02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 02 

,:-pARTMENTOF 

:;ANSPORWION 

V'XET OPERATIONS 

Reference: public docket No. FAA-2010-1269 

2uil FEB tU A q:0 3 

§ 11.81 What Information must i include in my petition for an exemption? 

You must include the following information in your petition for an exemption and submit 

it to FAA as soon as you know you need an exemption. 

(a) Your name and mailing address and, if you wish, other contact information such as a 

fax number, telephone number, or e-mail address; 

Davonaii-, Inc. Dolphin Atlantic, Inc. 

9725 NW 52""^ Street, Suite 503 702 SW 34* Street 

Doral, FL 33178 Ft Lauderdale, FL 33315 

cgwalston(2),hotmail .com Igoldberg@goIdaviation.cQm 

Tel: (786)546-0849 Tel: (954)359-9919 

Skyknight Air Services, Inc. Watermakers Air, Inc. 

5115 NW 17* Terrace, 39B 2545 NW 55* Court, Hanger 26 

Ft Laudeixlale, FL 33309 Ft Lauderdale, FL 33309 

SkvK.TMghtAiT@,vahoo.coin bfli cliarlie@. vahoo. com 

Tel: (954)257-7564 Tel: (904)233-7340 

(b) The specific section or sections of 14 CFRfrom which you seek an exemption; 

Relief from 14 CFR 135.183 

(c) The extent of relief you seek, and the reason you seek the relief: 

The extent of relief songjni is 41 nautical miles (15 niinutes at cruise for the Cessna 

C-208B w/ Cargo-pod) beyond power-off gliding distance from land. 

The reason we seek relief is in order to delineate compliance with 135.183 where Air 

Traffic Control (ATC) in high-density environments places aircraft at fixes and altitudes 

from which sin^e engine aircraft cannot reach land in the event of engine failure. The 

Miami ARTCC/TRACON Letter of Agreement (LOA) Dated December 10,2009 

attached (See A-1) makes clear the need for such relief 

(d) The reasons why granting your request would be in the public interest; that is, how it 

would benefit the public as a whole; 

By complying with the LOA listed above, the general flying public will be better served 

in safety by having all aircraft, including single engine air-carriers, operate under positive 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 03 

radar control inhiglily congested environments, such as the Miami/Fort Lauderdale 

airspace. 

Also, the Cessna Grand Caravan is the most feasible and economical aircraft in cuirent 

production in the United States today that meets the requirements of '9 or less' 

passenger/cargo air-carrier operations. Given the extensive shorelines, peninsulas and 

islands served, outlying remote communities in need of General Aviation support would 

greatly benefit by the broader use of such aircraft as the Cessna Caravan. Not to mention, 

the Cessna Caravan can carry more passengers/cargo per operating dollar than any other 

production aircraft; providing a profit for the operator where otherwise one mi^t not 

exist. The ancillary benefits of which would translate into more economical service to 

the public, as well more business and jobs. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek the exemption; 

135.183 was written primarily with piston-powered aircraft in mind. Although all singleengine aircraft share the same power dynamic, the turbine engine was still in its infancy 

stage at that time. Today with over 18 million fli^t hours logged on the Pratt & Whitney 

powered (PT6A-114A) Cessna Caravan, the standard of single-engine aircraft safety, at 

least where turbine-powered aircraft are concerned, has undoubtedly been raised beyond 

that envisioned upon this regulations implement. 

Furthermore, there exists no production aircraft today that matches the passenger/cargo 

carrying abilities of the Cessna Caravan. This leaves many Part 135 air-carriers operating 

discontinued line of aircraft that range from 30 to 70 years old. And even though many 

of these out-of-production aircraft are multi-engine, in most cases the asymmetricalthrust dynamic has led to a dismal safety record far outweighing the benefit of tlie second 

engine. This fact is supported by indvistry and insurance findings. 

Secondly, the language of part (b) makes clear that the regulation allows for singleengine aircraft to operate beyond power-off gliding distance to land (necessary for takeoff 

and landing). But the ambiguous wording of part (b) leaves in question to what extent; 

or more pointedly here, to what distance. At present an operator may in good-faith 

believe that they are in compliance when complying with ATC descent directives (i.e. 

Miami LOA) for approach and landing, but at the same time the Administrator can 

arbitrarily take the counter position that there exists some as yet unwritten limit (distance) 

for which the air-carrier has exceeded. Without some uniform defined limit, such as this 

Exemption request, the un-quantified language of part (b) essentially creates an 

interpretational nightmare that brings the use of the safer turbine-powered Cessna 

Caravan into question; leaving many air-carriers to operate antiquated difficult to 

maintain aircraft. 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 04 

In short, the granting of this Exemption will not only not adversely affect safety, but by 

permitting the petitioners to operate fliodem turbine-powered aircraft, such as the Cessna 

Caravan with its exemplary safety record, tfie level of safety will most certainly be 

significantly raised. 

0 A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

14 CFR 135.183 

(2) A brief description of the nature of the exemption you seek; 

15 minutes at cruise power setting (41 n.m. for the Cessna 208B with Cargo Pod) beyond 

the power-off gliding distance to land. 

(g) Any additional information, views or arguments available to support your request; 

and 

ICAO has already certified the Pratt «& Whitney Canada powered PT6-114A engine in the 

Cessna Caravan for such over-water operations. (See Attachment A-2) 

(h) If you want to exercise the privileges of your exemption outside the United States, the 

reason why you need to do so. 

The arrival profiles contained in the Miami ARTCC/TRACON LOA (A-1) are both over 

water and outside U. S. airspace. In addition to these arrivals, this problem frequently 

arises when single engine aircraft operate in coastal, peninsular and island areas with 

highly congested controlled environments; in this instance, in and around the Islands of 

the Caribbean (i.e. Nassau, Bahamas) where a large percentage of our operations are 

conducted. 

End 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 05 

ATTACHMENTS: 

A-1 

(Insert Miami ARTC and Miami TRACON Letter of Agreement Dated Dec. 10, 2009) 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 06 

Federaf Aviation 

Administration 

Memorandum 

Date; 

To: 

From: 

Subject: 

December 10,2009 

Air TraflTc Manager. MIA-1 

•^ 

I ^enncth £. Thomas 

"-^Air Traffic Manager, ZMA-I 

Revision U\ of ihe Miami ARTC Center and Miami TRACON Letter of 

Agraement, SUBJECT: Approach Control Service, Dated February 15. 2007 

By mutual agreement the Miami ARTC Center and Miami TRACON Letter of Agreement 

(LOA) has been revised. Revision 1 will be effective December 31, 2009, PJcase replace the 

appropriate pages on the effective date. An explanation of changes is listed below. 

Explanation of Changes 

Re-worded paragraph to include Letter of Procedure wording 

New paragraph to include Letter of Procedure wording 

Rc-worded paragraph and added climbing to 12,000 ft. 

Added climbing to 1,2,000 ft. 

Page 

3 

4 

5 

5 

Attachment 

Paragraph 

4.2.2.2 

4.2.2.9 

4.2.4.5 

4.2.4.6 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 07 

Federal Aviation 

Administration 

Memorandum 

Date. = ^ J/1N19 2007 

To: Air Traffic Manager, MIA-1 

From: 

Subject: 

Air Traffic Manager, ZMA-1 

New Miami ARTC Center and Miami Tower Letter of Agreement, 

i.UBJECT: Approach Control Service. Dated February 15, 2007 

AnnriTl r""" ""Z '^'^" ' ^^'^^ ^^''' " °"^ Miami To^ver Utter of Agn^ement Subiecf 

Explanation of Clianges 

Page 

5 

6 

Paragraph 

4.2,4. J 

4.3.1 

Changed PREDA TRANS to PREDA SID/TRANS 

Overflights not restricted to Fort Myers Temiinal Airport 

departures only. All overflights will be routed south of the 

WEVER ATA and north of point "0 " (ANNEX 2), assigned 

heading 110 at 5,000(1., routed out EEONS DTA except IrafHc 

landing Biniini when MIA is east will be routed direct Bimini. 

Attachment 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 08 

MIAMI ARTC CENTER AND MIAMI ATC TOWER 

. LETTER OF AGREEMENT 

SUBJECT: APPROACH CONTROL SERVICE 

1 PURPOSE: This Afireemeiu covers approach control service for airports 

vvjthin airspace delegated to Miami ATC Tower as depicted in the 

Annexes and is supplemental^ to llie Air Traffic Handbook. 

2 EFFECTIVE DATE: February 15,2007 

3 RESPONSIBILITIES: Miami Center (ARTCC) delegates to Miami 

Tower (ATCT) authority and responsibility for control of jurcrafl within 

the Terminal Area described in the Annexes. 

4 PROCEDURES: 

4-1 ARRIVALS: 

4.1.1 Between the hours of 0900 and 2200 local, ARTCC shall issue a speed 

restriction for ail arrivals as indicated below unless otherwise coordinated: 

East operation: ANNEY/MILSVaUNUR/FUPR 280 knots or less. 

West operation: ANNEY/MILSY/JUNUR/FLIPR 250 knots or less. 

East opcratioo: WORPP/SSCOT/WEVER/CURSO 250 knots or less. 

West operation; WORPP/SSCOT/WEVER/CURSO 280 knots or less. 

(DEKAL - 250 knots at all times.) 

4.1.2 Transfer of Control is defined as control for turns and descent within the 

confines of tiie Amval Transition Area (ATA) airspace defined in Annex 1. 

4.1.3 The ARTCC shall clear arrivals to the destination airport, M'M appropriate 

ATAs, to cross Transition Fixes as follows: 

4.1.4 MIA (and airports south) 

4,1.4.1 EAST OPERATION 

ATA 

TRANSITION FIX 

ATWEY 

MILSY 

FLIPR/JUNUR 

SSCOT/WORPP 

CURSO/WEVER 

ALTITUDE 1 

JETS 

130 

160 

120 

100 

FILED 210+ 

110 

N/A 

90 

«0 

-210 kts I 

N/A 

N/A 

80 

. 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 09 

4.L4.2 WEST OPERATION 

ATA 

TRANSITION FIX 

ANNEY 

MILSY 

FLTPR/JUNUR 

CURSO/WEVER 

SSCOT/WORPP 

KUBK 

ALTITUDE II 

JETS 

no 

130 

100 

140 

160 

N/A 

FILED 210+ 

no 

N/A 

80 

90 

90 

N/A 

-210 kts 

N/A 

N/A 

<50 

80 

N/A 

50 

4.1.4.3 

4.1.4.4 

4.T.4.5 

4.1.5 

4.1.5.1 

4.1.5.2 

Non tuitiojct aircraft departing the Keys, destination MIA may be cleared 

direct DHP/VK2 at 5,000 ft. 

TMB turbojet arri-vals over CURSO/WEVER shall be at 6,000 ft. TMB 

turbojet anrivals over SSCOT/WORPP shall be at 10,000 ft. Traffic filed 

less than 210 kts, arriving airport.? south of Miami may be cleared via 

VEGIE direct QEEZY direct destination at 4,000 fi^. 

When Homestead OCA is closed, HST tactical aircraft shall be routed via 

the HST 233*'R to cross CAJUN at 7,000 ft. 

FLL (and airports north of MI A) 

ATA 

TRANSITION FIX 

GISSII/BALEW 

CURSO/WEVER 

(Miami East) 

CURSO/^'EVER 

(Miann West) 

DEKAL (Miami East) 

DEKAL (Miami West) 

JINGL/KUBIC 

GlLBl 

'• 

JETS 

80 

no 

no 

60 

50 

80 

N/A 

ALTITUDE 

FILED 210+ 

N/A 

90 

90 

30/40-OPF/HWO 

40 AllOtliers 

30/40 - OPF/HWO 

40 All Others 

60 

40 

-210 kts 

N/A 

50 

40 

30/40-OPPAWO 

40 All Others 

30/40-OPF/HWO 

40 All OtlTcrs 

SO 

40 

OPF turbojet anivals over SSCOT/WORPP or CURSO/WEVER shall be 

at 10,000 ft. 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 18 

4.1.5.5 Only aircraft departing APF/MKY filed less than 210 kts shall be routed 

over KUBIC at 5,000 ft. 

4.1.5.4 ZMA shall assign FLL Turbojet Arrivals over CURSO/WEVER heading 

OlSatMNNDY/FAMIN. 

4.1.5.5 When holding is required; the holding pattern airspace area at all ATA 

fixes shall revert to ARTCC control. 

4.2 DEPARTURES: 

4.2.1 ATCT shall transition dcpartm^s via appropriate Departure Transition 

Areas (DTAs) and will climb aircraft to 16,000 feet or filed altitvide, 

whichever is lower, unless otherwi.'je specified. 

4.2.1.1 During "Heavy" departure times, the following proccduiiJ, may be 

implemented through TMU for turboprop departures usin? the HEDLY, 

ARKES, WINCO, THNDR, VALLY, SKIPS. PADUS^ PREDA, and 

ZAPPA DTAS. This procedure is to be implemented for each DTA 

separately and dynamically. 

ALTITUDE AIRCRAFT TVPE/AIRSPEED 

Jets 

Props - 210 kts or greater 

Props - Less than 210 kts 

4.2.2 DTA airspace is depicted in Annex 2 and departures are released for 

control to the ARTCC as follows: 

4.2.2.1 THNDR/ARKES/WINCO/HEDLY departures are released for turns, 

speed adjustments, and climb to filed altitude witliin the confines of the 

DTA, 20 NM nortli of DHP. 

4.2.2.2 ZAPPA/PREDA/BAHMAl departures are released, within tlie confines of 

the DTA, for turns, speed adjustments, end climb to filed altitude east of a 

line depicted on the RADAR mapping, beginning at 251730/0794936 and 

ending at 260415/0795000. 

4.2.2.3 EONNS departtires are released for turns, speed adjustments, and climb to 

filed allilude within tlie confines of the DTA south of HST. 

4.2.2.4 MNATE departures are released for turns and speed adjusmients south of 

HST. 

4.2 2.5 DORM departures arc released for turns within the confines of the DTA. 

Revision # I Eff. 12/31/09 
02/14/2011 08:49 2022G75075 OFFICE OF RULEMAKING PAGE 11 

4.2.2.6 

4,2.2.7 

4.2.2.8 

4.2.2.9 

4.2..^ 

4.2.3.1 

4.2.3.2 

4.2.3,3 

4.2.3,4 

SKIPS departures arc released for turns, speed adjustments, and cHmb to 

filed altitude within the confines of die DTA, 10 NM east of VKZ. 

BEECH departures are released for turns within the confines of the DTA. 

25 NM southeast of FLL. 

ATCT shall climb HST Fighier/Taclical departures to FL230 or lower 

requested altilude after ARTCC has accepted tlie handoff. 

VALLY/PADUS departures are released for turns, speed adjustments, aivd 

climb IQ filed altitude within the confines of tlie DTA. 

MIA (and airports south) 

ROUTE 

DTA 

VALLY 

PADUS 

BEECH 

SKIPS 

EONNS 

MNATE 

WINCO 

HEDLY 

DORM 

FIRST 

PREFERENCE 

RNAVSID's/TRANS 

VALLY SID/TRANS 

PADUS SlDmiANS 

BEECH SID/TRANS 

SKIPS SID/TRANS 

EONNS SlDffRANS 

MNATE SID/TRANS 

WINCO SID/IRANS 

HEDLY SID/TRANS 

N/A 

SECOND 

PREFERENCE 

AIRWAY 

ARll 

BR66V 

FLL098R 

BR53V 

A509 

HEADINd 170-210 

V97,V521, 

J43,.T73,J616 

V267. V437 

J53..r81 

DIRECT 

APF/MKY 

THIRD 

PREFERENCE 

HEADING 

HEADING 060 

HEADING 060 

HEADING 100 

I-JEADING 090-120 

HEADING 120-150 

HEADING 170-210 

HEADING 320-330 

HEADING 330-350 

HEADING 270-290 

Frefisrence number three shall be utilized only during a NAVAID outage. 

Aircraft filed below 10,000 ft out the SKIPS DTA shall be rerouted by 

ARTCC when ATCT is on a west operation. Traffic filed at or below 

5,000 ft or filed north of Nassau shall be routed via the BEECH DTA, 

Traffic filed landing Nassau, or south of Nassau, shall be routed via the 

EONNS DTA. 

During a Tamiami ARSR-4 Radar (QMA) Outage, SKIPS departures shall 

not be rerouted via EONNS DTA. 

4,2.5.5 No route preference is required for MNATE depnrturcs. 

Revision*?! Efll2/3I/0S> 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 12 

4.2.3.G 

4.2.3.7 

4.2.3.8 

4.2.3.9 

4.2.4 

4.2.4.1 

DORM Eyhall be used only for departures destined APF/N^KY at 4,000 ft. 

ARTCC shall miile OPF/HWO departures via ihe BEECH/VALLY/ 

HEDLY/WINCO/PADUS and MNATE DTASARTCC shall ensure HST departures thai file the TOAD SID, on 

Nortlibound transitions, cross 6 NM south of the R26/R47 boundary at or 

above 17,000 ft. 

Aircraft at 6,000 feet, filed 210 knots or less, and landing within the Key 

West Terminal Airspace may be cleared direct destination. 

FLL (and airports north of MIA) 

ROUTE 

DTA 

THNDR 

ARKES 

ZAPPA 

PREDA 

BEECH 

MNATE 

FIRST PREFERENCE 

RNAV SID'.s/TRANS 

THNDR SID/TRANS 

ARKES SID/TRANS 

ZAPPA SID/TRANS 

PREDA SID/TRANS 

BEECH SID/TRANS 

MNATE SID/TRANS 

SECOND 

PREFERENCE 

AIRWAY 

V157V599 

V5n J5S.rS5 

VI59 

J20JII3 

ARIO 

ARIO 

FLL098°R 

HEADING 170-

2T0 

THIRD 

PREFERENCE 

HEADING 

HEADING 320 - 340 

HEADING 330 - 350 

HEADING 060 

HEADING 060 

HEADING 100 

HEADING 170-210 

4,2.42 Preference number three shall be utilized only during a NAVAID outage. 

4.2.4.3 No route preference is required for MNATE dcpartunss, 

4.2.4.4 ZBV dcparltires shall be routed via Uie BEECH DTA, 

4.2.4.5 WlKn FLL is on a west operation; FLL BEECH DTA jet departures shall 

be routed as follows: Advanced navigation aircraft via the BAHMA SID, 

non-Advanced aircraft out tlie FLL PREDA DTA heading 090. and 

climbing to a maximum of 12,000 ft. 

4.2.4.6 ZBV cleparturcs proposed off FXE/PMP shall be routed, out the FLL 

PREDA DTA heading 090, and climbing to a maximum of 12,000 ft. 

4.2.4.7 THNDR DTA departures shall enter ARTCC airspace at or above 6,000 ft. 

Aircraft filed below 6,000 ft. shall be routed via the WINCO DTA by the 

ARTCC. 

Revision fll KIT, 12/31/09 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 13 

4.2.4.8 ARKES departures will be on a heading, within the confines of the DTA, 

•to intercept the ARKES SID/transition at or prior to the ARKES 

intersectioii, 

4.2.4.9 Aircraft at 6,000 feet, filed 210 knots or less, and landing within the Key 

West Terminal Airspace may be cleared direct destination. 

4.3 OVERFLIGHTS: 

4.3.1 ARTCC shall not route over flights through Miami Approach Control 

Airspace between the hours of 0700 and 2300 local with the exception of 

aircraft transitioning to or from points south of Grand Bahama Island, 

using the following routings: 

EasTboundr All inbound south of the WEVER ATA and north of 

point "O'XANNEX 2), assigned heading 110 at 5.000' routed out EEONS 

DTA, except when MlA is east^ traffic landing Bimini will be touted 

direct. 

Westbound; via the DEKAL ATA and out the WE<1C0 DTA at 4,000 fl. 

Westbound: via the JUNUR ATA and out the WINCO DTA at 12,000 ft 

CLEARANCE DELIVERY: 

ATCT shall issue departure clearances: 

"AS FILED" when a DTA identifier appears on the proposal strip and no 

pluses appear in tlve route of flight. 

Via "AS FILED" if an aircraft files the TOAD SID. 

Via amended routes displayed on the proposal sto'p beginning witli ilie 

first plus in the route of flight and ending with tlie second plus in the route 

of flight, 

4.4,3.1 When an PR strip is required to display the second plus in tine route of 

flight, the amended route shall continue from the last element on tlie 

proposal strip to the next plus on die FR strip. 

4.4.4 Via full route clearance when FRC appears on an FDIO strip. 

4.4.5 ARTCC shall issue, via interphone to the appropriate FDIO equipped 

facility, all FRCs, route amendments and altitude changes jnade by 

ARTCC Icxss tlian thirty (30) minutes prior lo proposed dcpartiu-e time. 

4.4 

4.4.1 

4.4.2 

4.4.2.1 

4.4.3 

4.4.6 ATCT may make FDIO amendments anytime prior to departure. 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 14 

4.4.7 ATCT shall ensure the amended altitude is issued when FRA (Full Route 

Altilude) appears in the remarks section. 

4.4.8 ATCT shall coordinate with ARTCC for clearance on all flights, which do 

not have a DTA identifier, or if no strip has bcc; R^ev. l. Effective 9/28/06 

5 SEPARATION: 

5.1 Radar separation shall not be less than five (5) nautical miles at the time of 

transfer of control. ARTCC shall ensure this separation is maintained or 

increasing on all arrival aircraft. ATCT shall ensure this separation is 

maintained or increflsing on all departure aircraft. 

5.1.1 When transitioning from terminal to en route control, three (3) miles 

increasing to five (5) miles or gitater may be used in accordance with 

FAA Order 7110.65. 

6 COMPUTER INTERFACE OLTf AGES; 

6.1 CENTRAL COMPUTER COMPLEX (ARTCC): 

6.1.1 ATCT shall stop deporturcs until coordination is effected with ARTCC. 

6.1.2 ARTCC shall issue departure clearances and forward inbound and over 

flight data via interphone. 

(J. 1,3 ARTCC shall assign arrivals the beacon code specified by ATCT. 

6.2 STARS (ATCT): 

6.2.1 ATCT shall a.ssign the beacon code from the FDIO strip prior to handoff. 

6.2.2 ARTCC .shall assign the non-discrete code as specified in 6.3.3 bsiow. 

6J2.3 A combined failure of FDIO and STARS interface will be treated as an 

ARTCC computer failure. 

6.3 STARS/CENTRAL COMPUTER COMPLEX: 

6.3.1 ATCT shall stop departures until coordination is effected with ARTCC. 

6.3.2 ATCT shall assign code 0300 to departures. 

7 FDIO n>ITERFACE: 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 15 

7,1 

7.2 

8 

All FDIO equipped Towers shall call ARTCC for departure clearance. 

ARTCC shall specify the beacon code on all arrivals and the destination 

airport, if other than Miami, 

MISCELLANEOUS: Deviations from procedures established in this 

Agreement shall be elTccted only aficr prior coordination is accomplished 

which completely defuies responsibility in each case, 

Kenneth E. Thomas 

Air Traffic Manager 

Miami ARTC Center 

Willidm W. Kribble 

Air Tj/aflic Manager 

Miai/i/ATC Tower 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE IB 

ANNEX I 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 17 

ANNEX 1 

ARRIVAL TRANSITION AREA DESCRIPTIONS 

GILBI 26»1S'30'780*44'5G" 

26°23'O0"/80*40'l9'" 

26*23'O0780»39'30" 

26«27'29780°42'07" 

26*23 •04"/80«47^50" 

Hfi.EY 26<'23^00"/80"'04'58" 

26'23'O0"/79*4r4r' 

26"26'00"/79M2-2r26"28'03779"43'5r' 

26''27'56"/80*02'5r 

26''27'30'V80*'05Mr" 

26°23'00"/80"04'58" 

FISEL 26''23'00"/79'55'00" 

26'»23'00779<'43-40" 

26»27'54779»46'34" 

26*27'54779°52^4TDEKAL 25»53'22"/79*36"35" 

25'52'25779''34'29" 

25"'47'5r'/79''3r01" 

25M8'48779°39'23-' 

JUNUR 25»27'30"/79°42'30" 

25^'20779^50n5" 

25M9*06779»46'12" 

25°24-16-779'"38"-37" 

WEVER 25*44'30780"'54'10" 

25''38"15780''52'30" 

25°32'50^VS0'49~15" 

25»29-13780''52*18" 

25'30'53780'^59^56" 

KUBIC 26^03'] 5780*57'30^' 

26'08'10"/80*56M5-' 

26°ir02781*00'47-' 

26°05'4378]'02'16" 

WORPP 25°49^00'/80'54"30" 

2S»56*00"/80''55'50" 

25'57'4378ror26" 

25°5r2l78r00'06'' 

10 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 18 

ANNEX 2 

I I 
02/14/2011 08:49 2022575075 OFFICE OF RULEMAKING PAGE 19 

ANNEX2 

DEPARTURE TRANSITION AREA DESCRIPTIONS 

WINCO 26' ] 2*30780*51' 15" 

25*'57M8780<'34'00" 

25*57*48780°27'38" 

26''1«'30'780''44'50 

THNDR 26'18'30780»44'50" 

25'S7'48780''27.'38" 

26°23'00780''39'30'' 

26*'23'00780«'40'19" 

HEDLY 26'23'00780*34'15" 

26°03'00780*22'10" 

26'03"00780'*16'45'' 

26'='23'00"/80*26'00" 

SKIPS 25*44'07779''42'00'" 

25''4SM2"/80°09"27" 

25'33^30779^42'00" 

ARKES 

ZAPPA/PREDA 

VALLY/PADUS 

26'23'00"/80*26^00" 

26*03^00780* 16'45" 

26*03''00"/80'='13'55" 

26*23'00780"11'50^' 

26*21'] 5779*42'00" 

26*2n5779''46'30'' 

26*10'15779*57^ 15" 

25*05'00"/79°58'45-' 

26*12'00779*36'00" 

26*12'00"/79''36'00"' 

26*05'00779*58'45''' 

25^58'00780''00'30'' 

25'^58'OO779*47'00'' 

26*06'15779*33'45" 

EONNS 25'='2ri5779"52-I9" 

25*29 "01780*0 r 30^' 

25*29^01780*12^30" 

25*17M0780*06'00" 

MNATE 25*15'15780*1 n5'~ 

25*29 "40780*22'SO" 

25°1$'45780^37'30" 

25*10'00780*28'00"* 

BEECH 26*04-15779*37' 15" 

25*59'5r'/79*32^26'' 

25*56'02779*34'5r' 

25*59'00779*45'30" 

DORM 25''49'00780*54-30'' 

26*00'45"/S0*57M5"' 

26*00^45'780*49'26" 

25''49'00'780''49'26"^ 

12 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 20 

A-2 

ICAO International Standards and Recommended Practiees 

Operation of Aircraft 

Annex 6 to the convention on International Civil Aviation 

Part 1 International Commercial Air Transport - Aero planes 

Ninth Edition July 2010 

Attachment H-3 

6. Route limitations over water 

6.1 Operators of single-engine turbine-powered aero planes carrying out operations at night and/or 

in IMC should make an assessment of route limitations over water. The distance that the aero 

plane may be operated fi-om a land mass suitable for a safe forced landing .should be determined. 

This equates to the glide distance from the cniise altitude to the safe forced landing are 

following engine failure, assuming still air conditions. States may add to this and additional 

distances taking into account the likely prevailing conditions and type of operations. This 

should take into account the likely sea conditions, the survival equipment carried, the achieved 

engine reliability and the search and rescue services available. 

6.2 Any additional distance allowed beyond the glide distance should not exceed a distance 

equivalent to 15 minutes at the aero plane's normal cruise speed. 
02/14/2011 08:49 2022675075 OFFICE OF RULEMAKING PAGE 21 

We the Petitioners do hereby respectfully request exemption from section 135.183 of Part 14 of 

the Code of Federal Regulations to the limits delineated. 

Respectfiilly, 

7^r4/J {/'tLO</CAJ^ /-.?A// 

Name and Date 

Dolphin Atlantic, Inc. 

Signature 

Name and Date / 

Water 

r.fM/UA^ Yf^a.K' Asy-zy 

Name and Da«: 

Davonair, Inc. 

signature 

Name and Date 

.»4'-^v '^JIADANAPOU 

MYCWWlSSION»tlOS3D4Si 

_ _ _ EXPIRES; OctPbM to, 2013 

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