2 3 May 2012

Docket Management Facility US department of Transportation 1200 New Jersey Avenue, SE We st Building Ground Floor Room W 12

- 140 Wa shington, DC 20590
Wi lliam R. Alex

- Project Manager wralex@verizon.ne t Direct (909) 732 4148 Tyler Camera Systems 14218 Aetna Street Van Nuys, CA 91401 Tyler Camera Systems, also DBA Tyler Technologies, a technical design and aviation manufacturing company has been in business for over 48 years. Our engineering, design, and manufacturing process is solely related to the helicopter industry. Tyler Camera Systems has worked extensively with the FAA and has successfully processed over 20 STC’s for helicopter camera mounts and external cargo racks for both Human External Cargo (HEC) and non - human loads. Tyler Camera Systems has developed the Tyler Supplemental Safety System to be employed by essential crewmembers while performing HEC Operations for the electric utility industry. Tyler Camera Systems is seeking relief from e xisting regulations by this request for exemption so that this additional safety enhancement device can be implemented. Electric Utility companies continuously serve the entire public interest by their mandates, charters and corporate structures, as suppl iers of essential electricity services nationwide. The United States power grid is aging and in need of significant refurbishment as well as new construction to meet ever increasing demands. A significant portion of the power grid is between 40

- 50 years o ld. A recent California Energy Commission report is predicting a conservative power growth need of 1.4 percent per year until 2020. Power outages are a nationwide concern. Most recently a significant power outage affecting Southern California and Arizona in 2011 was reviewed by both The Federal Energy Regulatory Commission (FERC) and North American Electrical Reliability Corporation (NERC) the report placed a heavy emphasis on the aging power grid as a contributing factor. Federal and State Regulatory ag encies, public concern, and corporate governance have prompted the major California Utilities as well as other providers’ nation wide to invest heavilyin new construction projects in addition to major repair and renovations of their grid

infrastructure.
In the W estern United States, new construction often traverses mountainous terrain, environmentally sensitive and inaccessible geography. New Construction in addition to major repair and renovation performed with the use of helicopters is essential to the successful completion of the work in addition to respecting the environmental and conservation mandates. In Oct 2006 the Federal Aviation Administration issued **NOTICE N8000.330.** In the notice Section 4. Guidance, (a), (1), (2) Defines the transportati on of utility company personnel (lineman) while performing patrols, maintenance and repairs of electrical power lines as Class B external

- load are performing an essential function in connection with the external

- load operation and are necessary to accompli sh the work. Transportation by helicopter and precision placement of personnel within these remote sites by class B

- external (HEC) has become essential to the successful performance of these tasks. W hen the order expired in 2007 much of the language fail ed to make the transition to FAA Order 8900.1, which provides guidance to FAA inspectors. In the interim many operators sought to increase the safety level of their crewmembers suspended beneath the helicopter. W hile well intentioned, several unauthorized products have evolved and became commonplace in their usage. Currently, there is no approved device available for the conduct of human external cargo (HEC) operations that meets the requirements set forth in 14 CFR Part 865(c), (1), (ii). It also would be difficult if not impossible for the typical single engine aircraft used in these types of operations to comply with those requirements. W hen the certification requirements were developed it was well before the time there was any idea or vision si ngle engine aircraft certificated under Part 27 would be authorized to conduct HEC Operations. Tyler Camera Systems and Tyler Technologies have now designed a device for this specific purpose. Tyler Technologies manufactures an external cargo rack system for H

- 369 series of helicopters which are FAA STC approved STC # SR01682LA and is manufactured under PMA approval number PQ1270NM, dated 1

- 13

-2005. Tyler Technologies also manufactures an External Attach frame FAA STC # SR02067LA and manufactured under th e PMA approval number PQ1270NM, dated 10

-26

-2007. Tyler Camera Systems has designed the Tyler Supplemental Safety System , by combining STC # SR01682LA and SR02067LA. This design will give essential crewmembers being carried as human external cargo (HEC) , an additional fail

- safe mechanism thus providing an additional layer of safety. The Tyler Supplemental Safety System will be completely isolated from the aircraft’s primary and secondary quick

- release systems and will have an independent dual action re lease thus meeting the requirements of 14 CFR Part 865(c), (1), (ii).Tyler Camera Systems is requesting an exemption for relief from 14 CFR Part 27.337

- 341, 14

CFR Part 27.865 (b), (3), (ii), (B) and 14 CFR Part 27.571 and all other applicable and relevant sections. The following limitations will be incorporated as part of the requested exemptions to further enhance the systems safety. 1. Maximum supplemental hook load 600 pounds. 2. The Tyler Supplemental Safety System shall not be used for carryin g external cargo loads. 3. The Tyler Supplemental Safety System is not authorized for energized operations. 4. The exemption would be valid in the continental United States, Alaska and Hawaii. 5. The Tyler Supplemental Safety System is limited to the following aircraft: MD Helicopters H

- 369 Series, 500N, Bell 407 and Eurocopter AS

- 350, 355 Series.
Tyler Camera Systems has been requested by several major electric utility providers as well as 14 CFR Part 133 certificate holders to design an engineering solution for both the safe and compliant solution to the additional safety requirements as mandated by 14 CFR Part 27.865 while conducting 14 CFR Part 133 external

- load, Class B

- Human External Cargo Operations. Tyler Camera Systems believes that modification of ou r current STC’s to create the Tyler Supplemental Safety System is clearly in the public interest and in fact provides an significantly INCREASED level of safety for the utility lineman participating in these types of operations above those prescribed in 27 .865. Granting of the exemption would allow immediate implementation additional safety device.