Comment from Air Line Pilots Association, Int'l

Summary: The Air Line Pilots Association, International (ALPA), opposes the petition by ASJR Aviation, LLC seeking an exemption to allow Designated Pilot Examiners (DPEs) to conduct proficiency and competency checks in full motion flight simulators. ALPA argues that DPEs lack the necessary experience with specific air carrier Standard Operating Procedures (SOPs) and policies that are required of Aircrew Program Designees (APDs), Aviation Safety Inspectors (ASIs), or Training Center Evaluators (TCEs).