AFS-11-429-E 

September 6, 2011 

 Exemption No. 10351 

 Regulatory Docket No. FAA-2011-0896 

Robert E. Cohn, Esq. 

Counsel for Shuttle America Corporation 

Hogan Lovells US, LLP 

555 Thirteenth Street, NW. 

Washington, DC 20004 

Dear Mr. Cohn: 

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 August 16, 2011, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Shuttle America Corporation (Shuttle America) for an exemption from 

§ 121.434(c) of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to 

allow Shuttle America and its pilots to count certain part 121 operating experience acquired 

or accomplished on EMB-170 aircraft while those pilots were employed by Republic Airline, 

Inc., as if that operating experience were accomplished at Shuttle America. 

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 Shuttle America. 

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

those presented in your petition. In Grant of Exemption No. 7539 (copy enclosed), the FAA 

found that an exemption would provide an equivalent level of safety. 
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That exemption permitted the affected pilots, who had acquired extensive operating 

experience in the 328JET under the Atlantic Coast Jet, Inc., air carrier operating certificate, to 

now operate the 328JET under the Atlantic Coast Airlines operating certificate. 

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

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

of Exemption No. 7539; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 7539 

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 Shuttle America Corporation an exemption from 

14 CFR § 121.434(c) to the extent necessary to allow Shuttle America pilots to use the 25 

hours of operating experience obtained while operating under the Republic Airline, Inc., air 

carrier operating certificate. This exemption also grants relief to the extent necessary to allow 

the Shuttle America pilots in command (PIC) to receive credit for the required FAA 

observation acquired while that PIC was operating under the Republic Airline, Inc., operating 

air carrier certificate. This exemption is subject to the conditions and limitations described 

below. 

Conditions and Limitations 

1. Prior to conducting operations under this exemption, Shuttle America must obtain 

amended operations specifications that include this exemption. 

2. Operations under this exemption are limited only to those prior Republic Airline, 

Inc., pilots who have completed the consolidation of training requirements set 

forth in § 121.434 as of the date of the issuance of this exemption. 

3. Shuttle America must develop and have approved by the FAA principal operations 

inspector, assigned to Shuttle America, a training module or modules that address 

the specific differences identified between Republic Airlines, Inc., flightcrew 

operating procedures and those of Shuttle America. These differences must be 

addressed and all affected pilots must pass a written/oral test that adequately 

evaluates the pilot’s knowledge of the subject differences. 
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4. No Shuttle America pilot may conduct part 121 operations under this exemption 

until satisfactory compliance with Limitation No. 3. 

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

Sincerely, 

/s/ 

David C. Gillion 

Acting Deputy Director, Flight Standards 

 Service 

Enclosure