June 25, 2013 

U.S. Department of Transportation 

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 of this 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 

Enclosure 
June 10, 2011 

U.S. Department of Transportation 

Docket Operations, West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

Dear Sir or Madam, 

l¥ti1.Nc 

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 of the 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 of the public as 

a whole. 

As requirement of the CAMP, PHI, Inc. has a full time training staff that trains air carrier 

personnel in the testing and inspection procedures and the use of the 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.com 
U.S. Department 

of Transportation 

L=ederal Aviation 

Administration 

October 24, 2011 

Mr. Jeffrey J. Jenkins 

Chieflnspector, Part 135 

PHI, Inc. 

P.O. Box 90808 

Lafayette, LA 70509 

Dear Mr. Jenkins: 

Exemption No. 10377 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Regulatory Docket No. F AA-2011-0892 

This letter is to inform you that we have granted your request 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 

By letter dated August 9, 2011, you petitioned the Federal Aviation Administration (FAA) on 

behalfofPHI, Inc. (PHI), for an exemption from§§ 91.411(b) and 91.413(c) ofTitle 14, Code 

of Federal Regulations (14 CFR). That exemption, if granted, would allow PHI to perform air 

traffic control (ATC) transponder tests and inspections and altimeter system and altimeter 

reporting equipment tests and inspections for its part 119 aircraft maintained. w.1der a 

continuous airworthiness maintenance program (CAMP). The exemption would also allow 

PHI to perform similar tests and inspections on its part 135 aircraft maintained under an 

approved aircraft inspection program (AAIP). 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register. The requested exemption would not set a precedent, and any delay in 

acting on this petition would be detrimental to PHI. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant ofExemption No. 7770 (copy enclosed), the FAA 

AFS-11-430-E 
found the reasons stated by the FAA for granting the enclosed exemption also apply to the 

situation you present. 

2 

In Exemption No. 7770, the FAA acknowledged the regulations from which the petitioner 

sought relief were written well before the FAA envisioned a company operating aircraft under 

part 13 5 whose part 13 5 fleet consists of aircraft with 9 or fewer passenger seats and aircraft 

with 10 or more passenger seats. With this type of fleet, the petitioner's own employees 

maintain its part 135 aircraft with 10 or more passenger seats, but the petitioner is required to 

send its part 135 aircraft with 9 or fewer passenger seats to a part 145 certificated repair 

station for certain maintenance. We found the petitioner's mechanics to be more familiar with 

the aircraft upon which the required testing would be performed than are the mechanics at a 

part 145 certificated repair station. PHI's situation is similar in that some of its aircraft are 

maintained under a CAMP while others are maintained under an AAIP. Because PHI operates 

its entire fleet under part 135, it would conduct the tests and inspections required by 

§§ 91.411(b) and 91.413(c) under the more comprehensive maintenance requirements of a 

CAMP, in a manner similar to the relief granted to PenAir in Exemption No. 7770. 

Having reviewed your reasons for requesting an exemption, I find that-

• they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 7770; 

• the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 7770 also 

apply to the situation you present; and 

• a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to 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 altimeter reporting equipment tests and inspections for 

its part 119 aircraft maintained under a CAMP. PHI is also granted relief to perform similar 

tests and inspections on its part 13 5 aircraft maintained under an AAIP. This exemption is 

subject to the conditions and limitations described below. 

Conditions and Limitations 

1. All A TC transponder tests and inspections and all altimeter reporting equipment 

tests and inspections must be conducted under PHI's part 119 CAMP. 

2. All tests and inspections must be recorded in the aircraft's maintenance log by the 

person performing each inspection and test. This entry must identify the person, 

the date, and this exemption number. 
3. An appropriate record of these tests and inspections also must be kept in PHI's 

maintenance recording system for part 119 and part 13 5. 

This exemption terminates on October 31, 2013, unless sooner superseded or rescinded. 

Sincerely, 

~~ David c. Gilliom 

Acting Deputy Director, Flight Standards 

Service 

Enclosure 

3 
~.)~"it ~~- ~t, a..~t - • j,J - '..J""""J ~:::la.ll ul~ a.oL:JI;:, · .. ,mil 

Safety & Economic Regulation General Authority of Civil Aviation 

Captain Paul Perkins 

c/o PHI, Inc. 

P .0. Box 90808 

Lafayette, LA 70509 USA 

Dear Capt. Perkins 

The General Authority of Civil Aviation of the Kingdom of Saudi Arabia (GACA) offers no 

objection to PHI, Inc, Holder ofU.S.FAA Air Carrier Certificate HEEA, operating U.S. or Saudi 

Arabian registered aircraft within the Kingdom of Saudi Arabia listed on PHI's U.S. Air Carrier 

Certificate until such time as a Saudi Arabia Air Canier Certificate (AOC) is issued to the Saudi 

Red Crescent Authority (SRCA). This interim authorization is predicated on PHI operating for a 

single customer (SRCA), within the Kingdom of Saudi 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