Compass Airlines, LLC
7500 Airline Drive , Suite 130 Minneapolis, MN 55450

www. compassairline.com

Compass Airlines Petition for Exemption from FAR §121.652 (a) 1 November 1 1 , 2010
Docket Management Facility US Department of Transportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W12

- 140 Washington, DC 20590

Compass Airlines Petition for Exemption from 14 CFR Part §121. 652 (a)

I. Introduction In accordance with Federal Aviation Regulation (FAR) 11.81, Compass Airlines (C77A868L) (Compass) hereby petitions the Administrator for an exemption, or other appropriate regulatory relief, from Section 121.6 52(a) to the extent necessary to allow Compass to substitute crosswind component and braking action restriction, along with a requirement to utilize automatic landing and approach coupler (ALAC) equipment, at the destination and alternate airports in place of the existing restrictions to decision height (DH) and visibility minimums of Category I precision approaches for pilots

- in

- command (PIC) who have not yet a ccumulated 100 hours (50, if reducible) in their curre nt aircraft type.

II. Section of the FAR Affected Section 121.652
, Landing weather minimums: IFR: All certificate holders . §121.6 52 states, in pertinent part, that: (a) If the pilot in command of an airplane has not served 100 hours as pilot in
command in operations under this part in the type of airplane he is operating, the MDA or DA/DH and visibility landing minimums in the certificate holder's operations specification for regular, provisional, or refueling airports are increased by 100 feet and one

- h alf mile (or the RVR equivalent). The MDA or DA/DH and visibility minimums need not be increased above those applicable to the airport when used as an alternate airport, but in no event may the landing
minimums be less than 300 and 1.Compass Airlines Petition for Exemption from FAR §121.6 5 2 (a) 2 III. Relief Requested
T his exemption would gr ant Compass relief from §121.652 (a) to the extent necessary to
allow Compass to substitute the following conditions and limitations in place of the existing restrictions to decision height (DH) and visibility minimums of Category I
pr ecision approaches at the destination and alternate airports for pilots

- in

- command (PIC) who have not yet a ccumulated 100 hours (50, if reducible) in their current aircraft type. (a) The PIC and SIC will be trained an d qualified for Category II , or trained to an equivalent level with respect to the airborne system use, ground facility use, associated procedures, and any other relevant topics

. In addition, low visibility instrument approach, landing, and missed approach scenarios are included in flight training using the applicable airborne system and appropriate training
devices or simulators for those scenarios. (b) Instrument landing system (ILS) or other precision approaches will be conducted using the aircraft automatic landing and approach coupler (ALAC) equip ment

. (c) Category I instrument approach procedures or landings will not be initiated when the weather conditions are below 4,000 RVR (3/4 mile visibility) and the cross

wind component exceeds 15 knots combined with a braking action report of less than “good.”

IV. Justification / No Adverse Effect on Safety FAR §121.652, commonly known as the High Minimums Captain rule, requires that both ceiling and visibility requirements be increased for pilots in command with less than 100 hours in type of aircraft operating under part 121. The rational for the original issuance
for FA R §121 .652 was based on several factors, many no longer of affect in today’s airline environment. One factor was the amount of time pilots needed to safely transition from airplanes powered by reciprocating engines to airplanes powered by turbojets.
Anothe r was the additional time needed to adjust to new airborne guidance and approach equipment like the automatic landing and approach coupler, radio altimeter, and flight director. Low visibility landing programs, flight characteristics of jet aircraft and
ot her factors also played a role.Compass Airlines Petition for Exemption from FAR §121.6 5 2 (a) 3 Compass believes it was not unreasonable for the FAA to require an increase of 100 feet and 1⁄2 mile visibility to the landing minimums for a pilot who had not served 100 hours as pilot in command. Present day airborne and ground based equipment is more

accu rate and more reliable than the airborne and ground based equipment when the first generation of jet transport aircraft was introduced.

In addition
, advances in simulation, particularly with enhanced visual systems have made training in low visibility ap proaches more realistic. Compass conducts training in simulators capable of replicating low visibility environments for all types of approaches. Compass pilots undergoing training in our upgrade program normally accomplish a minimum of 30 approaches to p ublished minimums. Because of advances in simulation technology since the early 1960s, the time spent in the low visibility approach environment of today’s simulators is of more training value than the combination of simulator/aircraft training of when this rule was promulgated.

Compass feels that in addition to improvements in simulation, the operating procedures which incorporate Crew Resource Management (CRM) with the improved airborne and ground equipment have contributed to making low visibil ity approach and landings among the least difficult maneuvers that a pilot is required to perform. Compass understands that the greater demand on a new captain are the strenuous task of operations to a landing surface that has a high crosswind and a runway surface that has a degraded level of braking action.

Unlike when this rule was first formulated the present day training programs are superior to those of the early 1960's and that, unlike the comparison between turbojet and piston

- powered airplanes, th e basic flight characteristics of transport turbojet airplanes do not differ significantly from one to another. Compass feels that the current aircraft qualification courses, conducted in a advanced simulator in modern visual systems and the operational li mitations proposed in this petition, more than compensate for the experience requirements of FAR §121 .652(a).Compass Airlines Petition for Exemption from FAR §121.6 5 2 (a) 4 V. Public Interest Compass believes that a grant of exemption would be in the public interest for the following reasons: (a) It is wholly consistent with previous exemptions granted in similar circumstances. (b) The present method depends exclusively on accumulating "flight hours in type" and often does not directly relate to actual low visibility operating experience, even though its sole effect is adjust ment of landing minimums. Further, the present § 121.652 (a) does not appropriately recognize and credit the positive
contribution that mod ern airborne systems, procedures, ground facilities, and training can make. (c) Increased safety by allowing flights to be completed to the scheduled airports that are familiar to flight crews rather than diverted to non

- routine alternate airports that flight crews are less familiar with. (d) Fuel consumption will decrease resulting in fewer emissions from Compass aircraft operat ing within the United States.

VI. Waiver of Public Notice Compass requests that a finding of good cause be made for waiving publication in the Federal Register. Publication of notice of this petition in the Federal Register would cause unnecessary delay to the petitioner. The relief requested in this petition currently resides in other exemptions, therefore there is no precedent set in granting this relief. If publication is required, a summary of this petition follows immediately below.

SUMMARY Compass Airlines (Compass) petitions the Administrator for an exemption, or other appropriate regulatory relief, from Section 121.652(a) to the extent necessary to allow Compass to substitute crosswind component and braking action restriction, along with a requirement to utilize automatic landing and approach coupler (ALAC) equipment, at the destination and alternate airports in place of the existing restrictions to decision height (DH) and visibility minimums of Category I precision approaches for pi lots

- in

- command (PIC) who have not yet a ccumulated 100 hours (50, if reducible) in their current aircraft type.Compass Airlines Petition for Exemption from FAR §121.6 5 2 (a) 5 VII. Conclusion In the past few decades, there has been a significant advancement in technology for flight simulation, flight crew training, and aircraft approach capability

. Aircraft are now much safer to operate due to these advancements. In consideration of these improvements and based on the information provided in this petition, we believe it is prudent for the FAA to grant Compass an exempti on from FAR §121.652 (a)

.

Please advise us if there is any further information you need for your review of this petition. Thank you for your consideration.

Sincerely,

Gary P. McVaney M anager of Policy, Process and Compliance Compass Airlines 612

- 713

- 6842 gary.mcvaney@compassairline.com

cc: Mr. J ohn Strange Principal Operations Inspector, Federal Aviation Administration, FSDO

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