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 anFAA 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. 44 th Street

Phoenix, AZ 85008