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 11, 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 121.652(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 pilots-in-command 

(PIC) who have not yet accumulated 100 hours (50, if reducible) in their current aircraft 

type. 

II. Section of the FAR Affected

Section 121.652, Landing weather minimums: IFR: All certificate holders. §121.652

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-half 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 §121.652(a) 2

III. Relief Requested

This exemption would grant 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 

precision approaches at the destination and alternate airports for pilots-in-command 

(PIC) who have not yet accumulated 100 hours (50, if reducible) in their current aircraft 

type.

(a) The PIC and SIC will be trained and 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) equipment.

(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 crosswind 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 FAR §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. 

Another 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 

other factors also played a role.
Compass Airlines Petition for Exemption from FAR §121.652(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 

accurate 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 approaches 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 published 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 visibility 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, the 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 limitations proposed in this petition, more than compensate 

for the experience requirements of FAR §121.652(a).
Compass Airlines Petition for Exemption from FAR §121.652(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 adjustment of landing minimums. Further, the 

present §121.652(a) does not appropriately recognize and credit the positive 

contribution that modern 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 operating 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 pilots-in-command 

(PIC) who have not yet accumulated 100 hours (50, if reducible) in their current aircraft 

type.
Compass Airlines Petition for Exemption from FAR §121.652(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 exemption 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

Manager of Policy, Process and Compliance

Compass Airlines

612-713-6842

gary.mcvaney@compassairline.com

cc: Mr. John Strange Principal Operations Inspector, Federal Aviation Administration, FSDO–EA27-IAD