pljenkins
Resident Knucklehead
In the eyes of the FSDO, I would suspect that the situations that fall within the purview of "circumstances beyond the operators control" to be very narrowly defined. On the surface, any situation that occurs with any manner of regularity is no longer "beyond the operators control", such as the OP's situation. This is a clear violation of 121.465. Having a flight schedule that is designed to exceed dispatch coverage is a clear violation of 121.465, as would one that is subjected to situations that would regularly allow it to exceed said limitations (chronically delayed flights for instance, or "pie in the sky" unreasonable routing assumptions like scheduling a flight for 3 hours when it cannot be completed in that timeframe).
The constant of all of this is NONE of these situations lays the onus of compliance at the feet of the dispatcher. I would be genuinely astonished if a dispatcher got a LOI for violations of 121.465. The only beef the feds might have is if you have knowledge of the violation and failed to report it.