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Bristow Alaska Inc. A part 135 helicopter operator based in Fairbanks Alaska would like to ask for an 

exemption to the federal aviation regulations part 43,3(g) and 43.3(h)(l ). This exemption is similar to an 

already existing exemption (8697). ·-.-.,. 1 

.•. 

FAR 11.81 Requirements 

(a) Your name and mailing address and, ifyou wish, other contact information such as a fax 

number, telephone number, or e-mail address; 

Jeff J. Ryhti 

Director of Maintenance 

Bristow Alaska Inc. 

1915 Donald Ave. 

Fairbanks, Ak 997012 

907 452-1197 voice 

907 452-4539 fax 

907 378-7777 cell 

jeffery .ryhti @bristowgroup.com 

(b) The specific section or sections of 14 CFR from which you seek an exemption; 

FAR 43.3(g) and 43.3(h)(l) 

(c) The extent of relief you seek, and the reason yotf.:seek the relief; 

Bristow Alaska's would like to be exempt from all of FAR 43.3(g) and 43.3(h)(l) 

Our request is to allow a pilot to remove and install batteries to prevent the battery from freezing in cold 

temperatures. We would also like to request that a pilot be allowed to remove and install pilot and 

passenger doors to facilitate external load operations. 

d) The reasons why granting your request would be in the public interest; that is, how it would 

benefit the public as a whole; 

It is not practical to have a mechanic fly with the aircraft to a location to perform the maintenance 

function of removing and installing the doors for the helicopter to perform the external load operation or 

removing and installing the battery to prevent the freezing of the battery. This adds unnecessary cost to 

the customers and Jowers the performance of the aircraft which in some cases prevents the job from being 

completed. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from which you 

seek the exemption; 

As a Part 135 helicopter operator working in a remott''area the maintenance actions of removing and 

replacing a battery can already be performed by a pilot'under FAR part 43.3(h) provided it is a result of 

mechanical difficulty. Bristow believes the opportunity to make a mistake would be higher when 

attempting to fix an aircraft with a discrepancy rathe11than preventing the discrepancy to begin with. 

Bristow Alaska, Inc. 1915 Donald Avenue, Fairbanks, Alaska 99701, United States 

t (907) 452 1197 f (907) 452 4539 www.bristowgroup.com 
., 

' 

Bristow Alaska also believes it is safer in certain applications to remove a door for increased visibility 

while performing external load operations. Both of these maintenance functions can be performed by 

elementary means and are not complicated in nature. Bristow Alaska will have a FAA approved training 

program addressing task accomplishment and required documentation for all the maintenance items pilots 

are approved to perform. 

(t) A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

Bristow Alaska Inc. would like the exemption for FAR 43.3(g) and 43.3(h)(l) 

Our request is to allow a pilot to remove and install batteries to prevent the battery from freezing in cold 

temperatures. We would also like to request that a pilot in a remote area be allowed to remove and install 

pilot and passenger doors as many jobs require the aircraft to fly to a location remove the door for 

external load operations and then install the door and return back to its home base. The maintenance 

functions mentioned above can be performed by elementary means and are not complicated in nature and 

are allowed to be performed by a pilot if due to a mechanical malfunction. 

(g) Any additional information, views or arguments available to support your request; and 

(h) If you want to exercise the privileges ofyour exemption outside the United States, the reason 

why you need to do so. 

In the remote artie conditions we operate in it is not practical to have maintenance personnel on board 

with the aircraft at all times. Likewise it would not be safe to leave maintenance at a remote location 

while the aircraft is performing its mission. This exemption would be on Bell 206 series, Bell 407 and 

Eurocopter B0105 helicopters only operated under Part 135 AAIP maintenance program. 

/#/~ Jeff J. Ryhti 

Director of Maintenance 

Bristow Alaska Inc. 

1915 Donald Ave. 

Fairbanks, Ak 997012 

907 452-1197 voice 

907 452-4539 fax 

907 378-7777 cell