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 206 B, 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. T he rule requires that:

“After April 24, 2017, no person may operate a rotorcraft unless that rotorcraft is equipped wit h an operable FAA-approved radio altimeter, or an FAA-approved device that incor porates a radio altimeter, unless
otherwise authorized in the certif icate holder’s approved minimum equipment list”

RLC currently operates a fleet of 38 BHT Model 206B, 206L1, L3, L4 and 407 helicopters. Our primary busine ss 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 opera ting environment and technologies/ procedures utilized by RLC that main tain the level of safety sought by the requirement of 14 CFR Part 135.160. If RLC were unable to c ontinue 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 ar e mitigating factors related to:US Department of Transportation 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 wi th 14 CFR Part 135.160 and is forced to suspend 135 operations, RLC’s employ ees would be unemployed. This would be an additional 300 people t hat will be out of work in an industry that has seen tens of thousands of people lose their jobs in the last 18 mont hs +/-. 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 empl oyees 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 repl acement services timely. Given that most all part 135 providers to the oil industry have drastically reduced their capacity of personnel and aircra ft, our customers’ ability to locate replacement providers could be questionabl e. This would severely limit their ability to conduct their normal production ov ersight and repairs and could lead to the interruption of thei r 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 ex tensive 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 t hat mitigate enhancements desired by
the new rule 14 CFR Part 135.160. These include:US Department of Transportation July 27, 2016 Page | 3

Satellite tracking/ flight following - All of our aircraft are monitored with satellite tracking that supplement voic e radio calls. We receive updates on each aircraft every 3 minutes duri ng 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 t han 50 knots) that signal our flight control personnel if aircraft drop below these minimums.

Enhanced Operati onal 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 (CFI T) are of great concern. RLC have developed procedures managed by our f light 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 w eather conditions).

Based on the adverse impact on RLC’s em ployees and customer s and the mitigating factors RLC employees in its day to day oper ations, 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