7 January 2014 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor Room W12-140 

1200 New Jersey Avenue 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 Operations 
Forward 

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-227 AC/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 of Title 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 of one hour before to one hour after the estimated time of arrival. 

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 takeoff a 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 consumption 
Discussion 

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 of this 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 of their 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 at the 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 under 
Domestic 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 of arrival 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 at the 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 of flight 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.