American Airlines, Inc.

FAA-2006-26068 - Enforcement of 14 CFR 121.391(a) and 121.393(b)

October 6, 2006

Application for Exemption from 14 CFR 121.391 and 121.393

American Airlines petitions the Federal Aviation Administration for limited relief from the FAA's interpretation of FAR §§ 121.391(a) & 121.393(b), to the extent such interpretation: (1) requires a full complement of Flight Attendants onboard a passenger-carrying aircraft during the deplanement of passengers; and/or (2) prohibits a Pilot qualified in emergency evacuation procedures from substituting for the forward cabin Flight Attendant during the enplanement of passengers.

FAR § 121.393(b) authorizes American to reduce its complement of Flight Attendants onboard the aircraft at intermediate stops to one-half the number required by FAR § 121.391(a), rounded down to the nearest whole number, but never fewer than one Flight Attendant once the aircraft is in a static mode, parked at the gate, with the engines off and a floor-level exit open.

For years FAA Regions and Principal Inspectors have been inconsistent with their application and enforcement of these regulations. Other air carriers, including one carrier whose primary FAA oversight office lies within the same FAA Region as American's Certificate Management Office has operated successfully and without incident with less than full complements of Flight Attendants during the deplaning, and boarding phases at intermediate stops. That practice evidences the relief that American seeks in this petition will not adversely affect safety and validates the FAA's original safety analysis of the minimal risk to the traveling public while an aircraft is "parked at the gate." The other carrier has petitioned the FAA for similar relief and the FAA must treat American petition in a similar manner.

By: American, Capt. Donald Dillman

November 30, 2006

Re: Comments of The Allied Pilots Association

Pilot duties at American Airlines prior to flight differ from those at some other airlines. AA pilots are required to perform a walk around of the aircraft prior to each flight. The Captain typically must print a flight plan and the attached flight specific notes prior to each flight. This is accomplished either at the gate or in station operations. International flight planning is more extensive and time consuming than domestic planning.

The argument for the request to go below minimum manning level onboard the aircraft appears to be driven by a manning problem at the station. Gate agent request for flight attendant help is ripe for abuse. What may be a rare request at one airline could be the norm at another. There is no mention in the request document as to a limit to the number of times this exemption could be exercised.

By: APA, Captain Ralph Hunter

July 23, 2007

Re: Grant of Exemption

By: John Allen, Flight Standards