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
October22, 2015 Via Email U.S. Department ofTransportation 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, SouthwestAirlines 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) ofTitle 14, Code of Federal Regulations and allows SouthwestAirlines (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 hourafterthe estimated time ofarrival atthe destination airport the appropriate weather reports orforecasts, 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 ofthis exemption, SouthwestAirlines (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 neverapproved for use and was never implemented. Currently, SWA has developed the systems to address all ofthe requirements ofthis 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 underthis exemption, Southwest must obtain an updated operations specification A005 (Exemptions and Deviations) that providesfor operations underthis exemption. 2. Operations underthis exemption are limited to onlythose destination airports in the contiguous United States. 3. Operations conducted underthis exemption must use a current and qualified aircraft dispatcher. 4. Operations underthis exemption are limited to onlythose 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 2

Operable ILS Ceiling Required Visibility Required

Category I 1,000feet above ground level 3 statute miles (AGL) Category II 1,000feet AGL 2 statute miles Category Ill 1.000feet AGL 2 statute miles

5. Before conducting operations underthis exemption, Southwest must demonstrateto the satisfaction of the FAA principal operations inspector (POl) assigned to the SouthwestAirlines Certificate Management Office that:
a. Each Southwest dispatcher has a system available to displaythe location ofeach flight within 3 minutes of real time; b. Each Southwest dispatch facility has a system that provides its dispatcherswith 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 ofthe specific aircraft routing as assigned by airtraffic control (ATC) and actual filed flight plan routing; d. Each Southwest dispatcher must havethe capability to expeditiously recompute projected arrival fuel from a "point aloft" tothe intended destination in the event conditions, including those required to be reported in Condition No. 8, occurthat negatively impactthe flight;
e. Each Southwest dispatcher must have data availablethatwill showaircraft status, including the aircraft capability to conduct CAT I, CAT II orCAT Ill operations as applicableto the exemption being used; f. Each Southwest dispatcher has a system availableto display locations ofother airborne aircraft including aircraft ofother operators; g. Each Southwest dispatch facility has a system available that provides its dispatcherswith a display ofplanned 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 thatthese can be relayed to flightcrews in an expeditious manner; i. Each Southwest dispatcher is provided the capability to accessthe services ofa qualified meteorologist approved by the POl wheneverthe dispatcher believes that consultation is necessary to ensure safety ofoperations underthis exemption. The presence ofan approved Enhanced Weather Information System program satisfies this requirement; and j. Each dispatch release issued in accordancewith this exemption will contain a statement such as "ALTERNATE WEATHER EXEMPTION APPLIED. SWAwill reference the appropriate manual.Re: Exemption No. 8654, FAA Docket No. FAA-2005-22457 October 22, 2015 3

6. The reporting requirements ofthe 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 determinethe feasibility ofdispatching the flight underthis exemption and/or continuing the flight afterdispatch. 7. Approved Procedures. Ifthe use ofthese systems, reports orthe occurrence ofotherfactors indicate that the conditions underwhich the flight was originally dispatched have changed and may negatively impact the flight, the dispatcher and flightcrew must re-evaluate the continued operation ofthe flight using approved procedures, and if necessary, agree on an alternate plan as soon as possible afterthe occurrence ofanyofthe following:
a. En route holding ordelaying vectors, airspeed changes, altitude changes, or re-routings; b. Unplanned or sustained use ofdeicing and anti-icing systems or otherfactors directly relating to fuel consumption that may have a negative effect on trip fuel requirements; c. The deterioration ofdestination weather below a 1,000-foot ceiling and 2-mile visibility ifusing an exemption that requires at least 3 statute miles visibility as listed in Table 1; and d. The deterioration ofdestination weather below a 1,000-foot ceiling and 1-mile visibility ifusing 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 ofany ofthe following:

a. Lateral deviation from the planned route by greaterthan 100 NM; b. Vertical deviation from the planned altitude by greaterthan 4000 feet; c. ETAwill exceed P.lanned by greaterthan 15 minutes; d. Fuel consumption in excess of planned that may have a negative effect on trip fuel e. Requirements; f. Fuel system componentfailure orapparent malfunction that may have a negative effect on trip fuel requirements; g. The flight encounters weather significantly differentthan forecast, to include turbulence; h. The flight is assigned en route or arrival holding; and 

### i. Unplanned orsustained use ofdeicing oranti-icing systems. 9. Southwest must maintain CAT I (operations specification C074)/CAT II/CAT Ill (operations specification C059) ILS approach authorization (as applicable) forthose aircraftto which this exemption would apply, and each aircraft must have fully operating equipment needed forthe appropriate CAT 1/CAT II/CAT Ill ILS approach forthat aircraft to operate underthis exemption. 10. At the time ofdispatch, 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 underthis exemption, unless the operator alsoRe: Exemption No. 8654, FAA Docket No. FAA-2005-22457 October22, 2015 4

holds Exemption No. 5549, the PIC has been trained in accordance with the requirements ofthat exemption, and all ofthe conditions specified by Exemption No. 5549 are met. 11. Operations are not permitted underthis exemption at any airport at which thunderstorms are reported or forecast from 1 hour before through 1 hour afterthe estimated arrival time ifsuch reports orforecasts are in either or both the main bodyorthe remarks section oftheweather report orthe weatherforecast. Furthermore, Southwest cannot use Exemption No. 3585 (as amended) issued to AirTransport Association ofAmerica, Inc., members (including Southwest) or any subsequent exemption granting similar relief regarding any kind offorecast ofthunderstorms at the destination airport in conjunction with any operation conducted underthis exemption. 12. Each certificated Southwest dispatcherand PIC, who conducts operations underthis exemption, must be provided with a copy of pertinent parts ofthis exemption. Operations underthis exemption are permitted by Southwest dispatchers and PICs but are not required. 13. Use ofthis exemption in operations to destinations outsidethe contiguous United States is prohibited. Southwest is authorized to use this exemption in operations to airports within the 48 contiguous States and the District ofColumbia from airports outside those boundaries provided Southwest also holds operations specification A012 (Part 121 Domestic Operationsto Certain Airports Outsidethe 48 Contiguous States and Alaska) and operations are conducted in accordance with the appropriate provisions ofthat operations specification as they pertain to operationsfrom Alaska and/orthe airports listed in Table 1thereof. 14. Southwest must provide the Administrator, by the 15'h day ofeach 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 underthis exemption satisfactorilyfor at least 24 continuous calendar months and sufficient data tothoroughly evaluate operational performance have been obtained. Reports must contain the following information:

a. The total number offlights operated by Southwest underdomestic rules to destinationswithin the 48 contiguous States and the District ofColumbia; b. The total number offlights operated underthis exemption, including those flights conducted under the appropriate provisions and limitations ofoperations specification A012. For each flight operated, the dates; airport pairs; flight numbers; aircraft make, model, and serial number; trended or graphical summary offlight planned fuel vs. actual arrival fuel; and contingencyfuel must be listed. Report format shall be in chronological order by fleet type;
c. The total numberofflights that divertto an alternate airport; d. The total number offlights that divertto an alternate airportthat are separated underthis exemption, and the reason for each diversion, such asweather conditions, mechanical problem, fuel quantity, passenger problem, air traffic, crewmember, or any other reason. Southwest mustfully document each diversion; and
e. The total numberofSouthwest flights, operated underthis exemption, that declare an emergency and the reason for such declaration, orduring which flight a lowfuel state occurs that results in actions being taken by ATC and/ordispatch to provide priority handling, even ifno emergency is declare.Re: Exemption No. 8654, FAA Docket No. FAA-2005-22457 October 22, 2015 5

The conditions and circumstances, in regard to public interest and equivalent levels ofsafety, which warranted the original grant ofexemption, continue to exist. The renewal ofthis exemption is not a controversial issue. Forthis reason, and the reasons stated above, SouthwestAirlines requests that a finding ofgood cause be made for waiving publication in the FederalRegister(14 CFR §11.87). Granting the requested reliefwill 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, DirectorAirOperationsAssurance Tim Leonard, Director Flight Operations Compliance and Operations Jim Stieve, Senior Manager Regulatory Programs 

### & Compliance Barry Brown, Associate General Counsel- Operations and Environment