September 9, 2012

Pinnacle Airlines, Inc.

40 S. Main St. 

Suite 1400

Memphis, TN 38103

Ph 901-348-4100

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 administrator 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” policy which ensures either the PIC or SIC has at 

least 75 hours of line operating flight time as either 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 airborne 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 Category II instrument approach procedure. 

9. Category 1 instrument approach procedures or landings 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 with 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 apply to the CL-65 fleet 

-This condition will be contained in the Flight Operations Manual (FOM) under 

the Exemption 10184 heading 

Condition 2: 

Pinnacle Airlines must maintain authority to operate under the provisions of 

OpSpec C059 

 

-This condition will be contained in the Flight Operations Manual (FOM) under 

the Exemption 10184 heading 

Condition 3: 

This exemption will only apply to Category I operations 

-This condition will be contained in the Flight Operations Manual (FOM) under 

the Exemption 10184 heading 

Pinnacle Airlines FAR 121.652 Exemption Application 5
Condition 4: 

Pinnacle Airlines will maintain a crew pairing policy which ensures either the PIC or SIC 

has at least 75 hours of line operating flight time as either the PIC or SIC in the 

appropriate seat, in the type aircraft being flown 

-Pinnacle currently operates with a crew pairing policy which meets the above 

requirement. This policy is located in section 5 of the FOM, a reference to this 

Exemption will be added to the FOM ensuring 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 Flight 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 Flight Operations Manual (FOM) under 

the Exemption 10184 heading and the Minimum 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 approach, to decision height or until initiation 

of a missed approach. 

 

-This condition will be contained in the Flight Operations Manual (FOM) under 

the Exemption 10184 heading 

Condition 8: 

The flight crew must use an appropriate Category II instrument approach 

procedure 

-This condition will be contained in the Flight 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 exceeds 15 knots or the braking action is 

reported as less than good. 

-This condition will be added to the Flight 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 requirement in turbojet 

airplanes to conduct Category II operations in accordance with 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. 

 

-This condition will be contained in the Flight Operations Manual (FOM) under 

the Exemption 10184 heading 

Pinnacle Airlines FAR 121.652 Exemption Application 8