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June 23, 2011 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE. 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

SUBJECT: Pinnacle Airlines, Inc Petition for Reconsideration 

Sir or Madame, 

In accordance with FAR 11.101, Pinnacle Airlines, Inc requests reconsideration for denial of 

exemption for 49 CFR part 40 drug testing requirements outlined in Regulatory Docket No. 

FAA2011-0049. 

Pinnacle and Mesaba Airlines can assure you that all requirements of 49 CFR Part 40 have been 

met by each air carrier separately. Mesaba met its burden to ensure that individuals crossing its 

threshold into safety-sensitive functions had been consistently, and without exception, screened 

for drug use. Therefore the public interest in ensuring that active drug users are detected and 

prevented from entering safety-sensitive positions had been met diligently by the airline. All 

records are currently maintained by the separate airlines in accordance with the requirements set 

forth by CFR 49 part 40 and will be available for inspection at a single location upon completion 

of the merger. 

Plans for the merger of assets of Mesaba Airlines by Pinnacle Airlines have changed since our 

request for exemption of 49 CFR part 40 drug testing requirements. Mesaba Airlines is now 

planning to surrender its certificate and the employees will become that of either Pinnacle 

Airlines or Colgan Airlines in essence, a merger 

We also fmd that other airlines have had exemptions approved that were requested for 

circumstances that do not materially differ. Delta Airlines requested exemption during the 

acquisition of Northwest Airlines and that request was approved on Regulatory Docket No. 

FAA2009-0308. US Airways, Inc requested an exemption with the acquisition of American West 

which was approved on Regulatory Docket No. FAA-2007-2738. Pinnacle Airlines disagrees 

Pinnacle Airlines 

Petition for Reconsideration 

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with the FAA's position that the acquisition of Mesaba is not a "merger" and is not supported by 

precedence. We conclude that this is a "merger". Mesaba will merge into two existing airlines 

and each merger would be essentially identical to previous airline mergers. 

It is our belief that there is no threat to the public because the due diligence of 49 CFR part 40 has 

been met by both companies. We affinn that all individuals that had been performing safety 

sensitive duties for Mesaba Airlines will have been consistently screened for drug use through an 

FAA approved and monitored drug testing program. Pinnacle has a process in place to ensure that 

only employees that are currently performing safety sensitive duties for Mesaba Airlines and 

subject to the regulations of 49 CFR Pari 40 would be permitted to perform safety sensitive duties 

for Pinnacle Airlines. Any employee that is not currently subjected to part 40 regulations would 

be required to complete the pre-employment process outlined in part 40. 

If we can provide additional information or be of any other assistance, please contact Marry Aim 

Morrow, Vice President of People at (901) 348-4258. Pinnacle Airline appreciates your 

reconsideration of this petition. 

Sincerely, 

Craig L. Chilcote 

Vice President Safety, Security and Compliance 

Pinnacle Airlines 

Petition for Reconsideration 

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