March 18, 2013 

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# o Docket ManagementFacWty US Departmellt ofTransportation 1200 New Jersey Avenue 

### SE West 

### Building Ground FloorRoom Wl2

..140 Washington, DC 20590 · Subject: Petition for Exemption from § 91.9(a) ofTitle 14, Code ofFederal Regulations.
Dear Sir:
I am petitioning the Federal Aviation Administration (FAA) on behalfofBristow U.S. LLC for an exemption from § 9t.9(a) ofTide 14, Code of

### Fedetal Regulations (14 CFR). 

### The requested exemption, ifgranted, would allow Bristow U.S. LLC to operate Sikorsky 

# s
..92A (S·92A) helicopters with limited exposure toengiae failure during takeoffand lancling 

### wmle carrying up to 19 passengers between land-based and offshore fadlities or when operating between two · offshore facilities, 

### day, night, visual flight rules, and instrument flight roles. Specifically, we are requesting relieffrom Section 91.9(a). Section 91.9(a) prescribes, in part. that no person may operate a civil aircraft withoutcomplying with the operating limitations· specified in the approved Rotorcraft Flight 

### Manual.
This request for exemption is for operations conducted in our Sikorsky 

### S..92A aircraft when· operating between land

..based and offshore facilities or when operating 

### between two offshore facilities. ' · '



### ., . ..

## .
.**~** Bristow U.S. LLC's Sikorsky 5-92A helicopters were certified underPart 29, amendment47, which relates to safety and ditching equipment wbkhprovides the highest level ofsafety today. The S·92As are equipped with aircraftfloatation gear and atecertified for ditching inup to

### sea· state 4. Additionally, when operating over water, each S-92A**~tis**provided, and wears. personal flotation equipment Also* the S-92A is equipped with life rafts that cad be deployed from inside or outside the aircraft.

.. , 1 • • • 1 ' · European operators, using the same aircraft, operate tbe S·92A in accordanCe 

### with Joint Aviation Requirernent-OPS-3 which already permits similar operations with limitedexposure to engine failure. We have operated our U.S. based S-92A aircraft under operations specification. (OpSpec) H-100 since 2008. We are also requesting that ifthis exemption is granted, that the exemption extends to our certificate operations conducted outside the United States when applicable. ' · We believe that the requested exemption will continue**~o** provide the same level ofsafety that is currently in place for our offshore operations. Undercurrent Bristow U.S. LLC usage ofthe S.

Bristow U.S. LLC. 4605 Industrial Drive, New Iberia, loolalana 70560, United States t (337) 365 an1 t (337) 359 3108 bristowgroup.com

# , ' •

.



### 92A aircraft, 

### we have collected data 

### related to the 

### engine reliability and it 

### shows that 

### we have' never had 

### an intlight 

### shutdown ofanengine in 6J()O hours 

### operated.
Bristow 

### U.S. LLC has operated under OpSpec 

### HlOO in the 

### United States since 2008 which 

### authorized operations similar to International Civil Aviation 

### Organization (ICAO) 

### Performance Class 2 with 

### limited exposure; 

### During this**period~** 

### no S-92A accidents have 

### been caused by power loss due to engine failure during 

### takeoffor landing. · ·

! Bristow 

### U.S. LLC bas instituted operational controls through its 

### general operations manual, ·· training program, and maintenance 

### surveillance. Bristow 

### U.S. LLC will 

### conductopeiations in such a manner 

### as to 

### minimize the 

### time spent exposed to

### engine failure. This will be accomplished by following the 

### manufacturer•srecommended &akeoft' and laadillg procedures whenever feasible. 

### Operations will 

### not be conducted 

### unless the 

### cmentaircraft weight, altitude, and temperature ensure 

### 100 feet 

### per minute rate of

### climb at 

### 1,000 feet 

### above the takeoff

### surfaCe with one engine inoperative and 

### the remaining engine at 

### maximum continuous one 

### engine inoperative (OEI) power. Bristow U.S. 

### LLC will further mitigate exposureby: (I)Conducting 

### Oigbtoperations to 

### and from helidecks and shore 

### based heliports that 

### meet«exceed size and weight

### requirements appropriate to the 

### aircraftconfiguration; 

### (2) Training its

### crews in a Level 

### D. FFS (Full Flight Simulator) initially and annually, ensuring the 

### highest levels of

### proficiency and competency; (3) Conducting route checks to confmn that its crews remain procedurally compliant and use 

### crew resource management principles during all tligbt operations; 

### and (4) Using Bristow U.S. 

### LLC's Helicopter Flight Data Monitoring program (known as HfDM) to ensure tllghtprofiles are in accordance with Performance Class 2 procedures. Bristow U.S. 

### LLC has been infonned that tbe FAA 

### wiD rescimJ OpSpee 

### HlOO. To date, Bristow U.S. LLC has accumulated over 6,500 hours ofoperational experience in this make and model. Meanwhile, Bristow Group, worldwide, has accumulated over 165,900 hours inthe S-92A. AU ofour U.S. based operations that use the S.92A aircraft operate them in accordance with HlOO and Performance Class 2profdes. Worldwide, they operate them to Performance Class 2 standards. This experience demonstrates that when takeoffand landing techniques are used to minimize exposure to forced landing due to 

### engine failure, that

### this aircraftcan be operated at

### an equivalent level of safety to Category A. Additionally, without the exemption 

### relief, because of the removal ofOpSpec HlOO it would become economically unfeasible to operate this aircraft which would likely result in their removal from service. Without the exemption relief, we would have to offer to our clients smaller, older, less sophisticated aircraft that do not provide the same level of safety. This would result in an overall degradation ofsafety and not serve the most important stakeholder, the passenger.

### Bristow U.S. LLC believes that 

### granting of

### this petition would be 

### in the 

### public interestbecause the S·92A aircraft have replaced older designs which do notofferthe same 

### safety enhaacements, and 

### those aircraft are not

### requiml tomeet dte stringentperformance requirements imposed on the S·92A and other similar aircraft.
In 

### closing, another United States helicopteroperator, who uses the 

### S-92A. petitioned 

### and 

### was granted 

### an exemption (No. 10507) to

### OpSpec HlOO. Both ofouroompanies S-92A aircraft 

### operate daily 

### in the 

### same environment, flying the same missions and flight 

### profiles. We service the same clients in some cases, and 

### land and takeofffrom 

### the same or like 

### locations. We train at 

### the same FFS (Full Flight 

### Simulator) facility and by all 

### accounts, have the 

### exact level of experience with the 

### S-92A aira'aft

### based on our fleet 

### size.
If

### I may be 

### offurther 

### assistance in

### dtis matteror if

### you 

### require additioual information. please do 

### not hesitate tocontact me 

### orthe Bristow U.S. U.Coffice 

### located in New Iberia, 

### Louisiana. 

### My email is robert.old@bristowgroup.com. Sincerely,

# 2~0¥ Robert Q. Old, Jr, 

### ChiefPilot

cc: Robert Phillips