1022 Airport Parkway ♦ Cheyenne, WY 82001 ♦ (307) 432

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# Great Lakes Airlines

PETITION FOR EXEMPTION: 14 CFR 135.223

Section Great Lakes Aviation, Ltd. is seeking exemption from:

FAR Part 135.223

EXTENT AND REASON FOR RELIEF

Great Lakes Aviatio n, Ltd. petitions the administrator for relief from the alternate weather requirements set forth in FAR 135.223 and to instead use the alternate weather requirements of FAR 121.619 for all domestic operations.

Great Lakes Aviation ’s Operation Specifica t i ons allow us to operate our Beec h 1900D’s under

FAR 121 and 135. Great Lakes utilizes the more restrictive guid ance provided in FAR 121 for

both operations (operations, maintenance, training, dispatching, etc. ) in order to enhance safety for the flying public, as well as maintain a consistency between the two o perations.

Our proposal would change the method for determining whether an alternate is required by utilizing one (1) set of rules (FAR 121.619) for our entire operation in lieu of utilizing two ( 2 ) different sets of rules (FAR 121.619 and FAR 135.223). This allowance would be contingent upon dispatching and tracking all flights (121 and 135) in accordance with FAR 121 Subpart U

, using a Great Lakes approved dispatcher.1022 Airport Parkway ♦ Cheyenne, WY 82001 ♦ (307) 432

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Explanation of 135.223 and 121.619:

FAR 135.223 “IFR: Alternate Wea ther Requirements” is slightly more restrictive in nature than its 121 counterpart, FAR 121.619. Below are the criteria to determine if an alternate will be required using FAR 135.223:

CEILING

o Add 1500 feet to the lowest circling approach for the destinat ion airport; or if no circling approach exists:

o Add 1500 feet to the lowest approach minimums for the destination airport ; or 2000 feet, whichever is higher.

VISIBILITY

o 3 miles; or

o 2 miles more than the approach visibility requirements for the approach in tended for use, whichever is higher

If the weather is below the above requirements at the destination airport, an alte rnate is required

.

FAR 121.619 states that an alternate is required unless the weather at the destination is at

least :

CEILING

o 2000 f eet and;

VISIBILITY

o 3 miles

In accordance with Great Lakes’ Operatio ns Specifications

, Great Lak es is required to dispatch all flights (121 and 135) under the more restrictive FAR 121 subpart U. Great Lakes has chosen this requir emen t for our operation to maintain the additional safety margins for flight crews, passengers, as well as to the overall operation.

A Great Lakes Aviation, Ltd. flight operated under 121 or 135 is under constant surveillance by a dispatcher, as well as provided c ontinuous communication capabilities with our dispatch center located in Cheyenne, WY. C ompany dispatcher s provide e ach Pilot in Command continuous updates on the weather at their destination and alternates, NOTAMS, etc. In

addition , Great Lakes Aviation p rovides each Pilot in Command / Dispatcher a means to directly

communicate with each other by use of AIRINC , and/or company radio. A flight can be in contact with the company anywhere throughout our route structure at any time.1022 Airport Parkway ♦ Cheyenne, WY 82001 ♦ (307) 432

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JUSTIFICATION FOR RE QUEST

FAR 135.223 and FAR 121.619 both provide similar requirements for air carriers to determine if

an alternate is required for a flight. These regulations assume that there will be an adequate
level of margin between the weather requirements of these ru les and the minimums imposed for

tha t instrument approach procedure available at that airport.

Depending upon the minimums associated with that approach, if relief is granted from 135.223
and the alternate weather requirements of 121.619 are allowed to be used for both op erations,
there would always be an adequate weather margin between the alternate weather requirement

and instrument approach minimums . In many cases, this margin will be in upwards of 1800 feet
and 2 1⁄2 sm visibility if using a precision approach, and as low as 1000 feet and 1sm visibility if
using a non

- precision approach. W ith a dispatcher continuously monitoring each flight, any
weather changes that would reduce these margins to a point where it may affect the ability of

the crew to land can be communi cated to the Pilot in Command . This can be done prior to
reaching that airport and any changes needed to be made to the flight plan can be done without
undue delay

. These procedures are already set in place in our standard operating procedures

, and have be en utilized in this manner since Great Lakes became an FAR 121 air carrier many

years ago.

It is assumed that FAR 135.223 is more restricti ve in nature due to the limited requirement s for dispatchers for carriers that operate under FAR 13 5. As a result of t he limited regulations requiring dispatchers under 135 , it is possible that an increased weather margin would be

needed to add an additional margin of safety for the Pilot in Command in the event un

forecasted weather should prevent the arrival at that a irport, especially if that Pilot in Command is not provided continuous updated weather from a dispatch center.

It is under these pretenses that Great Lakes Aviation requests the ability to utilize FAR 121.619 for determining alternate weather requiremen ts. The following would be requirements imposed on Great Lakes Aviation, Ltd. to utilize such an exemption:

1) All FAR 135 flights are to be dispatched and under continuous surveillance by a Great Lakes Aviation dispatcher, trained in accordance with Great L akes’ approved Dispatcher

program. 2) All FAR 135 flights will be dispatched in accordance with FAR 121 Subpart U

. 3) Each dispatcher will be provided a system to display the location of each flight and current/significant weather. 4) The dispatch system will have a system to alert the dispatcher when there is a change to a weather forecast, METAR, or a special weather update. 5) Great Lakes Aviation will provide a means of communication to allow all flight crews and

d ispatchers continuous communication ability for w eather changes, dispatch release changes, etc. throughout Great Lakes’ route structure. 6) This relief will only applicable to airports within the 48 contiguous United States and the

District of Columbia

.1022 Airport Parkway ♦ Cheyenne, WY 82001 ♦ (307) 432

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PUBLIC SAFETY

P ublic safety would not be affected wh ile utilizing FAR 121.619 alternate weather requirements.
All flights would continue to be dispatched and followed by a Great Lakes Aviation dispatcher.
All Great Lakes flights are conducted with two qualified crewmembers, effectively adding to the
safety margin when weather becomes a factor. The D ispatchers / Pilot in Command will have
continuous communication ability between e ach other during each flight and through out ou r

entire route structure . Any changes in the airport weather or changes to the flight plan ca n easi ly

be communicated without delay

.

While utilizing the FAR 121.619 alternate weather requirements, Great Lakes would effectively
continue to operate at the same safety levels as any equivalent 121 air carrier. With the
technological advances in weather forecasting, improved weather monitoring equipment,
advanced communication capabilities, and improvements in Flight Crew training requirements,
Great Lakes’ operation would continue to operate at a high level of safety.

PUBLIC INTEREST

If this exemption should be granted, we feel it is in the public interest for the following reasons:

This proposal would guarantee that the weather margins between the instr ument
approach minimums and the alternate weather requirements of 121.6 19, as well as the

r equirement for each flight to be dispatched by an approved dispatcher would provide a level of safety in the event un

- forecast ed weather should cause ceilings and visibilities to
drop and still allow enough margin to compl ete the flight

.

Having all operat ions (121 and 135) dispatched using the same alternate weather
requirements will create consistency between operations, thus reducing possible errors
in determining alternate correct w eather minimums and the possible ramifications of

those errors.1022 Airport Parkway ♦ Cheyenne, WY 82001 ♦ (307) 432

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SUMMAR Y

Great Lakes Aviation , Lt., holder of operating certificate GLBA031A, petitions the use of
FAR 121.619 alternate weather requirements in lieu of the requirements of 135.223 for all flights

conducted under FAR 135 under the basis that the carr ier currently dispatches all 121 and 1 35
flights in accordance with the requirements set forth in FAR 121 Subpart U

.

This is contingent upon the following requirements:

1) All FAR 135 flights are to be dispatched , and under continuous surveillance by a Great Lakes Aviation dispatcher, trained in accordance with Great Lakes’ approved Dispatcher

program. 2) All FAR 135 flights will be dispatched in accordance with FAR 121 Subpart U

. 3) Each dispatcher will be provided a system to display the location of each flight a nd current/significant weather. 4) The dispatch system will have a system to alert the dispatcher when there is a change to a weather forecast, METAR, or a special weather update. 5) Great Lakes Aviation will provide a means of co mmunication to allow all fligh t crews and

d ispatchers continuous communication ability for weather changes, dispatch release changes, etc. throughout Great Lakes’ route structure. 6) This relief will only applicable to airports within the 48 contiguous United States and the

District of Co lumbia

.

Thank you for your consideration of this request of exemption. I can be reached by email or
phone to answer any questions you may have.

Email: jlinnebur@flygreatlakes.com

Phone: 307

- 432

- 7210

Respectfully;

Joseph Linnebur Director of Operations

Gr eat Lakes Airlines 1022 Airport Parkway Cheyenne, WY 82001