AFS-11-211-E 

April 12, 2011 

 Exemption No. 7504E 

 Regulatory Docket No. FAA-2002-13930 

Captain Walt Trevathan 

Interim Manager, Flight Standards 

Pinnacle Airlines, Inc. 

1689 Nonconnah Blvd., Suite 118 

Memphis, TN 38132 

Dear Captain Trevathan: 

This letter is to inform you that we have granted your petition to extend Exemption 

No. 7504, as amended. It explains the basis for our decision and describes its effect. 

The Basis for Our Decision 

By letter dated March 7, 2011, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Pinnacle Airlines, Inc. (Pinnacle), for an extension of Exemption No. 7504, as 

amended. That exemption from § 121.434(c)(1)(ii) of Title 14, Code of Federal Regulations 

allows Pinnacle to substitute a qualified and authorized check airman or aircrew program 

designee for an FAA inspector to observe a qualifying pilot in command (PIC) who is 

completing initial or upgrade training specified in § 121.424 during at least one flight leg that 

includes a takeoff and a landing. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to Pinnacle. 
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Our Decision 

The FAA has determined that the justification for the issuance of Exemption No. 7504, as 

amended, remains valid with respect to this exemption and is in the public interest. 

Therefore, under the authority provided by 49 U.S.C. 40113 and 44701, which the FAA 

Administrator has delegated to me, I grant your petition, subject to the conditions and 

limitations listed below. 

Conditions and Limitations 

1. A Pinnacle check airman or aircrew program designee may conduct a PIC observation 

in place of an FAA inspector when— 

a. The Administrator preapproves that substitution for each observation of a 

qualifying PIC candidate, thus reserving first right of refusal to the FAA in 

each case. Pinnacle, therefore, must contact an appropriate FAA office, in 

each instance, before substituting that check airman or aircrew program 

designee; 

b. The qualifying PIC candidate has completed no less than 10 hours of 

supervised operating experience (OE) and accomplished no fewer than two 

takeoffs and landings; and 

c. The qualifying PIC candidate is performing PIC duties during a complete 

flight leg, including flight deck preparation, before starting engines checklist, 

taxi, takeoff, all other flight phases, landing, taxi, and securing checklist. 

2. Each Pinnacle check airman or aircrew program designee conducting a PIC 

observation in place of an FAA inspector must— 

a. Be approved by the Administrator to conduct the observation; 

b. Have served as a check airman or aircrew program designee for Pinnacle for 

no less than 6 months; and 

c. Not supervise the OE or conduct the initial line check for the qualifying PIC 

candidate being observed. 

3. Pinnacle must maintain student, check airman, and aircrew program designee records 

that demonstrate compliance with the conditions and limitations of this exemption. 
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The Effect of Our Decision 

Our decision extends the termination date of Exemption No. 7504, as amended, to 

April 30, 2013, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

Raymond Towles 

Acting Director, Flight Standards 

 Service