December 11, 2014 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue 

'1 c~ f'" 

L 

Kevin M. Tauzier 

Director of Operations 

SE West Building Ground Floor Room W12-140 

Washington, DC 20590 

Chevron Aviation GOMBU 

96 Runway Road 

Picayune, MS 39466 

601-749-4022 

KTauzier@ chevron.com 

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 Chevron Aircraft 

Operations for an exemption from § 91.9(a) of Title 14, Code of Federal Regulations (14 CFR). 

The requested exemption, if granted, would allow us to operate Augusta AW139 helicopters 

with limited exposure to engine failure during takeoff and landing between land-based and 

offshore facilities or when operating between two offshore facilities, day, night, visual flight rules, 

and instrument flight rules. 

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 Augusta AW139 aircraft when 

operating between land-based and offshore facilities or when operating between two offshore 

facilities. 

Chevron Aircraft Operations Augusta AW139 helicopters were certified under Part 29, 

amendment 47, which relates to safety and ditching equipment which provides the highest level 

of safety today. The AW139's are equipped with aircraft floatation gear and are certified for 

ditching in up to sea state 6. Additionally, when operating over water, each AW139 occupant is 

provided, and wears, personal flotation equipment. Also, the AW139 is equipped with life rafts 

that can be deployed from inside or outside the aircraft and has 406 MHZ deployable beacon. 

European operators, using the same aircraft, operate the AW139 in accordance with Joint 

Aviation Requirement-OPS-3 which already permits similar operations with limited exposure to 

engine failure. 
We believe that the requested exemption will continue to provide the same level of safety that is 

currently in place for our offshore operations. 

Chevron Aircraft Operations will further mitigate exposure by: (1) Conducting flight operations to 

and from helidecks and shore based heliports that meet or 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 confirm that its crews remain procedurally 

compliant and use crew resource management principles during all flight operations; and (4) 

Using Chevron Aircraft Operations Helicopter Flight Data Monitoring program to ensure flight 

profiles are in accordance with Performance Class 2 procedures. 

Operations will not be conducted unless the current aircraft weight, altitude and temperature, as 

provided in the AW139 Rotorcraft Flight manual, ensure the ability to climb 150 feet per minute 

at 1 ,000 feet above the takeoff surface with one engine inoperative and the remaining engine at 

maximum continuous one engine inoperative (OEI) power. 

Chevron Aircraft Operations will comply with, in addition to other routine preflight computations, 

the procedures cited in the AW139 Rotorcraft Flight Manual, Part 2, Section IX Supplemental 

Performance Information, page 9-77 and 9-78, Supplement 12 CAT A Operations partE and I 

contained in the paragraphs titled "Offshore Helideck Take-Off and Landing Procedures", 

Supplement 12 part A contained in the paragraphs titled "Ground Level and Elevated 

Heliport/Helideck Vertical Take-Off Procedures", and Supplement 50 Increased Gross Weight 

6800kg. 

Chevron Aircraft Operations will only fly the AW139 with two qualified pilots that are current in 

operation of the AW139. 

Chevron's Aircraft Operations has an approved training program and includes provisions for 

training of appropriate crews on the profiles associated with a Performance Class 2 paragraph 

C and D including performance planning. Chevron Aircraft Operations will document the 

conduct and completion of that training for the appropriate flight crewmembers. 

Proficiency in the use of the profiles described in the condition and the limitation as mentioned 

above must be demonstrated satisfactorily during recurrent evaluations required by §61.56 or 

61.58. 

Chevron Aircraft Operations has been informed that the FAA will not issue Ops Spec H1 00. To 

date Chevron Aircraft Operations established in the 1940's, operates from land to offshore 

platform helidecks using several different model aircraft. Chevron Aircraft Operations currently 

holds Air Carrier Certificate AC2A685K for Part 135 Operations, Repair Station Certificate 

AC2R685K and also operates part 91 General Flight Rules. Chevron Aircraft Operation can 

provide engine data for the AW139. Chevron Aircraft Operations has operated ten AW139's for 

9 years from land to offshore helidecks and has accumulated over 40,000 safe AW139 flight 

hours. 
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 Ops 

Spec H1 00 is no longer issued, 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 passenger's 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. 

Chevron Aircraft Operations believes that granting of this petition would be in the public interest 

because the AW139 aircraft have replaced older designs which do not offer the same safety 

enhancements, and those aircraft are not required to meet the stringent performance 

requirements imposed on the AW139 and other similar aircraft. 

In closing, Chevron Aircraft Operations, uses and operates the Sikorsky S-92A, which we 

petitioned and was granted exemption (No.1 0895). Chevron Aircraft Operations will also 

operate our AW139 daily, in the same environment, flying the same missions and flight profiles. 

The AW139 will service our passengers in the same environments, and land and takeoff from 

the same or like locations. The AW139 pilots will train at the same FFS (Full Flight Simulator) 

facility and by all accounts, have the exact level of operational experience. 

If I may be of further assistance in this matter or. if you require additional information, please do 

not hesitate to contact me or the Chevron Aircraft Operations Gulf of Mexico Business Unit, 

office located in Picayune Ms. My email is KTauzier@chevron.com. 

If you have any questions regarding this request please don't hesitate to call. 

Director of Operations 

Chevron Aircraft GOMBU 

Tel 601-749-4022 

Cell 601-569-0428