RLC, LLC

                                                                                                                                                                                      430 North Eola                                                                                                                                                                               Broussard, LA 70518                                                                                                                                                                                                                        Phone 337.837.6038

                                                                                                                                                                                                                     Fax      337.837.9938                                                                                                                                                            www.RLCLLC.net

US Department of Transportation 

Docket Operations 

West Building Ground Floor 

1200 New Jersey Avenue 

Washington, D.C. 20590 

Request for Exemption from 14 CFR Part 135.160(a) 

As per the requirements of 14 CFR 11.63 and 11.81

Requester’s Name and Complete Mailing Address 

Rotorcraft Leasing Co LLC (d.b.a. RLC.LLC) (Air Carrier YTRA264L) 

Dru Milke, CEO 

430 N. Eola Rd. 

Broussard, La 70518 

dmilke@rlcllc.net 

Applicability: Bell Helicopter Model 206B, 206L1, 206L3, 206L-4 and 407. 

Description of Proposed Exemption: Rotorcraft Leasing Co LLC (RLC) would like to 

be granted an exemption from 14 CFR Part 135.160. The rule requires that: 

“After April 24, 2017, no person may operate a rotorcraft unless that 

rotorcraft is equipped with an operable FAA-approved radio altimeter, or 

an FAA-approved device that incorporates a radio altimeter, unless 

otherwise authorized in the certificate holder’s approved minimum 

equipment list” 

RLC currently operates a fleet of 38 BHT Model 206B, 206L1, L3, L4 and 407 

helicopters. Our primary business is to provide transportation services to the offshore 

Oil and Gas Industry. 

RLC requests an extension of time for compliance with the new regulations based on 

two major factors- 1) The Adverse Impact on RLC Employees and Customers; and

2) Mitigating factors of RLC’s operating environment and technologies/ 

procedures utilized by RLC that maintain the level of safety sought by the 

requirement of 14 CFR Part 135.160. If RLC were unable to continue their service 

because of its financial inability to comply with 14 CFR Part 135.160, we believe it will 

have an adverse impact on or there are mitigating factors related to:
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July 27, 2016 

Page | 2 

RLCs Employees and Customers 

Impact on employees - Since part 135 operations comprise all of RLC’s 

business, if RLC was unable to comply with 14 CFR Part 135.160 and is forced 

to suspend 135 operations, RLC’s employees would be unemployed. This would 

be an additional 300 people that will be out of work in an industry that has seen 

tens of thousands of people lose their jobs in the last 18 months +/-. Moody’s 

estimates that for every job lost, it leads to 3.43 jobs lost in other sectors of 

the economy. Based on this, if the 300 employees at RLC were out of work, it 

would result in more than 1,000 people losing their jobs in other industries in the 

local/regional area. 

Impact on Customers - RLC moves between 20,000 and 25,000 personnel per 

month for our customers. If RLC were to suspend 135 operations due to its 

inability to comply with 14 CFR Part 135.160 the impact on our customers could 

be catastrophic if they are unable to find adequate replacement services timely. 

Given that most all part 135 providers to the oil industry have drastically reduced 

their capacity of personnel and aircraft, our customers’ ability to locate 

replacement providers could be questionable. This would severely limit their 

ability to conduct their normal production oversight and repairs and could lead to 

the interruption of their oil & gas production. 

RLC’s Operation and Technology/ Procedure to Radio Altimeters 

Operating Environment- RLC operates exclusively in the offshore and costal 

estuary environment that is at or near sea level. The benefits sought by 14 CFR 

Part 135.160 have limited benefit to RLCs operating environment that is void of 

hills, buildings, etc that are present in a city or non-offshore environment. Over 

the last five years RLC has compiled a safety record for flight operations that is 

second to none in our area of operations. These positive safety results are driven 

by a positive safety culture and the extensive use of technology and operating 

procedures that are strictly designed for RLCs operations. 

Mitigating technology’s/procedures that enhance safety– RLC employees a 

number of technologies and procedures that mitigate enhancements desired by 

the new rule 14 CFR Part 135.160. These include: 
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July 27, 2016 

Page | 3 

Satellite tracking/ flight following- All of our aircraft are monitored with 

satellite tracking that supplement voice radio calls. We receive updates 

on each aircraft every 3 minutes during flight. Given our operating 

environment is all within 20’ of sea level. Controlled Flight into water is 

one of our major concerns. Our satellite system allows us to set altitude 

(ex. 100’) and air speed alerts (less than 50 knots) that signal our flight 

control personnel if aircraft drop below these minimums. 

Enhanced Operational Controls – RLC operations are primarily VFR in an 

environment where weather can (and does) change very quickly at times. 

Due to rapidly changing weather conditions, inadvertent IMC and 

Controlled Flight In to Terrain (CFIT) are of great concern. RLC have 

developed procedures managed by our flight control personnel if/ when 

weather conditions begin to deteriorate. These controls range from simple 

notifications on condition and accelerate to the point that each flight must 

be approved by our Flight Operations Specialist (FOS – one of two 

individuals that manage our flight control department and have significant 

operational experience in RLC’s operating environment and the 

associated changing weather conditions). 

Based on the adverse impact on RLC’s employees and customers and the mitigating 

factors RLC employees in its day to day operations, RLC requests a 2 year delay in the 

required conformity to 14 CFR Part 135.160 until April 17, 2019. 

Sincerely, 

Drury Milke 

CEO 

Rotorcraft Leasing Company, LLC