### ______________________________________________________________________________

Era Helicopters LLC • PO Box 6550/70606 • 600 Airport Service Road • Lake Charles, LA 70605 • 337.478.6131 www.erahelicopters.com

P age 1 of 2 January 26 , 201 6
US Department of Transportation Docket Operations, M

- 30 West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE. Washington, DC 20590 Subject: 1 4 CFR § 91.9(a) Exemption Request
Dear Sir or Madam : I n acc o rd a n c e w ith Title 14 of the Code of Federal Regulations , Parts 11.15 a nd 11.81, Era Helicopters LLC , re q u e sts a n e x e mption fr om § 91.9 ( a ) wh i c h, in p ar t, st a t e s: E x ce pt a s p r ovid e d in p a r

a g ra ph ( d ) of this s ec tio n , no p er son m a y op e ra te a c ivil a i rc r af t
w ithout c omp l

y i n g w ith the op e ra ti n g limit a tions sp e c i f i e d in the a

p p r ov e d Roto r

craf t F li g ht M a nu a l, m ar

ki n g s, a nd p l acar

ds, or a s oth e r

w ise p re s cr ib e d b y t h e c e r ti f y i n g a utho r i t y of t h e c ount r y o f r e g ist r y . This petition requests an exemption from the following Airbus EC

- 225 Rotorcraft Flight Manual L imitation : Part 1, Section 2.1, Paragraph 3: Approved Flight Conditions CATEGORY A with a maximum of 19 passenger seats or CATEGORY B with a maximum of 9

- or
- less passenger seats, day, night, VFR and IFR

. (Emphasis added). Specifically, Era Helicopters requests to operate the EC

- 225 with a maximum of 19 passenger seats without complying with the “Category A” requirements specified in the RFM

. The EC

- 225 is a modern, 19

- passenger aircraft certified in accordance with the comprehensive safety standards of 14 CFR § 29 , and equipped with state

- of

- the

- art safety systems and technology

. Era began operating the EC

225 under Operations Specification H 100 in the US in May of 2008, and under JAR

- OPS 3 in other countries, in 2009. Both rules allow for flight profiles maintaining limited exposure to engine failure. The requested exemption will continue the operational standard that has been established by Ops Spec H100 and JAR

- OPS 3. O perating the EC

- 225 within “Category A” Limitations, would result in decreased passenger loads, which will require more fli ghts, and effectively increase the risk to passengers due to statistical hazards associated with take

- off and landings that are unrelated to engine failure. Additionally, full compliance with the “Category A” Flight Manual Limitation s c ould make operating the EC

- 225 economically unfeasible, and would likely result in its removal from s ervice. The outcome of which would be a reversion to smaller, older, and less sophisticated aircr aft that do not offer the level of safety equipment and certification standards provided by the EC

- 225 certified in accordance with the latest 14 CFR § 29 stan dards

. Any of these options would result in unintended, increased risk to the flying public.Page 2 of 2

Operation of the EC

- 225 in accordance with this exemption will provide continued operations in the Category A profile ( clear area ), and Performance Class 2, Defined Limited Exposure ( PC2 DLE) profile (elevated helideck ), with limited exposure to single engine failure as required by the Era EC

- 225 Standards Manual. This manual requires all o perations to be conducted within weight, altitude, and temperature par ameters in accordance with appropriate EC

- 225 RFM chart, (Section 10.5.A1 , A dditional Climbing Performance Makila 2A1 Engines Equipped (POST

- MOD 07 26592) ). This performance standard ensure s a 1 50 f t

. per minute rate of climb at 1,000 feet above the takeof f surface with one engine inoperative (OEI), and the remaining engine at maximum continuous OEI power. In addition to the safety assurances described above, Era Helicopters offers the following risk mitigations:

• Leve l D, FFS pilot training ;

• Annual pilot co mpetency and proficiency checking;

• Flight Data Monitoring;

• Sea State 6, emergency flotation equipment;

• Automatically deployable life rafts;

• Helicopter Emergency Egress Lighting System (HEELS) ;

• Personal flotation equipment; and

• Automatically deployable emergency locator transmitter s (ADELT s )

. Between 2007 and 2011, the global EC

- 225 fleet ha s accumulated over 400,000 flight hours of operational experience with an engine failure rate of less than 0.6 per 100,000 flight hours , (the engine fail rates are detailed in enclosures A: Technical Memo #AA082076 ) . Based on this reliability data, the Category

- A

- P erformance

Standard , equivalent level of safety is achieved when operating within PC2 DLE and Category A profiles as outlined in the Era Standards Manual

. T his exemption is in the interest of safety to the flying public

. For operations in foreign airspace , prior authorization of the Civil Aviation Authority with jurisdiction over that airspace will be obtained

. If there are any questions concerning this pet ition, or to report the disposition of this request, please contact me as indicated below. Sincerely,

Filed electronically using the Federal Document Management System, http://www.regulations.gov , on this date. Larry Lippert Director of Operations Era Helicopters, LLC Office: +1 337 656 4541 Mobile +1 337 302 9719 llippert@erahelicopters.com

### 1 APPLICABILITY 

## SECTION 

## 2.1 GENERAL LIMITATIONS

ALL LIMITATIONS SPECIFIED IN THIS SECTION ARE MANDATORY. These limitations are applicable to the standard aircraft version. FLIGHT MANUAL

Any additional limitations resulting from CATEGORY A operation are specified in CAT.A (MAKILA 2A) or CAT.A.A1 (MAKILA 2A1) sections. Any additional limitations resulting from the installation of optional equipment are specified in SUPPLEMENTS section.


### 2 CERTIFICATION CRITERIA
This helicopter is certified in accordance with FAR 29 CATEGORY A and CATEGORY B requirements.


### 3 APPROVED FLIGHT CONDITIONS
CATEGORY A with a maximum of 19 passengers seats or CATEGORY B with maximum of 9 or less passengers seats, day, night, VFR and I FR.


### 4 RESTRICTIONS
The following are prohibited:

- Acrobatic flying.

- Extended rearward flight liable to allow exhaust gases to enter cabin.

- Intentional running landings on soft ground.

- Deliberate penetration into clouds with massive vertical development.

- Intentional full auto-rotation landings.

- Downwind flight with the bleed valve not in offset position.

- Intentional single-engine flight in normal operation, except for maintenance test flight.

- Fuel transfer between tank groups during takeoff or landing.

- Flight in known icing conditions.

- Use of combined standard ground speed (Post-MOD 07 .26606) and CRHT modes for 

### 1 lAS< 30 kt.

- Use of CRHT mode in IMC above land.

- Back course.

- Opening of the hinged and stairway doors in flight (if fitted).
NOTE Local icing phenomena may occur in humid conditions with an indicated outside air temperature of +3°C.

EASA APPROVED: EC225 LP 

# 2.1

10-04 Page 1

The document reference is online. please cbe<:k the com:sponderu:e between the online documenbrtion and the printed version.

## EC225 SUPER PUMA STANDARDS MANUAL

DATE ...................... 01/26/2016 REVISION NUMBER..........1 PAGE.................................... 6 REFER TO LIST OF EFFECTIVE PAGES



### 3.2. Takeoff and Landing Pe rformance Standards Clear Area and Short Field 

### Category A standards, as defined in the EC -225 RFM, shall be used when able. When operational conditions do not al low for Category A performanc e standards, the PIC shall ensure compliance with the following:

 The appropriate Category A pr ofile shall be utilized; and

 Operations shall be conducted within weight, altitude, and temperature parameters in accordance with appropriate EC-225 RFM chart, (Section 10.5.A1, Additional Climbing Performance Makila 2A1 Engines Equipped (POST-MOD 07 26592)), i.e. 150 ft. per minute rate of climb at 1,000 feet above the takeoff surface with one engine inoperative (OEI ), and the remaining engine at maximum continuous OEI power.

Elevated Helideck 

### Performance Class 2, Defined Limited Exposure (PC2 DLE) standards, as defined in the EC-225 RFM, shall be used wh en able. When operational co nditions do not allow for PC2 DLE performance standards , the PIC shall ensure comp liance with the following:

 The appropriate PC2 DLE prof ile shall be utilized; and

 Operations shall be conducted within weight, altitude, and temperature parameters in accordance with appropriate EC-225 RFM chart, (Section 10.5.A1, Additional Climbing Performance Makila 2A1 Engines Equipped (POST-MOD 07 26592)), i.e. 150 ft. per minute rate of climb at 1,000 feet above the takeoff surface with one engine inoperative (OEI ), and the remaining engine at maximum continuous OEI power. Ground Level Helipad 

### Vertical Category A standards, as defined in the EC-225 RFM, shall be used when able. When operational conditions do not allo w for Vertical Category A performance standards, the PIC shall ensure co mpliance with the following:

 The appropriate Obstacle Clearance Co nfined Area OGE (Takeoff or Landing) profile shall be utilized; and

 Operations shall be conducted within weight, altitude, and temperature parameters in accordance with appropriate EC-225 RFM chart, (Section 10.5.A1, Additional Climbing Performance Makila 2A1 Engines Equipped (POST-MOD 07 26592)), i.e. 150 ft. per minute rate of climb at 1,000 feet above the takeoff surface with one engine inoperative (OEI ), and the remaining engine at maximum continuous OEI power.