Southwest Airlines Co. Alan Kasher Managing Director / D irector of Operations Regulatory Pro grams & Compliance 27 02 Love F ield Dr. I TOP- 1DO 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 consecut ive 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 ope ration 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 Novembe r 1 2 , 20 1 5 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 i n 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 orig inal 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 ex tension 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 , So uthwest Airlines seeks a renewal for a m inimum of two years, with a longer ex te nsion preferred . We appreciate the FAA's consideration of this request.



# ~~ {\}(' Alan Kasher AK/js cc : Joe Marott , Di re ctor Flight Trai n ing Center Jim Stieve , Sen ior Manager Regulatory Program s 

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