April 29, 2011 

Ms. Tyneka Thomas 

Office of Rulemaking - Airman and Airspace Rules Division 

Orville Wright Bldg. (FOB10A) 

FAA National Headquarters 

800 Independence Ave., SW 

Washington, DC 20591 

Exemption 7495 D

Dear Ms. Thomas, 

This correspondence serves as an official petition of renewal to the administrator for exemption 

or partial exemption from FAR 121.434 (c) (1) (ii) of Title 14, Code of Federal Regulations to the 

extent necessary to permit Mesa Airlines Inc. to substitute a qualified and authorized check 

airman in place of an FAA inspector to observe a qualifying pilot in command (PIC) while that 

PIC is performing prescribed duties during at least one flight leg that includes a takeoff and a 

landing when completing initial or upgrade training as specified in FAR 121.434. 

The original intent of FAR 121.434 (c) (1) (ii), issued in early 1970, was to validate the training a 

pilot received in a visual simulator. Since the rule was adopted, the airline industry has had 30 

years of experience with advanced simulation. Mesa Airlines notes that at Safety Summit I, 

sponsored by the Department of Transportation and the FAA, one of the recommendations was 

to allow a qualified company check airman to provide the FAA observation when an FAA 

inspector is not available. This would allow the FAA to target its personnel on those areas 

deserving higher priority and attention, thus, provide a more cost effective use of an inspector's 

time. The FAA has the authority to, and routinely does, observe any pilot at any time. These 

routine observations are on a schedule that allows flexibility without the burden of having to 

observe a particular pilot on specific flights necessitated by the airline's training and service 

schedule. This greater flexibility of FAA Inspectors and better use of its inspection force by 

focusing on higher priority safety functions. 

The company would gain the use of a qualified pilot immediately after completing operating 

experience (OE), significantly increasing the use of qualified pilots and improving its ability to 

provide on-time dependable air service to the public. The exemption would prevent the 

unnecessary cost of wages and lost productivity for those qualified pilots waiting for the FAA 

observation. Mesa Airlines currently operates 66 Regional Jets and 6 Turbo-Propeller aircraft 

with possible future expansion being considered. 

The granting of the proposed exemption would have no adverse effect on 

safety for the following reasons: 

1. The authorized check airman would be highly trained in the particular 

type of aircraft and approved by the FAA, whereas in some cases 

currently, the inspector performing the observation may not be qualified 

in the aircraft being flown. 

2. The check airman would be used to fulfill the requirements of 

FAR121.434(c) (1) (ii) only when an FAA inspector is not available. 
3. The FAA has the authority to observe any pilot at any time during line 

operations. 

Mesa Airlines proposes that the requested exemption be subject to the 

following conditions and limitations, if granted: 

1. Each check airman performing the duties otherwise appropriate to an 

FAA inspector, under this exemption, musta. Be an employee of Mesa; 

b. Be qualified and current in the duties of the PIC in the aircraft being 

operated; 

c. Be approved by our FAA principal operations inspector (POI); and 

d. Have been employed by Mesa as a check airman for a minimum of 6 

months. 

. 

2. Mesa must submit and have approved by its POI the name of each 

check airman to be used under this exemption before that check 

airman performs duties under the exemption. 

3. Before each observation conducted under this exemption, Mesa must 

contact its POI or the POI's designated representative. No observation 

may be conducted under this exemption unless the FAA determines 

there is not an FAA inspector available to observe the affected 

operation and so informs Mesa. 

4. The check airman observing the qualifying pilot must be other than the 

check airman conducting the operating experience flight. 

5. The check airman observing the qualifying pilot may not have 

previously conducted any operating experience flight during the 

current training of the qualifying PIC. 

6. Each operation conducted under this exemption must be recorded in 

Mesa's approved training records. 

7. Mesa must submit a schedule to its POI that includes the date(s) of 

each proposed observation to be conducted under 121.434. 

8. Mesa must maintain the records necessary to demonstrate 

compliance with the conditions and limitations of this exemption. 

Please do not hesitate to contact this office with any questions in support of 

this request. 

Sincerely, 

Capt. Alvin L. Isaacs 

Certificate Chief Pilot 

410 N. 44th Street 

Phoenix, AZ 85008