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Legal Interpretations

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Hedlund-SWA 2008

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Summary

The Question

What does "intermediate stop" mean for purposes of 14 CFR 121.391 and Exemption 9382?

Background

The manager of the FAA's Southwest Airlines Certificate Management Office requested an interpretation, on behalf of Southwest Airlines, of the term "intermediate stop" in 14 CFR 121.391 and Exemption 9382.

The FAA’s Interpretation

A stop where passengers remain on board and proceed on that aircraft to another destination. That is the definition in the preamble to a 1982 amendment to 14 CFR 121.391 and in earlier and later interpretations; the FAA has used it consistently for almost 30 years and has not redefined it, so Exemption 9382 must be read the same way.

Requester
Hedlund
Organization
SWA
Issued
June 4, 2008
Subject
Air Carrier & Commercial Operations

Regulations Cited

  • 14 CFR 121.391

Unreadable text from the scan (such as a barcode or stamp) is left out of the text below; the original letter shows it exactly.

Page 1

U.S. Department
of Transportation
Federal Aviation
Administration
JUN 4 2008
Mr. Bobby Hedlund
. Office of the Chief Counsel
Manager, Southwest Airlines CMO
Federal Aviation Administration
Freeport Office Center III
8700 Freeport Office Parkway
Suite 250
Irving, TX 75063
Dear Mr. Hedlund,
800 Independence Ave., S.W.
Washington. D.C. 20591

The following analysis is in response to your May 23, 2008, request for a legal interpretation on behalf of Southwest Airlines regarding the meaning of "intermediate stop" in relation to 14 C.F.R. § 121.391 and Exemption 9382.

The definition of intermediate stop, as set forth in the preamble to a i 982 amendment to § 121.391, is a stop "where passengers remain on board and proceed on that aircraft to another destination. [These stops] are usually of short -duration." 47 Fed. Reg. 56460. This definition is consistent with legal interpretations which describe an intermediate stop as "a stop where passengers remain on board." See Letter from Donald P. Byrne, Assistant Chief Counsel, Regulations, to Gregory Michael, Manager, Air Transportation Division, FAA Flight Standards Service, May 8, 2001 (answering request for legal interpretation of §121.391 and defining intermediate stop as a stop where passengers remain on board); Legal Interpretation 1988-3 (Mar. 5, 1988) (defining intermediate stop as a stop where passengers remain on board); Legal Interpretation 1979-31 (June 4, 1979) (referring to intermediate stop as a stop where passengers remain on board).

For almost 30 years, the FAA has consistently defined, and referenced, intermediate stops as those stops where passengers remain on board and proceed on that aircraft to another destination. The FAA has not redefined this term. Thus, in reviewing Exemption 9382, the term "intermediate stop" must be read in accordance with its definition and longstanding FAA interpretation as a "stop where passengers remain on board and proceed on that aircraft to another destination." 47 Fed. Reg. 56460.

Sincerely,

~4;;,o~Y--Assistant Chief Counsel, Regulations Division, AGC-200

Regulations Referenced

14 CFR 121.391

Snapshot retrieved August 6, 2026.

Summary

The Question

What does "intermediate stop" mean for purposes of 14 CFR 121.391 and Exemption 9382?

Background

The manager of the FAA's Southwest Airlines Certificate Management Office requested an interpretation, on behalf of Southwest Airlines, of the term "intermediate stop" in 14 CFR 121.391 and Exemption 9382.

The FAA’s Interpretation

A stop where passengers remain on board and proceed on that aircraft to another destination. That is the definition in the preamble to a 1982 amendment to 14 CFR 121.391 and in earlier and later interpretations; the FAA has used it consistently for almost 30 years and has not redefined it, so Exemption 9382 must be read the same way.

Requester
Hedlund
Organization
SWA
Issued
June 4, 2008
Subject
Air Carrier & Commercial Operations

Regulations Cited

  • 14 CFR 121.391