7 January 2014 U

.S

. Department ofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 New JerseyAvenue SE Washington, DC 20590 Dear Sir: In accordance with the provisions of Title 14 Code of Federal Regulations, Section 11, Key Lime Air Corporation, holder of air carrier certificate KY7A882H , hereby petitions for an exemption from 14 CFR 121.623(a) and (d); and 121

.643. The summary and petition are attached

.
Respectfully,

David Carrizo Director of Flight OperationsForward Key Lime Air is a certified air carrier operating under Title 14 CFR Parts 121 and 135 to conduct domestic, supplemental and on-demand flight operations

. Key Lime Air conducts all domestic and supplemental flight operations using certificated aircraft dispatchers and a Systems Operations Center (SOC)

. Key Lime Air is a privately held corporation currently operating a fleet of two Fairchild Metro 23s (SA227-DC) in domestic and supplemental operations

. Key Lime Air also has eighteen Metros (SA-227AC/BC and SA226) , three Dornier D0328-300s, one Embraer EMB120, two Cessna 404s,a Lear 24, and eight Piper Navajo Chieftains (PA31-350) engaged in on-demand operations in The United States (48 states and District of Columbia), Alaska, Canada, Mexico, Central America, South America, and the Caribbean

. Pursuant to the provision of Title 14 CFR section 11 , Key Lime Air hereby requests an immediate exemption from the following sections ofTitle 14 CFR Part 121 : 121.623(a) and (d) ; and 121

.643; The requested exemption would permit the Key Lime Air to conduct its supplemental operations within the 48 contiguous United States and the District of Columbia using the flight regulations for alternate airport (121

.619) and fuel reserve requirements (121

.639) that are applicable to domestic operations rather than supplemental requirements cited above. Specifically, Key Lime Air would be permitted to conduct operations without listing an alternate airport when the weather reports, forecasts, or any combination thereof, indicate that the ceiling will be at least 2,000 feet above the airport elevation and the visibility will be at least three (3) miles for a period ofone hour before to one hour afterthe estimated time ofarrival. FARs Affected 121.623(a) provides, in pertinent part, that each person releasing an aircraft for operation under IFR shall list at least one alternate airport for each destination airport in the flight reiease

. 121

.623(d) provides, in pertinent part, that no person may release a flight unless he lists each alternate airport in the flight release

. 121.643 provides, in pertinent part,that no person may release for flight or takeoffa nonturbine or turbo-propeller powered airplane unless, considering the wind and other weather conditions expected , it has enough fuel1

. To fly to and land at the airport to which it is released ; 2

. Thereafter, to fly to and land at the most distant alternate airport specified in the flight release; and 3

. Thereafter,to fly for 45 minutes at normal cruising fuel consumptionDiscussion Key Lime Air believes that granting this exemption affords an equivalent or greater level of safety to that provided for in the FAR sections 121.623(a) and (d); and 121

.643

. Key Lime Air offers in support ofthis Petition for Exemption and stated in applicable part: Key Lime Air utilizes trained and certificated dispatchers and advanced flight following equipment in the Systems Operations Center

. Key Lime Air's flight following system is enhanced by the computers and weather systems it uses. In addition , Key Lime Air utilizes backup communications procedures should the primary in-flight communications process fail. The Key Lime Air SOC can coordinate in-flight communication between the crew and dispatch, maintenance control , scheduling , and administration. The dispatch work stations are designed to provide a high level of flight safety. The Key Lime Air flight planning system allows dispatchers to generate computer flight plans accurately illustrating route and fuel requirements. This flight planning process provides a high level of accuracy in fuel burn calculations

. Key Lime Air has a very low dispatcher to flight ratio. This enhances safety by allowing the dispatchers to focus all oftheir time and resources on fewer flights

. Technical Data Key Lime Air is currently authorized to conduct Domestic operations within the 48 contiguous United States in compliance with the flight release and fuel reserve rules for Domestic operations

. Key Lime Air is also authorized to conduct Supplemental operations in all of the 48 contiguous United States and the District of Columbia, Alaska, Central America, Mexico, South America, Canada (excluding Canadian MNPS airspace) , and the Caribbean Sea (including the island/nations, but excluding the Havana FIR) in compliance with flight release and fuel reserve rules for Supplemental operations. This includes the requirement that the company list at least one alternate airport for each destination airport in the flight release

. 121.643 states that no supplemental operator may release for flight of takeoff an airplane unless, considering the wind and other weather conditions expected , it has enough fuel1

. To fly to and land atthe airport to which it is release: 2. Thereafter, to fly to and land at the most distant alternate airport specified in the flight release; and 3

. Thereafter, to fly for 45 minutes at normal cruising fuel consumption

. The rules cited that are applicable to Supplemental operations differ in certain key respects to similar dispatching requirements for operations conducted under Domestic operations authority. Specifically, 121

.619 does not require an air carrier conducting operations underDomestic operating authority to list an alternate airport for a destination airport when the appropriate weather reports,forecasts, or any combination thereof, indicate: 1. The ceiling will be at least 2,000 feet about the airport elevation; and 2

. Visibility will be at least 3 miles for at least 1 hour before and 1 hour after the estimated time ofarrival at the destination airport. In addition, 121.639 requires that an air carrier conducting operations under Domestic operating authority has enough fuel1. To fly to the airport to which it is dispatched; 2. Thereafter, to fly to and land atthe most distant alternate airport (where required) for the airport to which dispatched; and 3

. Thereafter, to fly for 45 minutes at normal cruising fuel consumption. Public Benefits The existing requirements for supplemental operators require that an alternate airport be designated for each flight, regardless of the forecast and existing weather conditions

. When the weather conditions are at least 2,000 foot ceiling and 3 miles visibility, this results in a larger than necessary fuel load for a supplemental operation. These larger than necessary fuel loads equate to money lost by Key Lime Air due to carrying the extra weight and by limiting the available payload

. Futiher, burning fuel to carry fuel needlessly contributes to the depletion of vital natural resources. In addition to the fuel conservation, the reduced fuel burn substantially reduces in direct proportion the amount of pollutant gases emitted into the troposphere, and the amount of carbon dioxide and water vapor emitted into the atmosphere, thereby reducing the impact on global warming as well. The increased fuel load requirement may also necessitate an otherwise unnecessary stop enroute for fuel, as the flight may not be capable of operating the route with the increased fuel reserve and increased fuel consumption. Enroute stops negatively affect the fuel required to reach the final destination

. An enroute stop increase the exposure to unnecessary delay and inconvenience while adding unwanted congestion to the already overcrowded air traffic system
. Enroute stops unnecessarily expose the traveling public to the more dangerous takeoff, landing, and taxiing phases offlight which is not in the public interest. Enroute stops also have an adverse effect on crewmember flight and duty time limitations and subsequent schedules. The result is that more of the public is adversely affected by a single event.Safety Impact An equivalent level of safety is provided by granting this petition and providing an alternative means of regulatory compliance

. Given the current operational practices and capability of Key Lime Air, substitution of the requirements of 121

.619 and 121

.639 as they pertain to domestic operation for the current supplemental rules would maintain the same level of safety as required for an air carrier exercising its authority under 119

.21 (a)(1)

. Request for Waiver Key Lime Air hereby requests waiver for publication of the petition in the Federal Register

. Precedent already exists for waiver from publication

. Similar requests have been granted to other Part 121 operators, three of those being Omni Air International, Champion Air and Airborne Express.