March 18, 2013 £J n ::.·.n 2 s 1-) 2: 1 o 

Docket Management FacWty 

US Departmellt of Transportation 

1200 New Jersey Avenue 

SE West Building Ground Floor Room Wl2 .. 140 

Washington, DC 20590 · 

Subject: Petition for Exemption from § 91.9(a) of Title 14, Code of Federal Regulations. 

Dear Sir: 

I am petitioning the Federal Aviation Administration (FAA) on behalf of Bristow U.S. LLC for 

an exemption from § 9t.9(a) of Tide 14, Code of Fedetal Regulations (14 CFR). The requested 

exemption, if granted, would allow Bristow U.S. LLC to operate Sikorsky s .. 92A (S·92A) 

helicopters with limited exposure to engiae failure during takeoff and 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 relief from Section 91.9(a). Section 91.9(a) prescribes, in part. 

that no person may operate a civil aircraft without complying 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 under Part 29, amendment 47, 

which relates to safety and ditching equipment wbkh provides the highest level of safety today. 

The S·92As are equipped with aircraft floatation gear and ate certified for ditching in up 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 limited exposure 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 if this 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 of safety that is 

currently in place for our offshore operations. Under current Bristow U.S. LLC usage of the 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 of an engine 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 takeoff or landing. · · 

! 

Bristow U.S. LLC bas instituted operational controls through its general operations manual, ·· 

training program, and maintenance surveillance. Bristow U.S. LLC will conduct opeiations in 

such a manner as to minimize the time spent exposed to engine failure. This will be 

accomplished by following the manufacturer• s recommended &akeoft' and laadillg procedures 

whenever feasible. Operations will not be conducted unless the cment aircraft 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 exposure by: (I) Conducting Oigbt operations to and 

from helidecks and shore based heliports that meet« exceed size and weight requirements 

appropriate to the aircraft configuration; (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 tllght profiles 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 of operational experience in this make and model. 

Meanwhile, Bristow Group, worldwide, has accumulated over 165,900 hours in the S-92A. AU 

of our U.S. based operations that use the S.92A aircraft operate them in accordance with HlOO 

and Performance Class 2 profdes. Worldwide, they operate them to Performance Class 2 

standards. This experience demonstrates that when takeoff and landing techniques are used to 

minimize exposure to forced landing due to engine failure, that this aircraft can be operated at an 

equivalent level of safety to Category A. Additionally, without the exemption relief, because of 

the removal of OpSpec 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 of safety and not serve the most 

important stakeholder, the passenger. 
Bristow U.S. LLC believes that granting of this petition would be in the public interest because 

the S·92A aircraft have replaced older designs which do not offer the same safety enhaacements, 

and those aircraft are not requiml to meet dte stringent performance requirements imposed on 

the S·92A and other similar aircraft. 

In closing, another United States helicopter operator, who uses the S-92A. petitioned and was 

granted an exemption (No. 10507) to OpSpec HlOO. Both of our oompanies 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 takeoff from 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 of further assistance in dtis matter or if you require additioual information. please do 

not hesitate to contact me or the Bristow U.S. U.C office located in New Iberia, Louisiana. My 

email is robert.old@bristowgroup.com. 

Sincerely, 

2~0¥ Robert Q. Old, Jr, 

Chief Pilot 

cc: Robert Phillips