronically 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor, 

Rm W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

Re: Petition for Renewal of Exemption from 14 CFR § 121.434(c)(1)(ii); FAA-2002-11485 

Dear Sir: 

Pursuant to Federal Aviation Regulation 14 CFR §11 .61 (b), Southwest Airlines Co. ("Southwest") hereby 

petitions the FAA for renewal of Exemption No. 7132, which permits Southwest to substitute a qualified 

and authorized check airman in place of an FAA inspector to observe a qualifying pilot in command ("PIC") 

while that PIC is completing the initial or upgrade training specified in 14 CFR part §121.434 (FAA-2002-

11485, previously Docket No. 29836). 

The FAA initially granted Exemption No. 7132 on February 28, 2000, and has extended it for seven 

consecutive two-year periods. Unless this exemption is extended once again, it will terminate on February 

28, 2016. Southwest requests that the FAA renew Exemption No. 7132 for at least two additional years. 

This request is consistent with the exemption renewals that the FAA has already granted to Southwest, as 

well as to other airlines. 

I. FAA HAS CONSISTENTLY FOUND THAT EXEMPTION 7132 IS IN THE PUBLIC INTEREST 

AND PROVIDES A COMPARABLE LEVEL OF SAFETY. 

Exemption No. 7132 grants Southwest relief from 14 CFR §121.434(c)(1)(ii) to the extent necessary to 

permit Southwest to substitute a qualified and authorized check airman in place of an FAA inspector to 

observe a qualifying PIC who is completing the initial or upgrade training specified in FAR §121.424 during 

at least one flight leg that includes a takeoff and a landing. Exemption No. 7132 at p. 2. 

In granting Southwest's exemption request and the subsequent renewals, FAA determined that such an 

exemption was in the public interest. Specifically, FAA found that for Southwest and other similarly 

situated commercial air carriers, "permitting a limited number of qualified and authorized check airmen to 

conduct certain PIC observations would benefit the public by reducing unnecessary costs that may 

influence the price of services to the public and by improving the airlines' ability to provide on- time, 

dependable air service." Exemption No. 7132 at p. 1. The FAA also found that the exemption "would not 

reduce the level of safety, provided the petitioner complies with certain conditions and limitations." 

These findings continue to hold true and Southwest's multi-year, uninterrupted safe operation pursuant to 

the exemption strongly supports its renewal. 
Re: Petition for Renewal of Exemption from 14 CFR § 121 .434(c)(1)(ii); FAA-2002-11485 

November 12, 2015 

2 

II. SOUTHWEST IS IN FULL COMPLIANCE WITH ALL OF THE EXEMPTION CONDITIONS AND 

LIMITATIONS. 

Southwest is in full compliance with all of the conditions and limitations specified in Exemption No. 7132 

and its subsequent renewals. Southwest believes that its performance under the exemption has been 

satisfactory to the FAA, as no indication to the contrary has been received. 

Ill. CONCLUSION 

All of the circumstances stated in Southwest's original request for this exemption and the preceding 

requests for its renewal, remain the same. There has not been any material change in the findings relative 

to public interest and safety that were the basis for granting the original exemption. As the FAA has noted, 

granting this exemption (and by extension the renewal of the exemption requested herein), would have no 

adverse effect on safety. Instead, it will allow Southwest Airlines to continue efficient and competent 

completion of observation flights through appropriate utilization of FAA resources and qualifying PIC's. To 

minimize the administrative burden on all parties, Southwest Airlines seeks a renewal for a minimum of 

two years, with a longer extension preferred. 

We appreciate the FAA's consideration of this request. 

{\}(' 

~~ Alan Kasher 

AK/js 

cc: Joe Marott, Director Flight Training Center 

Jim Stieve, Senior Manager Regulatory Programs & Compliance