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PINNACL E 

AIRLINES , INC . 

Exemption 8655B Application 
Pinnacle Airlines, Inc. 

1689 Nonconnah Blvd. 

Suite 111 

Memphis, TN 38132 

PINNACL E Ph 901-348-4100 

AIRLINES , INC . Fax 901-348-4103 

January 27th, 2010 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Attention Mr. Leo Mollis 

Dear, Mr. Mollis 

Pinnacle Airlines, Inc., REXA-257A requests the approval for issuance of an exemption similar to 

Exemption 8655B, in relief of FAR 121.619. 

Approval of this exemption for Pinnacle Airlines will increase the efficiency and reliability of the 

national airspace system, reducing weather related delays, improving completion factor, all 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 submitted. 

Michael Garvirr Jr. 

VP, Flight Operations 

(FAR 119 Director of Operations) 
Pinnacle Airlines 

Exemption 8655B, Proposal 

TABLE OF CONTENTS 

Naming of Exemption:. 3 

Conditions and limitations: 3 

Procedures for complying with the conditions and limitations associated with this 

exemption: 6 

Condition 1: 6 

Condition 2: 6 

Conditions*. 6 

Condition 4a: 6 

Condition 4b: 7 

Condition 4c: 7 

Condition 4d: 7 

Condition 4e: 8 

Condition 4f: 8 

Condition 4g: 8 

Condition 4h: 9 

Condition 4i: 9 

Conditions: 9 

Condition 6: 10 

Condition 7: 10 

Conditions: 10 

Condition 9: 11 

Condition 10: 11 

Condition 11: 11 

Condition 12: 12 

Dispatch Training Material 13 

Reporting Procedure for Exception 8655B 39 

Spreadsheet for Tracking 8655 Statistics 40 

Flight Operations Manual Material. 41 

Risk Assessment Tool. 44 

Pilot Training Material: 46 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Naming of Exemption: 

Throughout this application references are made to our application for Exemption 8655b for clarity sake. We 

understand that when Pinnacle Airlines receives approval for this exemption the actual exemption number 

will be different. When the new exemption number is assigned we will use that exemption number from that 

point forward for all references to said exemption. 

Conditions and limitations: 

Pinnacle Airlines proposes the following conditions and limitations in association with this proposal: 

1. 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) II instrument landing system is available for use. 

3. This Exemption will apply to the CL-65-2B19 and CL-65-2D24 fleets and all Pinnacle Airlines Crews 

qualified on those fleets. 

4. Before conducting operations under this Exemption, Pinnacle Airlines will demonstrate to your 

satisfaction 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 Pirmacle 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. 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

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. 

i. The Dispatch release will contain a statement for each flight Dispatched under this 

Exemption that states "ALTERNATE WEATHER EXEMPTION 8655B APPLIED." 

5. Pinnacle Airlines will maintain at least CAT II approach authorization, OpSpec C059, for those fleets 

to which this Exemption applies. Each aircraft operating under this Exemption must have all 

equipment needed for CAT IIILS approaches fiilly operational. 

6. At the time of Dispatch, the Flight crew must be qualified to conduct a CAT II approach. PICs with 

less than the requisite minimum hours specified in 14 CFR 121.652 will not be used in operations 

under this Exemption until Pinnacle Airlines is granted Exemption 5549, the PIC has been trained in 

accordance with the requirements of that Exemption, and all of the conditions specified by Exemption 

5549 are met. 

7. Operations are not permitted under this Exemption at any airport at which thunderstorms are reported 

or forecast from 1 hour before through 1 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. 

11. Pinnacle Airlines will provide the Administrator, by the 15* 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 Disfrict of Columbia; 

b. The total number of flights operated under this Exemption, including those flights 

conducted under the appropriate provisions and limitations of OpSpec A012. For each 

flight operated, the dates, airport pairs, flight numbers, aircraft M/M/S, frended or 

geographical summary of flight planned fiiel 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, fiiel quantity, passenger problem, air traffic, Crewmember, or any other reason. 

Pinnacle Airlines must fully document each diversion; 

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 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

actions being taken by ATC and/or Dispatch to provide priority handling, even if no 

emergency is declared. 

12. Dispatch will not apply Exemption 8655 when any of the following conditions exist: 

a. During periods of uncovered Dispatch shifts (ie, due to sick calls etc.) 

b. When the Dispatcher is within six months of successfully completing their initial 

Competence Check. 

c. When doing so will cause the Dispatcher to follow more than two flights released under 

Exemption 8655. 

d. On a flight that has ACARS deferred. 

E If a dispatcher is using Exemption 8655, they may not be simultaneously flight following 

more than five flights. 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Procedures for complying with tlie conditions and 

limitations associated with this exemption: 

Condition 1: 

Operations under this Exemption will be limited to only those destination airports in the 

48 contiguous States and the District of Columbia. 

-This condition will be added to the Flight Operations Manual (FOM) under the 

Exemption 8655B paragraph. 

Condition 2: 

Operations under this Exemption will be limited to only those airports at which an 

operable Category (CAT) II instrument landing system is available for use. 

-This condition will be added to the Flight Operations Manual (FOM) under the 

Exemption 8655B paragraph. 

Condition 3: 

This Exemption will apply to the CL-65-2B19 and CL-65-2D24 fleet. 

-This condition will be added to the Flight Operations Manual (FOM) under the 

Exemption 865 5B paragraph. 

Condition 4a: 

Each Pirmacle Airlines Dispatcher has the ability to display the location of each flight 

within 3 minutes of real time. 

-The Flight Explorer software currently used by Pinnacle Airlines Dispatch 

provides an industry best update of real time traffic flow information. The update 

rate is once every 10 seconds, far exceeding the 3 minute requirement of this 

Exemption. 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Condition 4b: 

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. 

-Pinnacle Airlines will have on the Northwest Airlines (NWA) part of our 

operation the NWA version of flight explorer. The TP's are updated as needed or 

every 15 minutes. The base reflectivity radar in NWA's FE is from Unisys and 

updates every 5 minutes. The echo tops product updates every 10 minutes. The 

single site radar update frequency is controlled by the National Weather Service 

and varies between 5 minutes and 12 minutes. 

Condition 4c: 

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. 

-The Flight Explorer Analyze Routes tab opens the Route Analyzer tool showing 

the planned, previous, and current routes of a particular flight. This system is 

currently in use by all Pinnacle Airlines Dispatchers. 

Condition 4d: 

Each Pinnacle Airlines Dispatcher has a system available to display locations of other 

airborne aircraft including aircraft of other operators. 

-Flight Explorer provides the most accurate and reliable stream of air traffic data 

available in the industry. The data is based upon radar, satellite and other tracking 

information supplied by the FAA and other sources. Once Flight Explorer 

receives this data, it is processed and sent to the Flight Explorer client software 

via the Internet. This system is currently in use by all Pinnacle Airlines 

Dispatchers. 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Condition 4e: 

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. 

-To meet this requirement, position reports will be required from pilots upon 

reaching top of climb, and every thirty minutes thereafter. The pilots will be 

reminded of this requirement in the release remarks. "ALTERNATE WEATHER 

EXEMPTION 8655B APPLIED, POSITION REPORTS REQUIRED. This 

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

Exemption 865 5B paragraph. 

Condition 4f: 

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. 

-The Dispatch User Interface (DUI) currently provides weather alerts for new 

METAR's, Specials, TAF's, and TP's to all Dispatchers. The system then 

automatically forwards TP's to any aircraft affected by them. The Dispatcher will 

be required to forward the new METAR's and TAF's via ACARS. The 

requirement to forward the new information via ACARS is incorporated in the 

Dispatcher training 

Condition 4g: 

Each Pinnacle Airlines Dispatcher has the capability to access the services of a qualified 

meteorologist 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. 

-We have an approved EWINS program on our Operations Specification AOIO. 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Condition 4h: 

Each Pirmacle 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. 

-The DUI allows us to easily re-calculate a flight from any point on the flight plan 

or the aircrafts present position (latitude/longitude from the last radar contact) to 

the destination, alternate, or a diversionary airport. This re-calculation may then 

be ACARS directly to the aircraft with any new routing, bums, times, ETA, etc... 

Condition 4i: 

The Dispatch release will contain a statement for each flight Dispatched under this 

Exemption that states "ALTERNATE WEATHER EXEMPTION 8655B APPLIED." 

-The DUI will have a predefined remark for this so that all Dispatchers will have 

one standardized remark. This pull down list of remarks allows the Dispatcher to 

simply click on the appropriate remark to be added to the release. This procedure 

is included in Dispatcher training for this Exemption. 

Condition 5: 

Pinnacle Airlines will maintain at least CAT II approach authorization, OpSpec C059, for 

those fleets to which this Exemption applies. Each aircraft operating under this 

Exemption must have all equipment needed for CAT II ILS approaches fully operational. 

-The FOM will clearly define the requirement to have a CAT II aircraft, airport 

and crew in order to utilize this Exemption. If Pinnacle Airlines ceases to 

maintain OpSpec C059, operations will not be conducted with Exemption 8655b. 

Prepared by Flight Operations, 27 January 2010 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Condition 6: 

At the time of Dispatch the Flight crew must be qualified to conduct a CAT II approach. 

PICs with less than the requisite minimum hours specified in 14 CFR 121.652 will not 

be used in operations under this Exemption until Pinnacle Airlines is granted Exemption 

5549, the PIC has been trained in accordance with the requirements of that Exemption, 

and all of the conditions specified by Exemption 5549 are met. 

-Records are maintained in Crew Qual which show if Crewmembers are Category 

II qualified. These records will be checked by Dispatch prior to releasing a flight 

with this Exemption to ensure compliance with this requirement. 

Condition 7: 

Operations are not permitted under this Exemption at any airport at which thunderstorms 

are reported or forecast from 1 hour before through 1 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. 

-Operations under this Exemption will only be conducted by direction from a 

SOC Manager. Dispatchers must have all flights operated under this Exemption 

approved by the Duty Manager prior to release. The Duty Manager will review 

the details of all flights operated under this Exemption prior to approval. For 

Flights where the risks as determined from a Risk Assessment Tool fall between 

12 and 18, the decision will be escalated to the Director of Operations for 

approval. 

Condition 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). 

-Dispatchers will receive training on this Exemption and the details of the 

Exemption will be published in the FOM. 

Prepared by Flight Operations, 27 January 2010 10 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Condition 9: 

Operations under this Exemption are permitted but not required. 

-Utilization of this Exemption is at the discretion of the Captain, Dispatcher and if 

necessary, based on the risk assessment form, the Director of Flight Operations. 

Condition 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. 

-The Dispatch training material and FOM clearly limit the use of this Exemption 

to airports in the contiguous 48 States, District of Columbia and from airports 

outside these regions into airports in the 48 contiguous States and District of 

Columbia. 

Condition 11 : 

Pinnacle Airlines will provide the Administrator, by the 15'*' 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 Colimibia; 

B. The total number of flights operated under this Exemption, including those 

flights conducted under the appropriate provisions and limitations of OpSpec 

A012. 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, fiiel quantity, passenger problem, air traffic, 

Crewmember, or any other reason. Pinnacle Airlines must fully document each 

diversion; 

Prepared by Flight Operations, 27 January 2010 11 
Pinnacle Airlines 

Exemption 8655B, Proposal 

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. 

-The Dispatch training program has specific details on how to comply 

with the provisions of Condition 11. To comply with Pinnacle's policy to 

"Never Compromise Safety", we will track these requirements by 

requiring the Dispatcher to fill out a Risk Assessment Tool prior to 

approval by the Duty Manager. The Duty Manager will review the Risk 

Assessment Tool and the details of the flight prior to approving the use 

of Exemption 8655. For marginal cases the Duty Manager will escalate 

the decision to the Director of Flight Operations for approval. The Duty 

Manager will then track this information on an Excel spreadsheet along 

with the results of the flight. This data will be compiled into a report to 

be sent to the FAA POI no later than the 15 of the month following the 

activity. 

Condition 12: 

Dispatch will not apply Exemption 8655 when any of the following conditions exist: 

a. During periods of uncovered Dispatch shifts (ie, due to sick calls etc.) 

b. When the Dispatcher is within six months of successfully completing their 

initial Competence Check. 

c. When doing so will cause the Dispatcher to follow more than two flights 

released under Exemption 8655. 

d. On a flight that has ACARS deferred. 

E If a dispatcher is using Exemption 8655, they may not be simultaneously 

flight following more than five flights. 

-This condition will be added to the Flight Operations Manual (FOM) 

under the Exemption 8655B paragraph. 

Prepared by Flight Operations, 27 January 2010 12 
Pinnacle Airlines 

Exemption 8655B, Proposal 

OBJECTIVES 

At the end of this course the student will be 

fanniliar with the following areas of Exemption 

8655 in the Ops Specs: 

• What flights Exemption 8655 applies To 

• What Exemption 8655 allows 

• The requirements for utilizing Exemption 

8655 

• The documentation required when it is 

used 

Prepared by Flight Operations, 27 January 2010 14 
Pinnacle Airlines 

Exemption 8655B, Proposal 

General Overview 

Exemption 8655 relates to the way the need for an 

alternate is determined. The old 1 - 2 - 3 rule that all 

Dispatchers apply will still be in effect, however, on 

select flights we will be able to use this Exemption to 

lower this criteria. 

The purpose is, of course, to save fuel when the 

weather is good and there is little risk of diversions. It 

is tied to the primary objective of CAT II operations 

which provides a level of safety equivalent to CAT I 

precision Instrument approach operations even though 

the seeing-conditions are less than those encountered 

in CAT I operations. 

The decision making process starts in the planning 

phase and the decision to divert would ideally be 

made during the enroute phase of flight rather than 

waiting until a missed approach is made. 

That being said there are extensive requirements 

relating to the application of this exemption. 

Prepared by Flight Operations, 27 January 2010 15 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Application 

This Exemption applies to flights that would 

also be eligible for CAT II landing minimums 

during the planning process. Specifically the 

flights must: 

• Have a Flight Crew that is CAT II 

qualified 

• Have an aircraft that is currently CAT II 

qualified 

• The airport must be CAT II qualified 

Prepared by Flight Operations, 27 January 2010 16 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Application 

> FOM - Aircrew Qualifications 

- Captains are not authorized to conduct Category 

II operations until they have accumulated 100 hours 

PIC, in type, at Pinnacle 

- Additionally, First Officers must have 100 hours, 

in type, at Pinnacle, for Category II operations and 

this Exemption 

Prepared by Flight Operations, 27 January 2010 17 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Application 

This chart, which is found in the 

Reference Data section of the QRH or 

the CFM Chapter 3 Limitations, 

presents an easy reference to the 

equipment that must be operational for 

a flight to use Exemption 8655. 

Prepared by Flight Operations, 27 January 2010 18 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Application 

Of course, a generic MEL 34-00-10 will 

be the primary source for determining if 

the A/C is CAT II capable, and it may 

be applied even if no other MEL's exist 

Prepared by Flight Operations, 27 January 2010 19 
r 

Pinnacle Airlines 

Exemption 8655B, Proposal 

Application 

An MEL for specific systems will 

include a remark like this one 

FOM - Authorized Airports 

>For airports within the US and its territories, CAT 

II approaches are authorized if the approach plate is 

issued to the route manual. 

Required Approach Light Systems 

> ALSF 1 or 2 is required for CAT II operations 

> Or the Foreign Equivalents (HIALS) 

- Sequenced Flashing Lights (SF) - only required 

in the US 

Touchdown Zone Lights (TDZ) 

Runway Centerline Lights (CL) 

High Intensity Runway Lights (HIRL) 

Prepared by Flight Operations, 27 January 2010 20 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Destination alternate airports are selected and included on 

releases in accordance with the Company Operations 

Specifications and Federal Aviation Regulations In 

accordance with the 1-2-3 rule 

• Specifically, no alternate is required for Part 121 

Operations if the destination weather is forecast 1 

hour before to 1 hour after ETA to be at least 2000 

foot ceiling and 3 miles visibility 

So what does the 1-1-2 Exemption allow? 

• With the 1-1-2 Exemption, no alternate is required 

for Part 121 operations if the destination weather is 

forecast 1 hour before to 1 hour after ETA to be at 

least 1000 foot ceiling and 2 miles visibility 

• Again, extensive requirements will have to 

be met when applying this Exemption 

For that reason, the 1-1-2 Exemption will only 

be used at the direction of the Duty Manager, or 

other SOC Dispatch Managers 

Prepared by Flight Operations, 27 January 2010 21 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

There are 11 requirements that have to be met 

and we will cover each one in the following 

slides and how Pinnacle plans on meeting these 

requirements 

1) Each Pinnacle Dispatcher must have the 

ability to display the location of each flight 

within 3 minutes of real time. 

Flight Explorer provides the most accurate and 

reliable stream of air traffic data available in the 

industry. In fact, Flight Explorer Professional 

users receive individual aircraft updates every 

minute. The Flight Explorer client software that 

we run from our PCs receive updates from Flight 

Explorer's servers every 10 seconds. This 

means that you receive fresh air traffic data 

every 10 seconds. 

Prepared by Flight Operations, 27 January 2010 22 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

2) The Dispatcher has the capability to overlay 

weather returns with an update rate of at least 

once every 5 minutes. 

Pinnacle meets this requirement on the 

NWA part of our operation utilizing the 

NWA's version of flight explorer. 

• The base reflectivity radar in NWA's FE is 

from Unisys and updates every 5 

minutes. 

Additionally, the TP's are updated as needed or 

every 15 minutes. The echo tops product 

updates every 10 minutes. The single site radar 

update frequency is controlled by the National 

Weather Service and varies between 5 minutes 

and 12 minutes. 

Prepared by Flight Operations, 27 January 2010 23 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

3) The Dispatcher must have a system that 

provides a display of the specific aircraft routing 

as assigned by air traffic control (ATC) and 

actual filed flight plan routing 

The Flight Explorer Analyze Routes 

Opens the Route Analyzer tool showing 

the planned, previous, and current 

routes of a particular flight. 

Prepared by Flight Operations, 27 January 2010 24 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

4) The Dispatcher has a system which is able 

to display the locations of other airborne 

aircraft including aircraft of other operators. 

Flight Explorer provides the most accurate 

and reliable stream of air traffic data 

available in the industry. The data is based 

upon radar, satellite and other tracking 

information supplied by the FAA and other 

sources. Once Flight Explorer receives this 

data, it is processed and sent to the Flight 

Explorer client software via the Internet. 

Prepared by Flight Operations, 27 January 2010 25 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

5) The Dispatcher has a system that provides 

a display of planned and actual fuel at regular 

intervals along the route and the difference 

between planned and actual fuel. 

To meet this requirement we will require 

position reports from pilots at top of climb, 

and every thirty minutes thereafter. The 

pilots will be reminded of this requirement 

in the release remarks. "ALTERNATE 

WEATHER EXEMPTION 8655B APPLIED, 

POSITION REPORTS REQUIRED." 

Prepared by Flight Operations, 27 January 2010 26 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

6) The Dispatchers have alerts 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. 

The DUI currently provides weather alerts 

for new METAR's, Specials, TAF's, and TP's 

to all Dispatchers. The system then 

automatically forwards TP's to any aircraft 

affected by them. The Dispatcher will be 

required to forward the new METAR's and 

TAF's via ACARS. 

Prepared by Flight Operations, 27 January 2010 27 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

7) The Dispatcher must have the ability to 

access the services of a qualified meteorologist 

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. 

Our EWINS program provides the 

Dispatcher with access to the meteorology 

department. This EWINS program is on our 

Operations Specification AOIO and is 

detailed in the Pinnacle Airlines EWINS 

Manual. 

Prepared by Flight Operations, 27 January 2010 28 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

8) The 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. 

The DUI allows us to easily re-calculate a 

flight from any point on the flight plan or 

the aircraft's present position (lat/long 

from the last radar contact) to the 

destination, alternate, or a diversionary 

airport. This re-calculation may then be 

ACARS directly to the aircraft with any new 

routing, burns, times, ETA, etc... 

Prepared by Flight Operations, 27 January 2010 29 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

9) The Dispatch release will contain a 

statement for each flight Dispatched under this 

Exemption that states "ALTERNATE WEATHER 

EXEMPTION 8655B APPLIED." 

The DUI will have a predefined remark for 

this so that all Dispatchers will have one 

standardized remark. This pull down list of 

remarks allows the Dispatcher to simply 

click on the appropriate remark to be 

added to the release. 

Prepared by Flight Operations, 27 January 2010 30 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

10) Operations are not permitted under this 

Exemption at any airport with thunderstorms 

reported or forecast (main body, conditional 

statement, or remarks section) from 1 hour 

before through 1 hour after the estimated time 

of arrival. Furthermore, Pinnacle Airlines will 

not use Exemption 3585 in conjunction with 

any operation conducted under this Exemption. 

Operations under this Exemption will only 

be conducted by direction from an SOC 

Manager. Dispatchers must have all flights 

operated under this Exemption approved 

by the Duty Manager prior to release. The 

Duty Manager will review the details of all 

flights operated under this Exemption prior 

to approval. For flights where the risks as 

determined from a Risk Assessment Tool 

fall between 12 and 18, the Decision will be 

escalated up to the Director of Flight 

Operations for approval. 

Prepared by Flight Operations, 27 January 2010 31 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

11) Pinnacle Airlines will provide the 

administrator, by the 15^^ of each month, 

reports that include the information from the 

preceding calendar month, including: 

a. The total number of flights 

operated by Pinnacle Airlines under 

domestic rules to destinations within 

the 48 contiguous states and District 

of Columbia; 

This will be a simple report pulled out 

of Flight Trac. 

Prepared by Flight Operations, 27 January 2010 32 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

b. The total number of flights 

operated under this Exemption, 

Including those flights conducted under 

OpSpec A012. This report will include 

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. 

To comply with Pinnacle's policy to 

"Never Compromise Safety" we will 

track these requirements by requiring 

the Dispatcher to fill out a Risk 

Assessment Tool prior to approval by 

the Duty Manager. The Duty Manager 

will review the Risk Assessment Tool 

and the details of the flight prior to 

approving the use of Exemption 8655. 

For marginal cases, the Duty Manager 

will escalate the decision to the 

Director of Flight Operations for 

approval. The Duty Manager will then 

track this information on an Excel 

spreadsheet along with the results of 

the flight. 

Prepared by Flight Operations, 27 January 2010 33 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

c. Every diversion must be fully 

documented, and the total number of 

flights that divert to an alternate 

airport. 

d. As well as, the total number of 

flights that divert under this 

Exemption, the reason for each 

diversion, such as weather conditions, 

mechanical problem, fuel quantity, 

passenger problem, air traffic, 

Crewmember, or any other reason, 

must also be documented. 

These will require a simple report 

pulled up in world flight. 

Prepared by Flight Operations, 27 January 2010 34 
^ 

Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

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, is also required to be 

tracked. 

This will also be tracked by the Duty 

Manager on an Excel spreadsheet. 

Prepared by Flight Operations, 27 January 2010 35 
Pinnacle Airlines 

Exemption 8655B, Proposal 

The 1-1- 2 Exemption 

Requirements 

12) Dispatch will not apply Exemption 8655 

when any of the following conditions exist: 

a. During periods of uncovered Dispatch shifts 

(ie, due to sick calls etc.) 

b. When the Dispatcher is within six months 

of successfully completing their initial 

Competence Check. 

c. When doing so will cause the Dispatcher to 

follow more than two flights released under 

Exemption 8655. 

d. On a flight that has ACARS deferred. 

E If a dispatcher is using Exemption 8655, 

they may not be simultaneously flight following 

more than five flights. 

The Duty Manager and each individual 

Dispatcher will be responsible for adhering to 

these limitations. 

Prepared by Flight Operations, 27 January 2010 36 
Pinnacle Airlines 

Exemption 8655B, Proposal 

AD Exemption 8655 Test 

You are about to enter the test area of this 

presentation. You are only allowed two attempts to 

pass the test associated with this presentation. After 

which you will be locked out. 

• You must score a minimum of 80% to pass. 

• Once you start the test you will not be able to 

go back and review the material. 

• Attempting to do so will register a second 

attempt on the test. 

• If you would like to review the material before 

attempting the test you may do so now by 

clicking on the button labeled "Review". 

• Click "Next" to begin the test. 

Prepared by Flight Operations, 27 January 2010 37 
Pinnacle Airlines 

Exemption 8655B, Proposal 

SUMMARY 

If you failed your first test you 

may repeat the training now by 

clicking the Try Again button. 

Once you have reached the end of 

the presentation please click next 

and wait for the presentation to 

disappear. 

Please wait for 10 seconds after the 

presentation has disappeared to 

close the screen. This will ensure 

that the LMS system has had time 

to record the course and that you 

get proper credit. 

Thank you for your continued professionalism and 

as always, stay safe! 

Forward any suggestion or Questions to the Program 

Manager 

Thanks! 

Prepared by Flight Operations, 27 January 2010 38 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Reporting Procedure for Exception 8655B 

For reporting purposes, a spreadsheet will be maintained in the SOC folder on the 

Pinnacle Airlines server. If a flight has been approved to operate under Exemption 

8655B, the duty manager will fill in the following fields for that flight: 

- Flight Date 

Flight Number 

Origin 

Destination 

- Aircraft Make 

- Aircraft Model 

Aircraft Serial Number 

Plarmed Fuel 

Contingency Fuel 

Actual Arrival Fuel 

Diversion City (If Applicable) 

Reason for Diversion 

- Emergency Declared (YfN) 

- Reason for Emergency (If Applicable) 

No later than the lO' of the following month. Performance Engineering will send a report 

to the Duty Manager which includes (1) the total number of flights operated under 

domestic rules to destinations within the contiguous States and D.C., and (2) the total 

number of flights that diverted to an alternate airport. 

The Duty Manager will then input these totals in the aforementioned spreadsheet. The 

Duty Manager will also count (1) the total number of flights operated under exception 

8655B, including those conducted under OpSpec A012, (2) the total number of flights 

operated under exception 8655B that diverted, and (3) the total number of 8655B flights 

that declared an emergency. The Duty Manager will then input these counts into their 

respective places on the report spreadsheet. 

Once the spreadsheet is complete, the Duty Manager will send the spreadsheet to the 

Administrator, ensuring that it is done so BEFORE the 15"^ of the following month. 

Prepared by Flight Operations, 27 January 2010 39 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Spreadsheet for Tracking 8655 Statistics 

Monthly Exemption 8655B Report 

Total Number of Flights* 

Total Number of 86S5B Flights" 

Total Number of Diversions 

Total Number of 8$6SB Flight Diversions 

Total Number of 86S6B Flights Declaring an Emergency 

g655B Flight Detail"' 

Flight 

Date 

Flight 

Number 

Origin Destination 

Aircraft 

Make 

Aircraft 

Model 

Aircraft 

Serial 

Number 

Planned 

Fuel 

Contingency 

Fuel 

Actual 

Arrival 

Fuel 

Diversion 

City (If 

Applicable) 

Reason 

for 

Diversion 

Emergency 

Declared 

(YIN) 

Reason for 

Emergency 

'Operated under dofnestic rules to destinations within the contiguous States and D.C. 

"Includes flights conducted under OpSpec A012 

"•Must be chronological by fleet type 

Prepared by Flight Operations, 27 January 2010 40 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Flight Operations Manual Material 

The following material will be added to the Flight Operations Manual (FOM) in section 7 

after "Exemption 3585" when Pinnacle Airlines is approved for Exemption 8655B. 

Prepared by Flight Operations, 27 January 2010 41 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Exemption 8655B 

Exemption 8655 allows us to utilize lower weather requirements for alternate planning if multiple 

conditions are met. This Exemption will be used on a limited basis in an effort to reduce fuel usage while 

maintaining the highest standard of safety. Category II capability is required for the aircrew, airport and 

aircraft before this Exemption can be used. It is the ability to fly a Category II approach if necessary, along 

with the other stringent requirements of this Exemption, that allow the alternate weather requirements to be 

reduced while still maintaining safety. 

Exemption 8655B allows for a flight to be dispatched without an alternate as long as the following 

conditions are met: 

-The forecast for the period 1 hour before until 1 hour after anticipated arrival time at the 

destination must be equal to or better than, a ceiling of 1000 feet and a visibility of 2 nautical 

miles. 

-A risk assessment tool for each specific flight will be completed by Dispatch before utilizing this 

Exemption. 

- Operations are not permitted under this Exemption at any airport at which thunderstorms are 

reported or forecast from 1 hour before through 1 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, you may not use Exemption 3585 in conjunction with any 

operation conducted under this Exemption. 

-Operations under this Exemption will be limited to only those destination airports in the 48 

contiguous States and the District of Columbia. 

-Operations under this Exemption will be limited to only those airports at which an operable 

Category (CAT) II instrument landing system is available for use. 

-This Exemption will apply only to the CL-65-2B19 fleet. 

-Both cockpit Crewmembers must be fully trained and current in Category II approach operations 

-The aircraft must be fiilly capable of conducting Category II instrument approach procedures. 

-Captains with less than the requisite minimum hours specified in 14 CFR 121.652 may not 

operate under Exemption 8655B. 

-Pilots are required to make position reports upon reaching top of climb, and every 30 minutes 

thereafter, updating Dispatch with position and fuel information. 

-Exemption 8655B must be noted on the flight release in the following format: "ALTERNATE 

WEA THER EXEMPTION 8655B APPLIED, POSITION REPORTS REQUIRED." 

-Dispatch will not apply Exemption 8655 when any of the following conditions exist: 

a. During periods of uncovered Dispatch shifts (ie, due to sick calls etc.) 

b. When the Dispatcher is within six months of successfully completing their 

initial Competence Check. 

c. When doing so will cause the Dispatcher to follow more than two flights 

released under Exemption 8655. 

Prepared by Flight Operations, 27 January 2010 42 
Pinnacle Airlines 

Exemption 8655B, Proposal 

d. On a flight that has ACARS deferred. 

E If a dispatcher is using Exemption 8655, they may not be simultaneously flight 

following more than five flights. 

There are many tracking and reporting requirements for Dispatch when utilizing this Exemption. Thorough 

communication between Pilots and Dispatch is critical to the successful utilization of this Exemption. The 

position report requirement must be followed when using this Exemption. ACARS is the primary means by 

which to make these reports. In the event of ACARS failure, any other approved means of communicating 

with Dispatch is acceptable. 

Prepared by Flight Operations, 27 January 2010 43 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Risk Assessment Tool 

The risk assessment tool on the following page will be used by SOC to determine 

whether the use of Exemption 8655B is appropriate for each individual flight where it 

may be appropriate. 

Prepared by Flight Operations, 27 January 2010 44 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Date: Deoarture: 

Release/Trlp#: Destination: 

Risk 

Value 

Flight 

Value 

Corrected 

Value 

Pilot Qualifications and Experience 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

First Officer with less than 200 hours in type 

Captain with less than 300 hours in type 

Captain with less than 100 hours in last 90 days 

Duty day greater than 12 hours 

Flight time projected to exceed 8 hours in the duty day 

Pop up trip (Less than 4 hours crew notification) 

Crew Rest (Last rest pelod was Reduced Rest) 

Conducting New Hire OE 

Conducting Capt. OE 

More than 4 legs in duty period 

Totai Factor Score - Section 1 

4 

5 

3 

3 

4 

3 

4 

N/F 

N/F 

5 

Destination Weather Trend 

11 

12 

13 

14 

15 

16 

The forecast at the end of the period from 1 hour before ETA until 1 hour after 

ETA has a lower visibility and/or ceiling than at the beginning of the period. 

The forecast at the end of the period from 1 hour before ETA until 1 hour after 

ETA has the same visibility and/or ceiling as at the beginning of the period. 

The current surface observation at the destination has a lower ceiling and/or 

visibility than the next previous surface observation. ETE greater than 1 Hour 

The current surface observation at the destination has a lower ceiling and/or 

visibility than the next previous surface observation. ETE less than 1 Hour 

The current surface observation at the destination has the same ceiling and/or 

visibility as the next previous surface observation. 

Surface winds greater than 17 knots at destination 

Totai Factor Score - Section 2 

N/F 

5 

5 

N/F 

2 

N/F 

Equipment 

17 MEL7CDL (Items affecting CAT II operations) 

18 MEL/CDL (Non Cat II related Items affecting safety of flight) 

Total Factor Score - Section 3 

Totals 

N/F 

3 

00-12 Risk Acceptable 

12-18 Director of Operations Must Approve 

18+ Unacceptable Risk 

* If any Flight Value on this form is N/F, operations 

under Exemption 8655B are not allowed.* 

"Flight Value" is the value associated with any risk factor on the flight. "Corrected Value" is the 

value associated with any risk factor after changes have been made, or occur, which alter the 

initial "Flight Value." For example, if the "Flight Value" for line ten was initially five, but the crews 

schedule was changed to include only three legs in their duty period, the "Corrected Value" would 

now be zero. 

The header and items 11-18 of this form will be completed by the Dispatcher. Items 1-10 and 

totaling the values on the form will be completed by the SOC Duty Manager. 

Prepared by Flight Operations, 27 January 2010 45 
Pinnacle Airlines 

Exemption 8655B, Proposal 

Pilot Training Material: 

The following PowerPoint presentation will be administered to all pilots in initial and 

recurrent training. 

Prepared by Flight Operations, 27 January 2010 46 
Exemption 8655 

Exemption 8655 provides a new 

capability allowing us to deviate from 

the current 1-2-3 (1 hour before or 

after, 2000' ceiling, 3NM visibility) 

alternate rule in some very specific 

situations. 
DELTA 

Exemption 8655 

CONNECTIO N 

-The intent of Exemption 8655 is to allow 

us to save fuel by not requiring alternates 

in situations where we can operate with 

Category II approaches, In stable or 

improving weather conditions. 

-These savings can be accomplished 

while maintaining the same or higher level 

of safety than in normal situations. 
Exemption 8655 

Exemption 8655 allows us to operate 

with forecast weather at the 

destination as low as 1000' ceiling 

and 2 NM visibility for one hour before 

or after the estimated time of arrival 

l/K/7"/-/0(77 requiring an alternate. 

Exemption 8655 

In exchange for being able to lower 

the 1-2-3 rule to 1-1-2, there are 

numerous requirements that must be 

met. Most of these requirements are 

S.O.C. and dispatcher functions, but 

some are pilot requirements. 
Exemption 8655 

Exemption 8655 may be used only on 

flights meeting all the following 

requirements: 

-CRJ-200 aircraft which is Category II capable 

-Category II capable Aircrew 

-Destination airport has at least one operable 

Category II approach 

Exemption 8655 

-Pilot's operating under exemption 8655 

are required to provide a position report at 

top of climb and every thirty minutes 

thereafter. These position reports must 

include current fuel status. 

-These reports provide dispatch with some of 

the information they require to closely 

monitor the flights progress. 
Exemption 8655 

-This enhanced monitoring from dispatch 

is intended to allow for early decisions to 

deviate, in case the weather or airport 

status at the destination deteriorates. 

- Remember, you will be operating without 

an alternate when dispatched under 8655, 

so an early decision to deviate if 

necessary is critical. 

Exemption 8655 

Flights operating under Exemption 8655 

will have the following statement as a 

remark on the flight release: 

"ALTERNATE WEATHER 

EXEMPTION 8655B APPLIED." 
Exemption 8655 

As part of the flight planning process, 

Dispatcher's are required to complete 

a separate Risk Assessment for each 

flight operated under Exemption 

8655. 

Exemption 8655 

-The risk assessment provides a tool for gauging 

the risks associated with utilizing reduced 

alternate requirements. 

-Some of the factors included in the assessment 

include: pilot expehence, current weather, 

weather trend, duty times, training in progress, 

aircraft capability, approach suitability and 

availability, etc. 
DELTA 

Exemption 8655 

-When operating under Exemption 8655, Pilot's 

must remain extra vigilant for changes in the 

weather or airport status at the destination. 

-If the destination is trending downward, an early 

decision to divert to a closer airport is a good 

choice. 

CONNECTIO N 

DELT A 

Exemption 8655 

-Because you will be operating without an 

alternate, proceeding to another airport after 

reaching the terminal area will obviously create 

a potentially serious fuel situation. 

-These situations should be avoided by carefully 

monitoring the weather and making proactive 

and early decisions to divert. 
DELTA 

Exemption 8655 

CONNECTIO N 

-Data and experience shows that proceeding to 

a diversion or alternate airport from cruise flight 

is much safer than proceeding to an alternate 

after executing a missed approach in a busy 

terminal environment. 

-By making the decision to deviate earlier, 

operations under this exemption may actually be 

safer than normal operations in many cases. 

Exemption 8655 

-Everyone must remember that under no 

circumstance is the utilization of Exemption 8655 

required. 

-The Pilots, Dispatcher and SOC Duty Manager 

must all agree on the use of Exemption 8655. 

-If you have any concerns or questions please 

contact your dispatcher and discuss the most 

appropriate, and safest course of action.