AFS-14-129-E 

April 29, 2014 

 Exemption No. 10985 

 Regulatory Docket No. FAA-2014-0026 

Mr. David Carrizo 

Director of Flight Operations 

Key Lime Air Corporation 

13252 E Control Tower Road 

Englewood, CO 80112 

Dear Mr. Carrizo: 

This letter is to inform you that we have granted your request for an exemption. It transmits 

our decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated January 7, 2014, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Key Lime Air Corporation (Key Lime Air) for an exemption from §§ 121.623(a) 

and (d) and 121.643 of Title 14, Code of Federal Regulations (14 CFR) to the extent 

necessary to allow 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 airports as required by § 121.619 and fuel reserve requirements as required by § 

121.639 that are applicable to domestic operations. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Key Lime Air. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 5307 (copy enclosed), the FAA 

noted that when a domestic air carrier initiates a flight without designating an alternate, its 

dispatcher, a certificated airman, is required to monitor the weather and other events that 

could change and prevent a safe completion of that flight. Should such an occurrence arise, 
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the regulations require the dispatcher to relay this occurrence rapidly to the flightcrew and 

provide them with information to complete the flight safely. The FAA further noted that there 

are no such requirements for flights conducted by a supplemental air carrier. 

The FAA agreed with the previous petitioner that significant fuel savings would result if the 

air carriers were granted an exemption from the requirement to carry enough fuel to fly to an 

alternate airport when the weather conditions were such that, under the domestic regulations 

of part 121, alternate airport fuel would not be required to be carried. 

After careful consideration of the facts and circumstances of the previous petitions, the FAA 

found that an exemption providing relief from the fuel supply and alternate airport 

requirements applicable to supplemental air carriers would not adversely affect safety because 

the fuel supply, dispatch system, flight time limitations, and crew rest requirements applicable 

to domestic air carriers would be established in their place. 

Having reviewed your reasons for requesting an exemption, I find that— 

 they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 5307; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 5307 

also apply to the situation you present; and 

 a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. §§ 106(f), 40113, and 44701, which the FAA 

Administrator has delegated to me, Key Lime Air Corporation is granted an exemption from 

14 CFR §§ 121.623(a) and (d) and 121.643 to the extent necessary to allow 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 airports as required by § 121.619 and fuel 

reserve requirements as required by § 121.639 that are applicable to domestic operations, 

subject to the conditions and limitations described below. 

Conditions and Limitations 

1. Prior to initiating operations under this exemption, Key Lime Air must amend its 

operations specifications to comply with the following regulations applicable to 

domestic air carrier operations: 

a. Part 121, subpart E: All sections; 

b. Part 121, subpart G: § 121.135; 

c. Part 121, subpart M: §§ 121.385 and 121.395; 
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d. Part 121, subpart P: All sections; 

e. Part 121, subpart T: §§ 121.533, 121.541, 121.551, 121.555, 121.557, and 

121.569; 

f. Part 121, subpart U: §§ 121.593, 121.599, 121.601, 121.607, 121.619, 

121.627, 121.635, 121.637, 121.639, 121.659, and 121.663; and 

g. Part 121, subpart V: §§ 121.683, 121.685, 121.687, 121.695, and 121.711. 

2. Key Lime Air must ensure that its aircraft dispatchers hold aircraft dispatcher certificates 

issued under subpart C of part 65 and are properly qualified under part 121, subpart P, 

before permitting those persons to serve in operations conducted under this exemption. 

3. Key Lime Air must conduct its supplemental operations under this exemption— 

a. Within the 48 contiguous United States and the District of Columbia; and 

b. Except as required in §121.637 for unlisted airports, or to, from, or between 

those regular, provisional refueling, and alternate airports listed in its 

operations specifications or listed in a separate current listing, if that listing is 

referenced in its operations specifications and is authorized by the 

Administrator. 

This exemption terminates on May 31, 2016, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John Barbagallo 

Acting Deputy Director, Flight Standards Service 

Enclosure