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 24, 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 operate 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 flight 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 

approved 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 Sikorsky 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 S92A’s are equipped with aircraft floatation gear and are certified for ditching in up 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 deployable 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 surveillance. 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. 

Operations will not be conducted unless the current aircraft weight, altitude, and temperature ensure 150 

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 one engine 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 configuration; (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 resource 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 conducted 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 Manual, Part 2, Section III, Supplemental Performance 

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 with 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 and 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 Ops Spec H100. To date 

Chevron Aircraft Operations 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 AC2R685K 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 model 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 200,000 safe flight hours. The fleet upgrades to the newer model 

S92-A will provide a higher level of safety and reliability for our passengers.

Experience demonstrates that when takeoff and landing techniques are used to minimize exposure to 

forced landing due to engine failure, that this aircraft can be operated at an equivalent level of safety to 

Category A. Additionally, without the exemption relief, because Ops Spec H100 is no longer issued, it 

would become economically unfeasible to operate this aircraft which would likely result in their removal 

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 

those 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 operators, who uses the S-92A, petitioned and were granted 

exemptions (No. 10507) 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 locations. 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 additional 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 attached.

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