BEFORE THE DEPARTMENT OF TRANSPORTATIQ1N f OFFICE OF THE SECRETARY WASHINGTON, DC
In the matter ofthe cancellation ofthe Air Taxi authority issued to: VIH COUGAR HELICOPTERS, INC. ) ) ) ) ) ) DocketDOT-OST-2012-0022 ) )



## _____________________________)
MOTION OF PETROLEUM HELICOPTERS, INC. NORTHERN PIONEER HELICOPTERS LLC AND SOLOY HELICOPTERS LLC TO WITHHOLD INFORMATIONFROM PUBLIC DISCLOSURE

Communications with respect to this document should be sentto: 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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# I ' BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, DC
In the matter ofthe cancellation ofthe Air Taxi authority issued to: VIH COUGARHELICOPTERS, INC. ) ) ) ) ) ) ) )



## _____________________________) Docket DOT-OST-2012-0022

MOTION OF PETROLEUM HELICOPTERS, INC. NORTHERN PIONEER HELICOPTERS LLCAND SOLOY HELICOPTERS LLC TO WITHHOLD INFORMATIONFROM PUBLIC DISCLOSURE Pursuant to Rule 12 ofthe Department's Rules ofPractice, 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 OfPetroleum 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 necessarybecause the Motion contains information that has been designated as confidential byVIH Cougar. In filing this motion, movants do not concede that any ofthat material has beenproperly 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 inresponding to the Department's Order to Show Cause and inresponding to Movants' Motion for Final Disposition in this matter. As Movants have previously pointed out,
1VIH Cougar has previously filed in the pubic docket information it has designated as purportedly confidential, and its lack ofany principled and consistentbasis in treating its designated material
as confidential is itselfabasis 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 ofthe Response has also been filed electronically in the docket, which public filing does not contain any ofthe 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.

2CERTIFICATE OF SERVICE I certify that I have on this 26th day ofDecember, 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 ofthis proceeding: Susan L. Kurland Office ofthe Assistant Secretary for Aviation and International Affairs U.S. Department ofTransportation 1200 New Jersey Avenue, SE RoomW96-495 Washington, DC 20590 Lauralyn Remo Office ofthe Assistant Secretary for Aviation and International Affairs U.S. Department ofTransportation 1200 New Jersey Avenue, SE RoomW96-495 Washington, DC 20590 Peter Lynch, AGC-300 Asst. ChiefCounsel for Enforcement Federal Aviation Administration 800 Independence Ave. SW Washington, DC 20591 WilliamJ. Weber Certification SectionManager 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

3David 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 CougarHelicopters, Inc.

___ /s/
_________ _ John Longstreth

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