23 May 2012

Docket Management Facility

US department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12-140

Washington, DC 20590

William R. Alex-Project Manager

wralex@verizon.net

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 existing 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 suppliers 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 old. 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 agencies, public concern, and corporate governance have 

prompted the major California Utilities as well as other providers’ nation wide to invest heavily 
in new construction projects in addition to major repair and renovations of their grid 

infrastructure. 

In the Western 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 transportation 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 accomplish 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. When the order expired in 

2007 much of the language failed 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. While 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. When the certification requirements were 

developed it was well before the time there was any idea or vision single 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 the 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 release 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 carrying 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 our 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.