Southwest Airlines Co. 

Alan Kasher 

Managing Director /Director of Operations 

Regulatory Programs & Compliance 

2702 Love Field Dr./TOP-1 DO 

P.O. Box 36611 

Dallas, Texas 75235 

(469) 603-0948 

October 22, 2015 

Via Email 

U.S. Department of Transportation 

Docket Management System 

400 7th Street, S.W., Plaza 401 

Washington, DC 20591-0001 

Re: Exemption No. 8654, FAA Docket No. FAA-2005-22457 

Ladies/Gentlemen: 

Southwest". 

In accordance with the Code of Federal Regulations, 14 CFR § 11.25, Southwest Airlines petitions to 

reinstate Exemption No. 8654 (FAA Docket No. FAA- 2005-22457). This exemption expired January 31, 

2010. 

Exemption No. 8654 granted relief from§ 121.619(a)(1) and (2) of Title 14, Code of Federal Regulations 

and allows Southwest Airlines (Southwest) its certificated dispatchers, and its pilots in command (PIC) to 

dispatch flights to domestic airports at which for at least 1 hour before and 1 hour after the estimated time 

of arrival at the destination airport the appropriate weather reports or forecasts, or any combination of 

them, indicate the ceiling may be reduced from at least 2,000 feet to 1,000 feet above the airport elevation 

and visibility may be reduced from at least 3 statute miles to 2 statute miles. 

During the duration of this exemption, Southwest Airlines (SWA) was unable to meet the required 

conditions and limitations out lined in this exemption. Specifically, SWA was unable to develop a 

technology system to display planned and actual fuel at regular intervals therefore this exemption was 

never approved for use and was never implemented. 

Currently, SWA has developed the systems to address all of the requirements of this exemption and 

requests for its reinstatement based on the conditions and limitations as outlined below. Similar 

exemptions are Exemptions 8653G and 10000C. 

Conditions and Limitations 

1. Before conducting operations under this exemption, Southwest must obtain an updated operations 

specification A005 (Exemptions and Deviations) that provides for operations under this exemption. 

2. Operations under this exemption are limited to only those destination airports in the contiguous 

United States. 

3. Operations conducted under this exemption must use a current and qualified aircraft dispatcher. 

4. Operations under this exemption are limited to only those airports at which an operable instrument 

landing system (ILS) procedure is published. Alternate minimums are predicated on the following 

table: 

Table 1 -Alternate Minimums (Ceiling and Visibility Required} 
Re: Exemption No. 8654, FAA Docket No. FAA-2005-22457 

October 22, 2015 

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Operable ILS Ceiling Required Visibility Required 

Category I 1,000 feet above ground level 3 statute miles 

(AGL) 

Category II 1,000 feet AGL 2 statute miles 

Category Ill 1.000 feet AGL 2 statute miles 

5. Before conducting operations under this exemption, Southwest must demonstrate to the satisfaction of 

the FAA principal operations inspector (POl) assigned to the Southwest Airlines Certificate 

Management Office that: 

a. Each Southwest dispatcher has a system available to display the location of each flight within 3 

minutes of real time; 

b. Each Southwest dispatch facility has a system that provides its dispatchers with overlays of 

weather returns updated at least once every 5 minutes; 

c. Each Southwest dispatch facility 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 Southwest dispatcher must have the capability to expeditiously recompute projected arrival 

fuel from a "point aloft" to the intended destination in the event conditions, including those required 

to be reported in Condition No. 8, occur that negatively impact the flight; 

e. Each Southwest dispatcher must have data available that will show aircraft status, including the 

aircraft capability to conduct CAT I, CAT II or CAT Ill operations as applicable to the exemption 

being used; 

f. Each Southwest dispatcher has a system available to display locations of other airborne aircraft 

including aircraft of other operators; 

g. Each Southwest dispatch facility has a system available 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; 

h. Each Southwest dispatch facility has a system available that automatically alerts its dispatchers to 

special weather updates, changes in weather reports, forecasts and/or other significant weatherrelated reports, and ensures that these can be relayed to flightcrews in an expeditious manner; 

i. Each Southwest dispatcher is provided the capability to access the services of a qualified 

meteorologist approved by the POl 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 program satisfies this requirement; and 

j. Each dispatch release issued in accordance with this exemption will contain a statement such as 

"ALTERNATE WEATHER EXEMPTION APPLIED. SWA will reference the appropriate manual. 
Re: Exemption No. 8654, FAA Docket No. FAA-2005-22457 

October 22, 2015 

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6. The reporting requirements of the flightcrews listed in Condition No. 8, Mandatory Pilot Reports, and the 

required dispatch flight planning and tracking systems in Condition No. 5 must be used to determine the 

feasibility of dispatching the flight under this exemption and/or continuing the flight after dispatch. 

7. Approved Procedures. If the use of these systems, reports or the occurrence of other factors indicate 

that the conditions under which the flight was originally dispatched have changed and may negatively 

impact the flight, the dispatcher and flightcrew must re-evaluate the continued operation of the flight 

using approved procedures, and if necessary, agree on an alternate plan as soon as possible after the 

occurrence of any of the following: 

a. En route holding or delaying vectors, airspeed changes, altitude changes, or re-routings; 

b. Unplanned or sustained use of deicing and anti-icing systems or other factors directly relating to fuel 

consumption that may have a negative effect on trip fuel requirements; 

c. The deterioration of destination weather below a 1 ,000-foot ceiling and 2-mile visibility if using an 

exemption that requires at least 3 statute miles visibility as listed in Table 1; and 

d. The deterioration of destination weather below a 1 ,000-foot ceiling and 1-mile visibility if using an 

exemption that requires for at least 2 statute miles visibility as listed in Table 1. 

8. Mandatory Pilot Reports. Pilots will notify Dispatch as soon as possible in the event of any of the 

following: 

a. Lateral deviation from the planned route by greater than 100 NM; 

b. Vertical deviation from the planned altitude by greater than 4000 feet; 

c. ETA will exceed P.lanned by greater than 15 minutes; 

d. Fuel consumption in excess of planned that may have a negative effect on trip fuel 

e. Requirements; 

f. Fuel system component failure or apparent malfunction that may have a negative effect on trip fuel 

requirements; 

g. The flight encounters weather significantly different than forecast, to include turbulence; 

h. The flight is assigned en route or arrival holding; and 

i. Unplanned or sustained use of deicing or anti-icing systems. 

9. Southwest must maintain CAT I (operations specification C074)/CAT II/CAT Ill (operations specification 

C059) ILS approach authorization (as applicable) for those aircraft to which this exemption would apply, 

and each aircraft must have fully operating equipment needed for the appropriate CAT 1/CAT II/CAT Ill 

ILS approach for that aircraft to operate under this exemption. 

10. At the time of dispatch, the flight crew must be qualified to conduct a CAT 1/CAT II/ CAT IIIILS 

approach to published minimums (as applicable). PIGs with less than the requisite minimum hours 

specified in § 121.652 cannot be used in operations under this exemption, unless the operator also 
Re: Exemption No. 8654, FAA Docket No. FAA-2005-22457 

October 22, 2015 

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holds Exemption No. 5549, the PIC has been trained in accordance with the requirements of that 

exemption, and all of the conditions specified by Exemption No. 5549 are met. 

11. 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 arrival time if such reports or forecasts 

are in either or both the main body or the remarks section of the weather report or the weather forecast. 

Furthermore, Southwest cannot use Exemption No. 3585 (as amended) issued to Air Transport 

Association of America, Inc., members (including Southwest) 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. 

12. Each certificated Southwest dispatcher and PIC, who conducts operations under this exemption, must 

be provided with a copy of pertinent parts of this exemption. Operations under this exemption are 

permitted by Southwest dispatchers and PICs but are not required. 

13. Use of this exemption in operations to destinations outside the contiguous United States is prohibited. 

Southwest is authorized to use this exemption in operations to airports within the 48 contiguous States 

and the District of Columbia from airports outside those boundaries provided Southwest also holds 

operations specification A012 (Part 121 Domestic Operations to Certain Airports Outside the 48 

Contiguous States and Alaska) and operations are conducted in accordance with the appropriate 

provisions of that operations specification as they pertain to operations from Alaska and/or the airports 

listed in Table 1 thereof. 

14. Southwest must provide the Administrator, by the 15'h day of each month, reports that include the 

information listed below, during the preceding calendar month. The POl is authorized to delete this 

reporting requirement once Southwest has conducted operations under this exemption satisfactorily for 

at least 24 continuous calendar months and sufficient data to thoroughly evaluate operational 

performance have been obtained. Reports must contain the following information: 

a. The total number of flights operated by Southwest under domestic rules to destinations within the 48 

contiguous States and the District of Columbia; 

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

the appropriate provisions and limitations of operations specification A012. For each flight operated, 

the dates; airport pairs; flight numbers; aircraft make, model, and serial number; trended or 

graphical summary of flight planned fuel vs. actual arrival fuel; and contingency fuel must be listed. 

Report format shall 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 separated under this exemption, 

and the reason for each diversion, such as weather conditions, mechanical problem, fuel quantity, 

passenger problem, air traffic, crewmember, or any other reason. Southwest must fully document 

each diversion; and 

e. The total number of Southwest 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 

declare. 
Re: Exemption No. 8654, FAA Docket No. FAA-2005-22457 

October 22, 2015 

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The conditions and circumstances, in regard to public interest and equivalent levels of safety, which 

warranted the original grant of exemption, continue to exist. The renewal of this exemption is not a 

controversial issue. For this reason, and the reasons stated above, Southwest Airlines requests that a 

finding of good cause be made for waiving publication in the Federal Register(14 CFR §11.87). Granting 

the requested relief will set no precedents. 

AK/js 

cc: Greg Wells, Senior Vice President Operational Performance 

Matt Hafner, Vice President Network Operations Control 

Craig Drew, Vice President Flight Operations 

Scott Halfmann, Vice President Safety & Security 

Jeff Hamlett, Director Air Operations Assurance 

Tim Leonard, Director Flight Operations Compliance and Operations 

Jim Stieve, Senior Manager Regulatory Programs & Compliance 

Barry Brown, Associate General Counsel- Operations and Environment