Kevin Tauzier

Chief Pilot North American Exploration and Production Company Aircraft Operations 96 Runway Rd. Picayune, Ms. 39466

Tel 601 749

- 4023

Fax 601 749

- 4028

KTauzier @chevron.com

October 2 4 , 2013

Docket Management Facility US Department of Transportation 1200 New Jersey Avenue SE West Building Ground Floor Room W12

- 140 Washington, DC 20590

Subject: Petition for Exemption from § 91.9(a) of Title 14, Code of Federal Regulations.

Dear Sir:

I am petitioning the Federal Aviation Administration (FAA) on behalf of Chevron Aircraft Operations for an exemption from § 91.9(a) of Title 14, Code of Federal Regulations (14 CFR). The requested exemption, if granted, would allow us to opera te Sikorsky S

- 92A (S

- 92A) helicopters with limited exposure to engine failure during takeoff and landing while carrying up to 19 passengers between land

- based and offshore facilities or when operating between two offshore facilities, day, night, visual fli ght rules, and instrument flight rules.

Specifically, we are requesting relief from Section 91.9(a). Section 91.9(a) prescribes, in part, that no person may operate a civil aircraft without complying with the operating limitations specified in the

approv ed Rotorcraft Flight Manual.

This request for exemption is for operations conducted in our Sikorsky S

- 92A aircraft when operating

between land

- based and offshore facilities or when operating between two offshore facilities.

Chevron Aircraft Operations Si korsky S

- 92A helicopters were certified under Part 29, amendment 47, which relates to safety and ditching equipment which provides the highest level of safety today. The S

9 2A ’ s are equipped with aircraft floatation gear and are certified for ditching in u p to sea state 5

. Additionally, when operating over water, each S

- 92A occupant is provided, and wears, personal flotation equipment. Also, the S

- 92A is equipped with life rafts that can be deployed from inside or outside the

aircraft and has 406 MHZ depl oyable beacon

.

European operators, using the same aircraft, operate the S

- 92A in accordance with Joint Aviation Requirement

- OPS

- 3 which already permits similar operations with limited exposure to engine failure.

We believe that the requested exemption will continue to provide the same level of safety that is currently in place for our offshore operations.

Chevron Aircraft Operations has instituted operational controls through its general operations manual, training program, and maintenance surveilla nce. Chevron Aircraft Operations will conduct operations in such a manner as to minimize the time spent exposed to engine failure. This will be accomplished by following the manufacturer’s recommended takeoff and landing procedures whenever feasible. Op erations will not be conducted unless the current aircraft weight, altitude, and temperature ensure 1 5 0 feet per minute rate of climb at 1,000 feet above the takeoff surface with one engine inoperative and the remaining engine at maximum continuous o ne eng ine inoperative (OEI) power.Chevron Aircraft Operations will further mitigate exposure by: (1) Conducting flight operations to and from helidecks and shore based heliports that meet or exceed size and weight requirements appropriate to the

aircraft confi guration; (2) Training its crews in a Level D, FFS (Full Flight Simulator) initially and annually, ensuring the highest levels of proficiency and competency; (3) Conducting route checks to confirm that its crews remain procedurally compliant and use crew r esource management principles during all flight operations; and (4) Using Chevron Aircraft Operations Helicopter Flight Data Monitoring program to ensure flight profiles are in accordance with Performance Class 2 procedures.

Operations will not be conduct ed unless the current aircraft weight, altitude and temperature, as provided
in the S92

- ARotorcraft Flight manual, ensure the ability to climb 150 feet per minute at 1,000 feet above the takeoff surface with one engine inoperative and the remaining engine at maximum continuous one engine inoperative (OEI) power

.

Chevron Aircraft Operations will comply with, in addition to other routine preflight computations, the procedures cited in the S92

- A Rotorcraft Flight M anual, Part 2, Section III, Supplemental Perf ormance Data, page III

- 1

- 67 , contained in the paragraphs titled “Elevated Helideck Takeoff and Landing

- Limited Exposure” Figure 3

- 28 WAT and the paragraph titled “Vertical Takeoff Elevated Helideck”.

Chevron Aircraft Operations will only fly the S92

- A wit h two qualified pilots that are current in operation of

the S92

- A.

Chevron’s Aircraft Operations has an approved training program and includes provisions for training of appropriate crews on the profiles associated with a Performance Class 2 with limited exposure takeoff and arrival, including performance planning. Chevron Aircraft Operations will document the conduct and completion of that training for the appropriate flight crewmembers.

Proficiency in the use of the profiles described in the condition a nd the limitation as mentioned above must be demonstrated satisfactorily during recurrent evaluations required by §61.56 or 61.58.

Chevron Aircraft Operations has been informed that the FAA will not issue Op s Spec H100. To date Chevron Aircraft Operatio ns established in the 1940’s

, operates from land to offshore platform helidecks using several different model aircraft. Chevron Aircraft Operations currently holds Air Carrier Certificate

AC2A685K for Part 135 Operations, Repair Station Certificate AC2R685 K and also operates part 91 General Flight Rules. Although Chevron Aircraft Operation cannot provide engine data for the S

- 92A as it is a newly purchased aircraft, the engine reliability data can be substantiated by two other operators utilizing the same m odel S92

- A which currently hold exemptions (No. 10507) and (No. 10773). Chevron Aircraft Operations has operated eight Sikorsky model S76 for 30 plus years from land to offshore

helidecks and has accumulated over 200,00 0 safe flight hours

. The fleet upgra des to the newer model
S92

- A will provide a higher level of safety and reliability for our passengers.

E xperience demonstrates that when takeoff and landing techniques are used to minimize exposure to forced landing due to engine failure, that this aircra ft can be operated at an equivalent level of safety to Category A. Additionally, without the exemption relief, because Op s Spec H100 is no longer issued, it would become economically unfeasible to operate this aircraft which would likely result in their r emoval from service. Without the exemption relief, we would have to offer to our passenger’s smaller, older, less sophisticated aircraft that do not provide the same level of safety. This would result in an overall degradation of safety and not serve the most important stakeholder, the passenger.

Chevron Aircraft Operations believes that granting of this petition would be in the public interest because

the S

- 92A aircraft have replaced older designs which do not offer the same safety enhancements, and

th ose aircraft are not required to meet the stringent performance requirements imposed on the S

- 92A and

other similar aircraft.

In closing, two other United States helicopter operator s

, who uses the S

- 92A, petitioned and were granted exemptions (No. 105 07) and (No. 10773)

. Chevron Aircraft Operations will also operate our S

- 92A daily

,in the same environment, flying the same missions and flight profiles. We service our passengers in the

same environments , and land and takeoff from the same or like loca tions. We train at the same FFS (Full Flight Simulator) facility and by all accounts, have the exact level of operational experience with similar

aircraft based on our fleet size.

If I may be of further assistance in this matter or if you require additio nal information, please do not

hesitate to contact me or the Chevron Aircraft Operations Gulf of Mexico Business Unit, office located in Picayune Ms . My email is KTauzier@Chevron.com

Additional PDF documents att ached.

If you have any questions regarding this request please don’t hesitate to call?

Thanks,

Kevin Tauzier

Chief Pilot Chevron Aircraft Operations

Tel 601 749

- 4023

Cell 601 569

- 0428