BEFORE THE 

DEPARTMENT OF TRANSPORTATIQ1N f 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

In the matter of the cancellation of the 

Air Taxi authority issued to: 

VIH COUGAR HELICOPTERS, INC. 

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Docket DOT -OST -2012-0022 

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_____________________________ ) 

MOTION OF PETROLEUM HELICOPTERS, INC. NORTHERN PIONEER 

HELICOPTERS LLC AND SOLOY HELICOPTERS LLC TO 

WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE 

Communications with respect to this document should be sent to: 

Jonathan Blank 

John Longstreth 

Timothy Hobbs 

K&L Gates LLP 

1601 K Street NW 

Washington, DC 20006-1600 

202-778-9100 (fax) 

jonathan.blank@klgates.com 

john.longstreth@ klgates.com 

tim.hobbs@ klgates.com 

202-661-6250 

202-661-6271 

206-370-7664 
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BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, DC 

In the matter of the cancellation of the 

Air Taxi authority issued to: 

VIH COUGAR HELICOPTERS, INC. 

) 

) 

) 

) 

) 

) 

) 

) 

_____________________________ ) 

Docket DOT -OST -2012-0022 

MOTION OF PETROLEUM HELICOPTERS, INC. NORTHERN PIONEER 

HELICOPTERS LLC AND SOLOY HELICOPTERS LLC TO 

WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE 

Pursuant to Rule 12 of the Department's Rules of Practice, 14 C.P.R. § 302.12, Petroleum 

Helicopters, Inc. ("PHI"), Northern Pioneer Helicopters LLC ("Northern") and Soloy 

Helicopters LLC ("Soloy") hereby move to withhold from public disclosure the unredacted 

Response Of Petroleum Helicopters, Inc., Northern Pioneer Helicopters LLC and Soloy 

Helicopters LLC VIH Cougar Helicopters, Inc.' s("VIH Cougar") Supplemental Production of 

Documents Required by Order 2012-12-9, filed in this docket on December 26,2012. The 

motion is necessary because the Motion contains information that has been designated as 

confidential by VIH Cougar. 

In filing this motion, movants do not concede that any of that material has been properly 

designated as confidential. Movants have moved for an order seeking to make public the 

underlying information on which the Response relies and any other information on which VIH 

Cougar has relied in responding to the Department's Order to Show Cause and in responding to 

Movants' Motion for Final Disposition in this matter. As Movants have previously pointed out, 

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VIH Cougar has previously filed in the pubic docket information it has designated as purportedly 

confidential, and its lack of any principled and consistent basis in treating its designated material 

as confidential is itself a basis to make this information public, as it suggests VIH Cougar's goal 

is more to disrupt to the proceeding and Movants' ability to respond than it is to protect any 

legitimately confidential information. 

A redacted version of the Response has also been filed electronically in the docket, which 

public filing does not contain any of the material that has been designated as confidential. 

Dated: December 26,2012 

Respectfully submitted, 

______ ./s/ ____________ _ 

Jonathan Blank 

John Longstreth 

Timothy Hobbs 

K&L Gates LLP 

1601 K Street NW 

Washington, DC 20016 

Counsel for Petroleum Helicopters, Inc. 

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CERTIFICATE OF SERVICE 

I certify that I have on this 26th day of December, 2012 served the foregoing Motion to Withhold 

Materials from Public Disclosure upon the persons listed below, and have also filed a copy 

electronically in the docket of this proceeding: 

Susan L. Kurland 

Office of the Assistant Secretary for 

Aviation and International Affairs 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Room W96-495 

Washington, DC 20590 

Laural yn Remo 

Office of the Assistant Secretary for 

Aviation and International Affairs 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Room W96-495 

Washington, DC 20590 

Peter Lynch, AGC-300 

Asst. Chief Counsel for Enforcement 

Federal Aviation Administration 

800 Independence Ave. SW 

Washington, DC 20591 

William J. Weber 

Certification Section Manager 

FAAAFS-900 

45005 Aviation Drive Suite 131 

Dulles, VA 20166 

Roy Hardie 

Aviation Safety Inspector 

Federal Aviation Administration 

1601 Lind Avenue SW, Suite 260 

Renton, W A 98057 

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David M. Nadler 

David Y. Yang 

Andrew E. Smith 

DICKSTEIN SHAPIRO LLP 

1825 Eye Street, NW 

Washington, DC 20006 

Telephone: (202) 420-2200 

Facsimile: (202) 420-2201 

nadlerd @dicksteinshapiro.com 

yangd@ dicksteinshapiro. com 

smitha@ dicksteinshapiro.com 

Counsel to VIH Cougar Helicopters, Inc. 

___ /s/ _________ _ 

John Longstreth 

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