From: Theodore Denzler <Theodore.Denzler@Halliburton.com>

To: Daniel Jacquet/ANM/FAA@FAA Cc: Joseph Fletchall <Joseph.Fletchall@Halliburton.com>

Date: 04/05/2012 07:08 AM Subject: Halliburton Petition for Exemption

Mr. Jacquet,

I was asked to respond to the additional questions you have regarding the petition for exemption,

dated March 8, 2012, Joseph Fletchall, Halliburton Energy Serv ices submitted to you. The requested additional information is as follows;

1).Title 14 Code of Federal Regulations (CFR) 11.81(d) requires you provide the reasons why granting your request would be in the public intere st; that is, how would it benefit the public as a

whole.

Being an energy services company, we always lo ok for ways to reduce our costs however large or small. The elimination of the required emer gency evacuation crewmember will reduce our operating costs. The cost s associated with that crewmember include, but are not limited to, lodging, meals, uniforms, salary and also travel ex penses for business trips as well as training. In the situation where we use company personnel to fill the role of the evacuation crewmember, we lose the use of that person in their full time capacity thus requiring overtime paid to other employees or the temporary use of contract labor to fill the void. Any reduction in our operating

costs reduces the cost of our services which will benefit the public as a whole no matter how great or small.

2). 14 CFR 11.81(h) requires you state the reason why you want to exercise the privilege of the exemption outside the Un ited States, if granted.

As stated in our original petition, “Due to t he nature of our business, we occasionally have additional passengers added to a flight just prio r to departure. Since we are a global operating company, we do not always have the option to add an emergency evacuation crewmember. This inability is due to the lack of availability of such a crewmember in the location we may be or due to the time constraints involved. This would pr event us from using our aircraft to its maximum potential. (This is also one reason we are aski ng for a full exemption from the requirement for domestic and international operations)”. The second to the last paragraph of the petition states “The Halliburton Energy Services flight departm ent is requesting a full exemption from the requirements...” and also states “Description of compensating design features or alternative standards which allow the granting of the ELOS...” Please specify if Halliburton wishes to obtain an exemption or an ELOS.

We are asking for an exemption from th e G550 OPERATING MANUAL SUPPLEMENT G550- OMS-1 which requires the use of, and specifies the training for, the Emergency Evacuation

Crewmember.

The second to the last paragraph states, “To summar ize: The Halliburton Energy Services flight department is requesting a full exemption from the requirements of an “Emergency Evacuation Crew member” as required by FAR 25.807(a)(3); 25.807(g)(2) and (3) and 25.807(i)(2), Emergency Exits and FAR 25.807 at Amendment 25- 98.” Please specify if Halliburton is requesting an exemption from 14 CFR 25.807 in it ’s entirety or 14 CFR 25.807(a)(3), 25.807(g)(2) and (3) and 25.807(i)(2) only. Also please note an exemption to the regulations noted above will not eliminate the requirement to have an Emer gency Evacuation Crewmember required via an

ELOS.The regulations noted in the petition were thos e used for the basis of the original ELOS. Emergency Exits and FAR 25.807 at Amendment 25- 98. Description of compensating design

features or alternative standards which allow the granting of the ELOS (including design changes, limitations or equipment needed for equivalency.

FAA Approved Gulfstream Document GVSP- GER-6111 mandated G550 -OMS-1 and thus the Emergency Evacuation Crewmember. We are asking for an exemption from the G550 Operating Manual, Supplement G550-OMS-1.

The last paragraph refers to Gulfstream G500 a nd G550 airplanes. Please identify these aircraft using the model designation from the Type design Data Sheet.

Type Certificate Data sheet A12EA, The Lat est Revision is 32 Dated June 16, 2009 and incorporates the following aircraft: Gulfstr eam G-1159, G-1159A, G- 1159B, G-IV, GV, GV-SP

AND GIV-X.

Aircraft Service Change (ASC) 11, “G550 Modificati on” will designate those aircraft as Model GVSP (G550). Those aircraft shall be operated under Airplane Flight Manual GAC-AC-G550-OPS001. Applicable to S/N 5001 and subsequent.

Aircraft Service Change (ASC) 10, “G500 Modificati on” will designate those aircraft as Model GVSP (G500). Those aircraft shall be operated under Airplane Flight Manual GAC-AC-G500-OPS001. Applicable to S/N 5001 and subsequent.

Model GV-SP (GV-SP): Production Certificate No . 7SO (issued September 1, 1978 and reissued August 14, 2003), S/N 5001 and subsequent.

Thank You for your time regarding this matter. Pleas e contact us if we can be of any further help.

Sincerely, on behalf of Mr. Fletchall, Chief Pilot,

Ted Denzler Halliburton Aviation Dept.

Mobile +1 832 248 9647

Office +1 281 871 3521

Fax +1 281 871 3510