December 11, 2014

Docket Management Facility US Department of Transportation 1200 NewJerseyAvenue '1**c~** f'" L
Kevin M.Tauzier DirectorofOperations

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 Operationsfor an exemption from 

### § 91.9(a) of Title 14, Code of Federal Regulations (14 CFR). The requested exemption, if granted, would allow us to operateAugusta AW139 helicopters with limited exposureto enginefailure during takeoff and landing between land-based and offshore facilities orwhen operating between two offshorefacilities, day, night, visual flight rules, and instrumentflight rules. Specifically, we are requesting relief from Section 91.9(a). Section 91.9(a) prescribes, in part, that no person mayoperate a civil aircraftwithout complying with the operating limitations specified in the approved Rotorcraft Flight Manual.
This request for exemption is for operations conducted in ourAugustaAW139 aircraftwhen operating between land-based and offshorefacilities orwhen operating between two offshore facilities.
Chevron Aircraft OperationsAugusta AW139 helicopterswere certified under Part 29, amendment 47, which relates to safety and ditching equipmentwhich provides the highest level of safetytoday. TheAW139's are equipped with aircraftfloatation gearand are certified for ditching in up to sea state 6. Additionally, when operating overwater, each AW139 occupant is provided, and wears, personal flotation equipment. Also, the AW139 is equipped with life rafts that can be deployedfrom inside oroutside 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 operationswith limited exposure to engine failure.We believe thatthe requested exemption will continue to provide the same level of safetythat is currently in placefor our offshore operations.
Chevron Aircraft Operations will further mitigate exposure by: (1) Conducting flight operations to and from helidecks and shore based heliportsthat 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 unlessthe current aircraftweight, altitude and temperature, as provided in the AW139 Rotorcraft Flight manual, ensure the abilityto climb 150feet per minute at 1,000 feet above the takeoffsurfacewith one engine inoperative and the remaining engine at maximum continuous one engine inoperative (OEI) power. Chevron Aircraft Operations will complywith, in addition to other routine preflight computations, the procedures cited in the AW139 Rotorcraft Flight Manual, Part2, Section IX Supplemental Performance Information, page 9-77 and 9-78, Supplement 12 CATA Operations partE and I contained in the paragraphs titled "Offshore HelideckTake-Off and Landing Procedures", Supplement 12 partA contained in the paragraphs titled "Ground Level and Elevated Heliport/HelideckVertical Take-Off Procedures", and Supplement50 Increased GrossWeight 6800kg.
Chevron Aircraft Operations will onlyfly the AW139 with two qualified pilots that are current in operation ofthe AW139.
Chevron's Aircraft Operations has an approved training program and includes provisionsfor training of appropriate crews on the profiles associated with a Performance Class 2 paragraph C and D including performance planning. Chevron Aircraft Operationswill documentthe conduct and completion of thattraining forthe 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 informedthatthe FAAwill not issue Ops Spec H100. To date Chevron Aircraft Operations established in the 1940's, operatesfrom land to offshore platform helidecks using several different model aircraft. Chevron Aircraft Operations currently holds Air Carrier Certificate AC2A685Kfor Part 135 Operations, Repair Station Certificate AC2R685K and also operates part 91 General Flight Rules. Chevron Aircraft Operation can provide engine datafor the AW139. Chevron Aircraft Operations has operated ten AW139'sfor 9years from land to offshore helidecks and has accumulated over 40,000 safe AW139 flight hours.Experience demonstratesthat when takeoffand landing techniques are used to minimize exposure to forced landing due to engine failure, thatthis aircraft can be operated at an equivalent level of safety to Category

### A. Additionally, without the exemption relief, because Ops Spec H100 is no longer issued, it would become economically unfeasibleto operatethis aircraft which would likely result in their removal from service. Withoutthe exemption relief, we would have to offerto our passenger's smaller, older, less sophisticated aircraftthat do not provide the same level of safety. This would result in an overall degradation of safetyand not serve the most importantstakeholder, the passenger. Chevron Aircraft Operations believesthat granting ofthis petition would be in the public interest because the AW139 aircraft have replaced older designswhich do not offerthe same safety enhancements, and those aircraft are not required to meetthe stringent performance requirements imposed on the AW139 and othersimilar aircraft.
In closing, Chevron Aircraft Operations, uses and operates the Sikorsky S-92A, which we petitioned and was granted exemption (No.10895). Chevron Aircraft Operationswill also operate ourAW139 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 takeofffrom the same or like locations. The AW139 pilots will train atthe same FFS (Full Flight Simulator) facility and byall accounts, have the exact level of operational experience.
If I may be offurther assistance in this matter or. ifyou require additional information, please do not hesitateto contact me orthe 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 hesitateto call.

Director of Operations Chevron Aircraft GOMBU Tel 601-749-4022 Cell 601-569-0428