June 25, 2013 U.S. Department ofTransportation Docket Operations, M-30 West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE. Washington, DC 20590 POST OFFICE BOX 90808 LAFAYETTE, LOUISIANA 70509 USA TELEPHONE: 337 235 2452

Subject: Request for Extension to Exemption No. 10377 docket number FAA2011-0892. Exemption from Title 14, CFR part 91.411 (b) and 91.413(c). Dear Sir or Madam, Pursuant to Federal Aviation Regulation ("FAR") §11.25, (14 CFR §11.25), PHI, Inc. respectfully requests an extension of Exemption No: 10377 docket number FAA-2011- 0892. The requested extension of exemption from Title 14, CFR part 91.411 (b) and 91.413(c) would allow PHI, Inc. air carrier trained personnel to continue to perform air traffic control (ATC) transponder tests and inspections, and the altimeter systems and altimeter reporting equipment test and inspections in accordance with the PHI, Inc. Continuous Airworthiness Maintenance Program (CAMP) on all PHI 14 CFR, Part 135 aircraft that are maintained under the PHI, Inc. Approved Aircraft Inspection Program (AAIP). This exemption expires on October 31, 2013. The reasons and conditions presented in the original petition dated June 10, 2011, upon which the original issuance of Exemption No. 10377 was granted remain unchanged. Pursuant to Federal Aviation Regulation ("FAR") §11.83, (14 CFR §11.83), PHI, Inc. also requests that the use ofthis exemption be allowed outside the United States. At the time of the original petition, PHI, Inc. did not operate any aircraft maintained on an Approved Aircraft Inspection Program (AAIP) outside the United States. Since that time, PHI, Inc. has entered into a contract to provide aircraft operating services in the Kingdom of Saudi Arabia. The reasons and conditions for using the exemption in the Kingdom of Saudi Arabia are the same as those for aircraft operating in the United States.Thank you for your consideration. I look forward to answering any questions you might have. Sincerely,

# ~\;.7J._~ Jeffrey J. Jenkins Chief Inspector Part 135 PHI, Inc. Ph: 337-272-4331 email: jjenkins@phihelico.com

EnclosureJune 10, 2011
U.S. Department ofTransportation Docket Operations, West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE. Washington, DC 20590
Dear Sir or Madam, 

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POST OFFICE BOX 90808 lAFAYETTE, LOUISIANA 70509 USA TELEPHONE: 337 235 2452

PHI, Inc. is a commercial air carrier authorized under Title 14 CFR Part 119 and 135 that provides transportation services to the offshore oil industry and emergency medical services industry. PHI, Inc. operates a mixed fleet of approximately 240 aircraft. These aircraft are maintained in accordance with a Continuous Airworthiness Maintenance Program (CAMP) or an Approved Aircraft Inspection Program (AAIP) in accordance with Title 14 CFR Part 135.411(a)(1) and 135.411(a)(2). As the holder of a CAMP, PHI, Inc. air carrier trained personnel are authorized to perform air traffic control (ATC) transponder tests and inspections in accordance with Title 14 CFR Part 91.413, and the altimeter systems and altimeter reporting equipment test and inspections in accordance with the PHI, Inc. CAMP on all PHI 14 CFR, Part 135 aircraft that maintained under the PHI, Inc. CAMP. PHI, Inc. is requesting an exemption from Title 14 CFR Part 91.411(b) and 91.413(c). This exemption if granted, would allow PHI, Inc. air carrier trained personnel to perform air traffic control (ATC) transponder tests and inspections in accordance with Title 14 CFR Part 91.413 and the altimeter systems and altimeter reporting equipment test and inspections in accordance with the PHI, Inc. CAMP (which includes the same tests and inspections required by Title 14 CFR Part 91.411) on PHI, Inc. 14 CFR, Part 135 aircraft that are maintained on an AAIP. This exemption would benefit the public interest by allowing PHI, Inc. air carrier trained personnel to perform these test and inspections whose familiarity and knowledge of the aircraft is equal to or often exceed that of contracted Title 14 CFR Part 145 repair stations. There is also the benefit of reduced aircraft downtime since many ofthe PHI, Inc. AAIP aircraft are emergency medical services (EMS) aircraft that are stationed remotely throughout the United States that must be taken out of service due to scheduling and travel requirements that arise with the contracting of outside Title 14 CFR Part 145 repair stations. With reduced downtime, there is a higher availability of EMS aircraft to provide life saving transportation services for the benefit ofthe public as a whole. As requirement ofthe CAMP, PHI, Inc. has a full time training staffthat trains air carrier personnel in the testing and inspection procedures and the use ofthe test equipment.Documented procedures and guidance is provided in the PHI, Inc. General Maintenance Manual as required by Title 14 CFR Part 135.21. PHI, Inc. trained personnel that perform the required tests and inspections using the same test equipment and procedures as personnel from a Title 14 CFR Part 145 repair station would be able to make the same determination of airworthiness therefore maintaining a level of safety at least equal to the one required by Title 14 CFR Part 91.411 and 91.413. Thank you for your consideration. I look forward to answering any questions you might have. Sincerely, 

# 'l#t'Y·W...·
Jeffrey J. Jenkins Chief Inspector Part 135 PHI, Inc. Ph: 337-272-4331 email: jjenkins@phihelico.comU.S. Department ofTransportation L=ederal Aviation Administration



### October 24, 2011



### Mr. Jeffrey J. 

### Jenkins Chieflnspector, Part 135 PHI, Inc. P.O. Box 90808 Lafayette, LA 70509
DearMr. Jenkins: ExemptionNo. 10377 800 Independence Ave., S.W. Washington, D.C. 20591



### RegulatoryDocketNo. FAA-2011-0892

This letteris to informyou that wehave granted yourrequest for exemption. It

### transmits our decision, explains its basis, and gives you the conditions and limitations ofthe exemption, including the date it ends.
The Basis for Our Decision Byletter dated August 9, 2011, youpetitionedthe Federal Aviation Administration (FAA) on behalfofPHI, Inc. (PHI), for an exemption from§§ 91.411(b) and 91.413(c) ofTitle 14, Code ofFederal Regulations (14 CFR). That exemption, ifgranted, would allow PHIto perform air traffic control (ATC) transponder tests and inspections and altimeter system and altimeter reporting equipmenttests and inspections for its part 119 aircraft maintained. 

### w.1der a continuous airworthiness maintenanceprogram (CAMP). The exemptionwould also allow PHIto perform similartests and inspections on its part 135 aircraftmaintained under an approved aircraft inspectionprogram (AAIP).
The FAAhas determined that good cause exists for notpublishing a summaryofthe petition inthe Federal Register. Therequested exemption would not set a precedent, and any delayin acting onthis petitionwouldbe detrimental to PHI.
TheFAAhas issued a grant ofexemption in circumstances similarin all material respects to thosepresented in yourpetition. In Grant ofExemptionNo. 7770 (copy enclosed), the FAA

AFS-11-430-E

### found thereasons statedbythe FAAfor granting the enclosed exemption also apply to the situation youpresent. 2



### InExemption No. 7770, the FAA acknowledged the regulations from whichthe petitioner sought reliefwere writtenwell before the FAA envisioned a company operating aircraftunder part 135 whose part 135 fleet consists ofaircraft with 9 orfewer passenger seats and aircraft with 10 or more passenger seats. Withthis type offleet, the petitioner's own employees maintain its part 135 aircraft with 10 or more passenger seats, butthe petitioner is required to send itspart 135 aircraftwith 9 or fewerpassenger seats to a part 145 certificated repair station for certain maintenance. We found thepetitioner's mechanics to be more familiar with the aircraft upon whichthe required testing wouldbeperformedthan are the mechanics at a part 145 certificatedrepair station. PHI's situation is similar inthat some ofits aircraft are maintained under a CAMP while others are maintainedunder anAAIP. Because PHI operates its entire fleet underpart 135, itwould conduct the tests and inspections required by §§ 91.411(b) and 91.413(c) underthe more comprehensive maintenance requirements ofa CAMP, in a manner similarto the reliefgranted to PenAir inExemptionNo. 7770. Having reviewed yourreasons for requesting an exemption, I find that- • they are similar in all material respects to reliefpreviouslyrequested inthe enclosed Grant ofExemptionNo. 7770; • the reasons stated bythe FAAfor granting the enclosed Grant ofExemptionNo. 7770 also apply to the situationyoupresent; and • a grant ofexemptionis inthepublic interest.
OurDecision Under the authority contained in49 U.S.C. 40113 and 44701, whichthe FAAAdministrator has delegatedto me, I hereby grant PHI, Inc., an exemption from 14 CFR §§ 91.411(b) and 91.413(c) to the extent necessary to allow PHI to perform ATC transponder tests and inspections and altimeter system and altimeterreporting equipmenttests and inspections for its part 119 aircraft maintainedunder a CAMP. PHI is also granted reliefto perform similar tests and inspections onits part 135 aircraft maintained under anAAIP. This exemption is subject to the conditions and limitations describedbelow.
Conditions and Limitations 1. 

### All ATC transponder tests and inspections and all altimeterreporting equipment tests and inspections mustbe conducted under PHI'spart 119 CAMP.
2. All tests and inspections mustberecorded inthe aircraft's maintenance logbythe personperforming each inspection andtest. This entry mustidentifytheperson, the date, andthis exemption number.

### 3. An appropriate record ofthese tests and inspections also mustbekept in PHI's maintenance recording system for part 119 and part 135.
This exemptionterminates on October 31, 2013, unless sooner superseded or rescinded. Sincerely,

# ~~ David 

## c. Gilliom Acting Deputy Director, Flight Standards Service
Enclosure 

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### a.oL:JI;:, · ..

## ,mil General Authority ofCivil Aviation Safety & 

### Economic Regulation

Captain Paul Perkins c/o PHI, Inc. 

### P.0. Box 90808 Lafayette, LA 70509 USA

Dear Capt. Perkins
The General Authority ofCivil Aviation ofthe Kingdom ofSaudi Arabia (GACA) offers no objection to PHI, Inc, Holder ofU.S.FAA Air Carrier Certificate HEEA, operating U.S. or Saudi Arabian registered aircraft withinthe Kingdom ofSaudi Arabia listed on PHI's U.S. Air Carrier Certificate until such time as a Saudi Arabia Air CanierCertificate (AOC) is issued to the Saudi Red Crescent Authority (SRCA). This interim authorization ispredicated on PHI operating for a single customer (SRCA), withintheKingdom ofSaudi Arabia, under Saudi Arabia Part 91 mles and regulations. During this period; PHI will operate and maintain its aircraft in accordance with U.S. FAA Part 135 rules and regulations in addition to GACA Pati 91 requirements.
Sincerely,



### .**~~~c----**



# f1...--- 'N Capt Mohammad Ali Jamjoom VP Safety &Economic Regulations

Date: Attach: No.: Saudi Arabia- P.O. Box 887 Jeddah, 21421