KEY AIR 

. , __ ; 

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 fax 
Petition of: 

Key Air, LLC 

Regulatory Docket 

No. 

for an exemption 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) of the Federal Aviation Regulations 

to operate aircraft on an .IFR takeoff at military or foreign airports with visibility reported at less 

than 1 mile. 

Article of the FAR affected: 

Article 13 5.225 (f) (I) provides, in pertinent 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 having jurisdiction over that airport. In addition, no pilot may, at that airport-

(1) Take off under .IFR when the visibility is less than 1 mile: 

Exemption request: 

Key Air proposes to conduct I FR take 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 in accordance with the limitations and provisions of Operations Specification paragraph 

C079. Further, this proposal requests identical privileges at military and foreif,'11 airports as those 

described in the provisions of our current Operations Specification paragraph C079. 

Key Air will comply with the applicable instrument approach procedures and weather minimums 

prescribed by the authority having jurisdiction over foreign and militmy airports. 

This petition applies to all aircraft Key Air has listed on the certificate's D085 Aircraft listing 

Operational Specification. 

Key Air, LLC's Petition for Exemption Page lof3 
In support of this 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 064 7 8. Key Air holds Air Carrier Operating Certificate Number KK Y A467B issued 

on December 4, 1989 and re-issued on April 13, 2007 and conducts air taxi and on 

demand charter operations under FAR 135. 

2. The demands of the charter (air taxi) service operated by Key Air include operations at 

military airports as well as at airpmis in foreign countries. 

3. All Key Air crewmembers are trained and evaluated in FAA -approved Level C and D 

simulators underanFAA-approved 14CFRPart 135trainingprogram. TheLowerthan 

Standard Takeoff Minimums (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 Air training meets all the regulatory requirements 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 visibility take off operations under FAR 135 at military airports as well 

as at airports in foreign countries. In over 21 years of experience in the management of 

reduced visibility take off operations under FAR 135, Key Air has never experienced a 

perfonnance or safety issue. 

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) Air Charter Safety Foundation ( ACSF) ; and 

2) IS-BAO. 

7. Key Air believes that this exemption would permit us to respond to a growing demand 

for chartered air transportation 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 Foreign airports would impose an unreasonable burden to general public. If 

Key Air, LLC's Petition for Exemption Page2of3 
granted, this exemption would be in the public interest while still maintaining the highest 

level of safety. 

Good cause fonvaiving publication and 120-day filing requirements exists because: 

Key Air respectfully requests a waiver of the 120-day filing requirements and the publishing of a 

summary of the Petition in the Federal Register. The delay in the granting of this exemption 

request will result in additional delay for relief that has already been granted to Part 119 

certificate holders operating underPart 121 (byrule) and Part 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 takeoff operations in reduced visibility conditions at Military 

and Foreign airports. 

Respectfully submitted, 

Christopher R. Hand 

Director of Operations 

Key Air, LLC 

203-575-4428 

Key Air, LLC'sPetition for Exemption 

Date: July152015 

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