# KEYAIR

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__; U.S. Department of Transportation Docket Operations, M-30 West Building ground floor Room W12-140 Washington, DC 205590

To whom it may concern, Key Air, LLC would like to officially request to extend exemption number 10311, regulatory docket no. FAA-2011-0337. The Key Air, LLC exemption is set to expire on July 31, 2015. Please note the attached petition.

Chris Hand Director of Operations Key Air, LLC 203-575-4428

KEY AIR LLC 3 Juliano Drive, Suite 2.01, Oxfurrl, CT 06478 203.264.0605 tel 203.264.02.18 faxPetition of: Key Air, LLC Regulatory Docket 

### No.

for anexemption from Article 135225 (l)(l)oftheFederal Aviation Regulations. PETITION FOR EXEMPTION In accordance with the provisions ofFAR 11.25, Key Air, LLC (Key Air) hereby petitions the Administrator for an exemption from Article 135.225 (f) (1) ofthe Federal Aviation Regulations to operate aircraft on an .IFR takeoffat military or foreign airports with visibility reported at less than 1mile. Article ofthe FAR affected: Article 135.225 (f) (I)provides, inpertinent part, Each pilot making an IFR takeoff or approach and landing at a military or foreign airport shall comply with the applicable instrument approach procedures and weather minimums prescribed by the authority havingjurisdiction over that airport. In addition, no pilot may, at that airport- (1) Take offunder .IFR when the visibility is less than 1 mile: Exemption request: KeyAirproposes to conduct I FRtake offs at military and foreif,'11 airports when visibility is less than I mile. Key Air is authorized to use lower than standard takeoff minima at U.S. Civil Airports inaccordance withthe limitations and provisions of Operations Specificationparagraph C079. Further, this proposal requests identical privileges at military and foreif,'11 airports asthose described 

### intheprovisions ofourcurrent Operations SpecificationparagraphC079. KeyAirwill complywiththe applicable instrument approachprocedures andweatherminimums prescribed by the authority havingjurisdiction over foreign and militmy airports. This petition applies to all aircraft Key Air has listed on the certificate's D085 Aircraft listing Operational Specification.

KeyAir, LLC'sPetition forExemption Page lof3In support ofthis proposal, Key Air respectfully submits the following comments: I. Key Air's principal base of operations is located at 3 Juliano Drive, Suite 201, Oxford, CT 06478. Key Airholds Air Carrier Operating CertificateNumber KKYA467B issued on December 4, 1989 and re-issued on April 13, 2007 and conducts air taxi and on demand charteroperations underFAR 135. 2. The demands ofthe charter (air taxi) service operated by Key Air include operations at military airports as well as at airpmis inforeign countries. 3. All Key Air crewmembers are trained and evaluated in FAA -approved Level C and D simulators underanFAA-approved 14CFRPart 135trainingprogram. TheLowerthan Standard TakeoffMinimums (500ft.) training event is included in alllnitial, Upgrade and Recurrent Curriculum Segments. The simulator training and evaluation is done using low visibility conditions appropriate to the minimums authorized in the Ops Specs C079. Key Airtraining meets all the regulatoryrequirements and follows the applicable 8900.J guidanceforbothFARpart 121 and 135trainingprograms. 4. Key Air is currently authorized to conduct takeoffs at U.S. Civil Airports in weather below Category I takeoff minimums for 14 CFR 13 5 aircraft operations through Operations Specification C079 Paragraph (t)(3) down to 500ft. Runway Visual Range. Therefore, the FAA has already recognized that Key Air can safely and effectively conduct said operations. 5. Since December 4, 1989, Key Air has successfully proven that it is capable of safely conducting low visibility takeoff operations. Prior to the April 25, 2008 revision to Operations Specification paragraph C079, Key Air was authorized to conduct, and did conduct, reduced visibilitytake offoperations under FAR 135 at military airports as well as at airports in foreign countries. In over 21 years ofexperience in the management of reduced visibility take offoperations under FAR 135, Key Air has never experienced a perfonnanceorsafetyissue. 6. Key Air has instituted an effective Safety Management System used to identify and mitigate any and all risk in potentially unsafe operational conditions. Said Safety Management System has been officially recognized by the following industry and governmental sources: 1) AirCharter SafetyFoundation (ACSF) ;and 2) IS-BAO. 7. Key Air believes that this exemption would permit us to respond to a growing demand for chartered airtransportation at military and foreign airports and would permit Key Air aircraft to be available to the general public which would not otherwise be available. To not allow Key Air to conduct takeoff operations in reduced visibility conditions at Military and Foreignairports would imposeanunreasonable burdento general public. If KeyAir, LLC'sPetitionforExemption Page2of3granted, this exemptionwould beinthepublic interest while still maintainingthe highest level ofsafety. Good cause fonvaiving publication and 120-day filing requirements exists because: Key Airrespectfully requests a waiver of the 120-day filing requirements and the publishing ofa summary ofthe Petition in the Federal Register. The delay in the granting ofthis exemption request will result in additional delay for relief that has already been granted to Part 119 certificateholders operating underPart 121 (byrule) andPart 135 (by exemption). Accordingly, there is good cause to dispense with these notice-and-comment requirements. Summary and formal request as follows: Pursuant to FAR 1125 and for the reasons set forth above, Key Air respectfully requests that the Administrator, on an expedited basis and without publication in the Federal Register, grant Key Air an exemption from Article 135.225 (t) (1) of the Federal Aviation Regulations. The exemption is necessary to conduct takeoffoperations inreduced visibility conditions at Military and Foreign airports. Respectfully submitted,

Christopher R. Hand Director ofOperations Key Air, LLC 203-575-4428

KeyAir, LLC'sPetition for Exemption Date: July152015

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