### PINNACLE A I R L I N E S. I N C. 

## September 11, 2012 Pin nacle Ai rlines, In c. 40 S. Mai n 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 

## I Madam Pin nacle Airlines, Inc., REXA257A petitions the Administrator for an extension of FAA Exemption 10208, in relief of FAR121.619. Approval of th is reques t for Pi n nacle Ai rli nes wi l l i ncrease the efficiency and reliability of the national airspace system, reducing weather related delays, improving completion factor, al l while saving fuel. These enhancements will improve the quality of air travel for the public good, while maintaining the highest standards of safety. Thank you for your consideration of our application. Please do not hesitate to contact me if you have any questions concerning this proposal. Respectfully subm itted,
/Santi Lombardo/ Director, Flight Operations Pinnacle Airlines, Inc.

## Pinnacle **Airlines FA** **R 121**  **.619 Exemption**  **Petition**

3 

# Conditions **and limitations:** 
Pinnacle Airlines proposes the following conditions and limitations in association with this proposal: I. Operations under this Exemption will be limited to only those destination airports in the 48 contiguous States and the District of Columbia. 2. Operations under this Exemption will be limited to only those airports at which an operable Category (CAT) I instrument landing system is available for use. 3. This Exemption will apply to the CL
-65
-2B 19 and CL
-65
-2D24 fleets and all Pinnacle Airlines Crews qualified on those fleets. 4. Before conducting operations under this Exemption, Pinnacle Airlines will verify that:
a. Each Pinnacle Airlines Dispatcher has the ability to display the location of each flight within 3 minutes of real time. b. The Pinnacle Airlines System Operations Control (SOC) has the capability to overlay weather returns with an update rate of at least once per five minutes.
c. The Pinnacle Airlines SOC has a system that provides its Dispatchers with a display of the specific aircraft routing as assigned by air traffic control (ATC) and actual filed flight plan routing. d. Each Pinnacle Airlines Dispatcher has a system available to display locations of other airborne aircraft including aircraft of other operators.
e. The Pinnacle Airlines SOC has a system that provides its Dispatchers with a display of planned and actual fuel at regular intervals along the route and the difference between planned and actual fuel. f. The Pinnacle Airlines SOC has a system available that automatically alerts its Dispatchers to special weather updates, changes in weather reports, forecasts and/or other significant weather
-related reports, and ensures that these can be relayed to Flight crews in an expeditious manner. g. Each Pinnacle Airlines Dispatcher has the capability to access the services of a qualified meteorologist approved by the POI whenever the Dispatcher believes that consultation is necessary to ensure safety of operations under this Exemption. The presence of an approved "Enhanced Weather Information System" satisfies this requirement.

## Pinnacle **Airlines FA** **R 121**  **.619 Exemption**  **Petition**

4 h. Each Pinnacle Airlines Dispatcher has the capability to expeditiously re-compute projected time of arrival from a "point aloft" to the intended destination in the event conditions occur that negatively impact the flight.
1. The Dispatch release will contain a statement for each flight Dispatched under this Exemption that states "ALTERNATE WEATHER EXEMPTION 10208 APPLIED." 5. Pinnacle Airlines will maintain at least CAT I approach authorization, OpsSpec C074, for those fleets to which this Exemption applies. Each aircraft operating under this Exemption must have all equipment needed for CAT I ILS approaches fully operational. 6. At the time of Dispatch, the Flight crew must be qualified to conduct a CAT I approach. PICs with less than the requisite minimum hours specified in 14 CFR 121.652 will not be used in operations under this Exemption unless the PIC has been trained in accordance with the requirements of Pinnacle Airlines Exemption 10184, and all of the conditions specified by Exemption 10184 are met. 7. Operations are not permitted under this Exemption at any airport at which thunderstorms are reported or forecast from I hour before through I hour after the estimated time of arrival if such reports or forecasts are in either or both the main body or the remarks section of the weather report or weather forecast. Furthermore, Pinnacle Airlines will not use Exemption 3585P or any subsequent Exemption granting similar relief regarding any kind of forecast of thunderstorms at the destination airport in conjunction with any operation conducted under this Exemption. 8. Each Pinnacle Airlines Dispatcher and PIC, who conducts operations under this Exemption, will be provided with a copy of the pertinent parts of this Exemption. This information will be retained in the Flight Operations Manual (FOM). 9. Operations under this Exemption are permitted but not required. 10. Pinnacle Airlines may use this Exemption in operations to airports within the 48 contiguous States and District of Columbia, and from outside those boundaries provided OPSpec A012 is maintained, and operations are conducted in accordance with the appropriate provisions of that OpSpec. II. Pinnacle Airlines will provide the Administrator, by the 15th of each month, reports that include the information listed below, during the preceding calendar month:
a. The total number of flights operated by Pinnacle Airlines under domestic rules to destinations within the 48 contiguous States and District of Columbia; b. The total number of flights operated under this Exemption, including those flights conducted under the appropriate provisions and limitations of OpSpec AO 12. For each flight operated, the dates, airport pairs, flight numbers, aircraft M/M/S, trended or geographical summary of flight planned fuel vs. actual arrival fuel, and contingency fuel must be listed. Report format will be in chronological order by fleet type;
c. The total number of flights that divert to an alternate airport; d. The total number of flights that divert to an alternate airport that are operated under this Exemption, and the reason for each diversion, such as weather conditions, mechanical problem, fuel quantity, passenger problem, air traffic, Crewmember, or any other reason. Pinnacle Airlines must fully document each diversion;

## Pinnacle **Airlines FA** **R 121**  **.619 Exemption**  **Petition**

5 e. The total number of flights, operated under this Exemption, that declare an emergency and the reason for such declaration, or during which flight a low fuel state occurs that results in actions being taken by ATC and/or Dispatch to provide priority handling, even if no emergency is declared. 12. Dispatch will not apply this Exemption when any of the following conditions exist:
a. When any originally or normally scheduled dispatch shift is not filled for any reason: including sick calls, personal leave etc. b. When the Dispatcher is within six months of successfully completing their initial Competence Check.
c. On a flight that has ACARS deferred. (Reference is made in some material pertaining to this exemption that if ACARS is unavailable you may use a radio patch for communication, this is only to allow communications when an ACARS failure has occurred after block out on a flight using this exemption. In no case shall a flight under this exemption be initiated without operable ACARS) d. If the Pinnacle Airlines SOC is experiencing power or computer outages 13. Flight Movement Forecasts, Flight Operations Forecasts, and Turbulence Plots will be the only EWINS products considered when applying this exemption.