______________________________________________________________________________

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

www.erahelicopters.com

Page 1 of 2

January 26, 2016

US Department of Transportation

Docket Operations, M-30

West Building Ground Floor,

Room W12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

Subject: 14 CFR § 91.9(a) Exemption Request

Dear Sir or Madam:

In accordance with Title 14 of the Code of Federal Regulations, Parts 11.15 and 11.81, Era Helicopters 

LLC, requests an exemption from § 91.9(a) which, in part, states:

Except as provided in paragraph (d) of this section, no person may operate a civil aircraft 

without complying with the operating limitations specified in the approved Rotorcraft

Flight Manual, markings, and placards, or as otherwise prescribed by the certifying

authority of the country of registry.

This petition requests an exemption from the following Airbus EC-225 Rotorcraft Flight Manual Limitation:

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 EC225 under Operations Specification H100 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.

Operating the EC-225 within “Category A” Limitations, would result in decreased passenger loads, which will 

require more flights, 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 Limitations could make operating the EC-225 economically unfeasible, and would likely result 

in its removal from service. The outcome of which would be a reversion to smaller, older, and less sophisticated 

aircraft 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 standards. 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 operations to 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)). This performance standard ensures a 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.

In addition to the safety assurances described above, Era Helicopters offers the following risk mitigations:

• Level D, FFS pilot training;

• Annual pilot competency 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 transmitters (ADELTs).

Between 2007 and 2011, the global EC-225 fleet has 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-PerformanceStandard, equivalent level of safety is achieved when operating within PC2 DLE and Category A profiles as 

outlined in the Era Standards Manual.

This 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 petition, 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 Performance 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 allow for Category A performance standards, the PIC shall 

ensure compliance with the following: 

 The appropriate Category A 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. 

Elevated Helideck 

Performance Class 2, Defined Limited Exposure (PC2 DLE) standards, as defined in the 

EC-225 RFM, shall be used when able. When operational conditions do not allow for 

PC2 DLE performance standards, the PIC shall ensure compliance with the following: 

 The appropriate PC2 DLE 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. 

Ground Level Helipad 

Vertical Category A standards, as defined in the EC-225 RFM, shall be used when able. 

When operational conditions do not allow for Vertical Category A performance 

standards, the PIC shall ensure compliance with the following: 

 The appropriate Obstacle Clearance Confined 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.