AAM-11-387-E 

August 22, 2011 

 Exemption No. 10335 

 Regulatory Docket No. FAA-2011-0768 

Mr. Craig Chilcote 

Vice President Safety, Security and Compliance 

Pinnacle Airlines, Inc. 

1689 Nonconnoh Boulevard, Suite 111 

Memphis, TN 38132 

Dear Mr. Chilcote: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated July 14, 2011, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Pinnacle Airlines, Inc. (Pinnacle) for an exemption from part 120 of Title 14, Code 

of Federal Regulations (14 CFR) to allow Pinnacle to operate its drug and alcohol testing 

program in unison with Mesaba Airlines (Mesaba) drug and alcohol program. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Pinnacle. 

The FAA has issued grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 9927 (copy enclosed), the FAA 

found that granting this exemption would be in the public interest and would maintain a level 

of safety equivalent to that provided by the current regulations. 

Having reviewed your reasons for requesting an exemption, I find that— 
2 

 they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 9927; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No.9927 also 

apply to the situation you present; and 

 a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant Pinnacle Airlines an exemption from 14 CFR part 120 to 

the extent necessary to allow Pinnacle to operate its drug and alcohol testing program in 

unison with Mesaba Airlines (Mesaba) drug and alcohol program, subject to the conditions 

and limitations described below. 

Conditions and Limitations 

1. Pinnacle and Mesaba must submit MIS annual report data that is within 2 percent of 

 the administrator’s minimum annual rate. Specifically, the amount to be tested for 

drugs is no less than 24.5 percent (2% of 25%) and for alcohol no less than 9.8 percent 

(2% of 10%). 

2. Mesaba must continue to submit MIS annual report data for each year or portion 

thereof for which they are in operation. 

3. All Pinnacle locations must be in compliance with the requirement to display 

informational materials and hotline numbers within 6 months of the single operating 

certificate issuance date. 

4. All drug and alcohol testing records for the combined programs (Pinnacle and 

Mesaba) must be produced at one central employer location within 6 months of the 

single certificate issuance date. 
3 

5. The FAA’s confidentiality requirements are regulated by the DOT’s procedural 

regulation 49 CFR part 40, specifically § 40.25. The FAA concurs with the DOT’s 

determination regarding confidentiality requirements. Pinnacle must refer to the DOT 

decision. 

This exemption terminates on September 30, 2013, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

James R. Fraser, M.D. 

Deputy Federal Air Surgeon 

Enclosure