September 9, 2012 Pinnacle Airlines, Inc.

40 S. Main St.

Suite 1400 Memphis, TN 38103

Ph 901-348-41 00

Fax 901-348-4103

U.S. Department of Transportation

Docket Operations, M-30 West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Dear, Sir/Madam

Pinnacle Airlines, Inc., REXA257A petitions the adm inistrator for extension o f Exemption 10184

in relief of FAR 121.652.

Approval of this Exemption will benefit the flying public by improving reliability of air service for numerous communities served by Pinnacle Airlines. Also, by reducing the number of diversions caused by low weather minimums, safety will be enhanced due to the fact diversions are rarely practiced, whereas Category II approaches are highly trained and monitored.

Thank you for your consideration of our request. Please do not hesitate to contact me if you have any questions concerning this proposal.

/Santi Lombardo/ VP, Flight Operations (FAR 119 Director of Operations )

## Conditions and limitations:

Pinnacle Airlines proposes the following conditions and limitations in association with this proposal when operating under this exemption:

1. This exemption will apply to the CL-65 fleet.

2. Pinnacle Airlines must maintain authority to operate under the provisions of OpSpec C059.

3. This exemption will only apply to Category I operations.

4. Pinnacle Airlines will maintain a “Crew Pairing” po licy which ensures either the PIC or SIC has at least 75 hours of line operating flight time as eith er the PIC or SIC in the appropriate seat, in the type aircraft being flown.

5. The PIC and SIC must be fully qualified for Category II operations.

6. The aircraft and associated airb orne systems must be fully functional for Cat. II operations.

7. A coupled approach is used for the approach, to decision height or until initiation of a missed approach.

8. The flight crew must use an appropriate Ca tegory II instrument approach procedure.

9. Category 1 instrument approach procedures or la ndings will not be initiated or completed when the weather conditions are below 4000 RVR (3/4 Mile Visib ility) and if eith er the cross-wind component exceeds 15 knots or the braking action is reported as less than good.

10. Pinnacle Airlines pilots who do not meet the 300 hour PIC requ irement in turbojet airplanes to conduct Category II operations in accordance w ith approved operations specifications C59(d) may conduct Category II operations under the appropriate provisions of this exemption provided he or

she has accumulated 300 hours as a pilot in a turbojet airplane.

Pinnacle Airlines FAR 121.652 Exemption Application 4

## Procedures for complying with the conditions and limitations associated with this exemption:

Condition 1:

This exemption will appl y to the CL-65 fleet

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading



### Condition 2:

Pinnacle Airlines mus t maintain autho rity to operate under the provisions of OpSpec C059

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading



### Condition 3:

This exemption will only appl y to Category I operations

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading

Pinnacle Airlines FAR 121.652 Exemption Application 5

### Condition 4:

Pinnacle Airlines will maintain a crew pairi ng policy which ensures either the PIC or SIC has at least 75 hours of line ope rating flight time as eith er the PIC or SIC in the appropriate seat, in the t ype aircraft being flown

-Pinnacle currently operates with a crew pairing policy which meets the above requirement. This policy is located in sect ion 5 of the FOM, a reference to this Exemption will be added to the FOM ensuri ng that if the crew pairing policy is not maintained, the Exemption will not be used.



### Condition 5:

The PIC and SIC must be fully qualified for Category II operations

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading



### Condition 6:

The aircraft and associated airborne systems must be fully functional for Cat. II operations

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading and the Mi nimum Equipment Lists (MEL’s) in all affected aircraft will be updated to reflect this limitation

Pinnacle Airlines FAR 121.652 Exemption Application 6

### Condition 7:

A coupled approach is used for the approa ch

, to decision height or until initiation of a missed approach

.

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading



### Condition 8:

The flight crew must use an appropria te Category II instrument approach procedure

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading



### Condition 9:

Category 1 instrument approach procedures or landing s will not be initiated or completed when the weather conditions are below 4000 RVR (3/4 Mile Visibility) and if either the cross-wind component exce eds 15 knots or the braking action is reported as less than good.

-This condition will be added to the Fli ght Operations Manual (FOM) under the Exemption 10184 heading

Pinnacle Airlines FAR 121.652 Exemption Application 7

### Condition 10:

Pinnacle Airlines pilots who do not meet the 300 hour PIC require ment in turbojet airplanes to conduct Category II operations in accordance with approved operations specifications C59(d) may conduct Categor y II operations under the appropriate provisions of this exemp ti on provided he or she has accumulated 300 hours as a pilot in a turbojet airplane.

-This condition will be contained in the Fli ght Operations Manual (FOM) under the Exemption 10184 heading

Pinnacle Airlines FAR 121.652 Exemption Application 8