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

October 9, 2015
US Department ofTransportation Docket Operations, M-30 West Building Ground Floor, Room Wl2-140 1200 New Jersey Avenue, SE. Washington, DC 20590 Subject: Request for Extension to Exemption No. 8852C, Regulatory Docket No. FAA-2005-20038 Exemption from 14 CFRPart 135.411 (a)(2); 135.411 (a)(1); 91.413(c); 91.411(b) Filed electronically using the Federal Document Management System, htq>://www.regulations.gov. on this date.
Dear Siror Madam:
Era Helicopters, LLC (Era Helicopters) is a commercial Air Carrier authorized under Title 14 CFR, Part 119 and Part 135 (Air Carrier Certificate No. UOGA290L). EraHelicopters currently operates 118 aircraft on the Air Carrier Certificate. 41 aircraft are maintained in accordance with 135.41l(a)(2) and 77 aircraft are maintained in accordance with 135.4ll(a)(l). Under the provisions ofTitle 14 CFR Part 91.413(c)(2) and Part 135.411(a)(2) Era performs the required inspections ofPart 91.411 and Part 91.413 on all ofthe 135.411(a)(2) "CAMP" aircraft. The literal interpretation ofthe rule, Title 14 CFR 91.413(c) (2), implies that the holder ofa Continuous Airworthiness Maintenance Program (CAMP) can perform these tests and inspections. It does not state that all aircraft owned or operated by the operator must be maintained under a CAMP to comply with this rule. The majority ofEra's aircraft maintained under Part 135.4ll(a)(l) are stationed remotely throughout the states ofAlabama, Alaska, Louisiana, Massachusetts, North Carolina, and Texas. The economic burdento contract a Part 145 Repair Stationtotravel tothese locations forthese inspections exceeds that which other operators mustbear. EraHelicopters requests the continued ability to comply with the inspections required by Part 91.411 and Part 91.413 on our aircraft maintained under Part 135.411(a)(l). Era Helicopters' trained personnel currentlyperformthese inspections on larger, more complex aircraft maintained under Part 135.4ll(a)(2). Their familiarity with Era's aircraft exceeds that which an outside Part 145 contractor can provide.

Page 1 of2AllowingEraHelicopterstoperformthese inspections wouldbenefitpublic interestby allowing ourtrained personnel to complete these inspections instead ofan outside entity that is often less reliable and cannot always be available in the timeframe required

. This unavailability can often mean aircraft are grounded andthe public customers are losing valuable services when EraHelicopters has qualified personnel on site and can performthe required inspections. Exemption from Title 14 CFR Part 91.4ll(b) and Part 91.413(c) for Era's Part 135.4ll(a)(1) aircraft maintainedunder an Approved Aircraft Inspection Program (AAIP) would provide an equal orhigher level ofsafetyasthe currentrule. The same conditions and limitations from ouroriginal exemption 8852B would apply

. Proposed Conditions and Limitations:

1. All ATC transponder tests and inspections and altimeter reporting equipment tests and inspections must be conducted under Era's Part 135 General Maintenance Manual. 2. All tests andinspections must be recorded in the aircraft's maintenance log bythepersonperforming each inspection and test. This record must identify the person performing the inspection, the date of the inspection, and this exemption number. 3. All records ofthese tests and inspections must be kept in Era's maintenance recording system for its aircraft operated under Part 135. Sincerely,

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