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 Services 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 interest; that is, how would it benefit the public as a 

whole. 

Being an energy services company, we always look for ways to reduce our costs however large 

or small. The elimination of the required emergency evacuation crewmember will reduce our 

operating costs. The costs associated with that crewmember include, but are not limited to, 

lodging, meals, uniforms, salary and also travel expenses 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 United States, if granted. 

As stated in our original petition, “Due to the nature of our business, we occasionally have 

additional passengers added to a flight just prior 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 prevent us from using our aircraft to its maximum 

potential. (This is also one reason we are asking 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 department 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 the 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 summarize: 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 Emergency Evacuation Crewmember required via an 

ELOS. 
The regulations noted in the petition were those 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 and G550 airplanes. Please identify these aircraft 

using the model designation from the Type design Data Sheet. 

Type Certificate Data sheet A12EA, The Latest Revision is 32 Dated June 16, 2009 and 

incorporates the following aircraft: Gulfstream G-1159, G-1159A, G-1159B, G-IV, GV, GV-SP 

AND GIV-X. 

Aircraft Service Change (ASC) 11, “G550 Modification” 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 Modification” 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. Please 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