### Chevron 

# Ill

Chevron USA

September 1, 2015 Docket Management Facility US Department ofTransporta t ion 1 200 New Jersey Avenue 96 Runway Road Picayune, MS 39466

SE Wes t Building Ground Floor Room W1 2-140 Washington, DC 20590 Subject: Petition for Renewal of E xemption #10895 Chevron Aircraft Operations is requesting renewal of Exemption #10895 from the Federal Aviation Administration (FAA) concerning §91.9(a) ofTitle 14, Code of Federal Regulations (14CFR)

. The requested exemption, if renewed, would allow Chevron USA to operate Sikorsky S
-92A (S
-92A) helicopterswith limited exposure to engine failure during takeoff and landing while carrying up to 19 passengers between land-based and offshore facilities orwhen operating between two offshore facilities, day, night, visual flight rules, and instrument flight rules

. Specifically, we are requesting relieffrom 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 renewal ofthe exemption is for operations conducted in our Sikorsky S-92A aircraft when operating between land-based and offshore facilitiesor when operating between two offshore facilities.Chevron USA's Sikorsky S-92A helicopters were certified under Part 29, amendment 47, which relates to safety and ditching equipment which provides the highest level of safety today. The S-92A's are equipped with aircraft floatation gear and are certified for ditching in up to sea state 5. Additionally, when operating over water, each S-92A occupant is provided, and wears, personal floatation equipment. Also, the S-92A is equipped with life rafts that can be deployed from inside or outside the aircraft. European operators, using the same aircraft, operate the S-92A in accordance with Joint Aviation Requirement-OPS-3 which already permits similar operations with limited exposure to engine failure. We have operated our Sikorsky S-92A aircraft under this exemption since 2013. We believe thatthe request to renew the exemption will allow us to continue to provide the same level ofsafetythat is currently in place for our offshore operations. Under current Chevron USA usage ofthe S-92A aircraft, we have collected data related to the engine reliability and it shows that we have never had an inflight shutdown of an engine in 4,726 hours operated. Chevron USA has operated under this exemption in the United States since 2013 which authorized operations similar to International Civil Aviation Organization (ICAO) Performance Class 2 with limited exposure. During this period, no S-92A accidents have been caused by power loss due to engine failure duringtakeoffor landing. Chevron USA will further mitigate exposure by: (1) Conducting flight operationsto 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, ensuringthe 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 operation; and (4) Using Chevron's Helicopter Flight Data Monitoring program to ensure flight profiles are in accordance with Performance Class 2 procedure.Chevron USA has been informed that the FAA will rescind OpSpec HlOO. To date, Chevron USA has accumulated over 4,726 hours ofoperational experience in this make and model. Meanwhile, Chevron Inc, worldwide, has accumulated over 262,909 hours in the S-92A. All of our U.S. based operations that use the S-92A aircraft operate them in accordance with HlOO standards

. This experience demonstrates that when takeoff and landing techniques are used to minimize exposure to forced landing due to define failure, that this aircraft can be operated at an equivalent level of safety to Category A. Additionally, without the exemption relief, because ofthe removal of OpSpec HlOO 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 offerto our customer's smaller, older, less sophisticated aircraftthat do not provide the same level of safety. This would result in an overall degradation ofsafety and not serve the most important stakeholder, the passenger. Chevron USA believes that granting ofthis petition would be in the public interest because the S-92A aircraft have replaced older designs which do not offerthe same safety enhancements, and those aircraft are not required to meetthe stringent performance requirements imposed on the S-92A and other similar aircraft.
In closing, another United States helicopter operator, who uses the S-92A, petitioned and was granted an exemption (No. 10895) to OpSpec HlOO. Both ofour companies S92A aircraft operate daily in the same environment, flying the same missions and flight profiles. We service the same customers in some cases, and land and takeofffrom the same or like locations. We train at the same FFS (Full Flight Simulator) facility and by all accounts, have the exact level ofexperience with the S-92A aircraft based on ourfleet size. If I may be offurther assistance in this matter or ifyou require additional information, please do not hesitate to contact me orthe Chevron USA office located in Picayune, MS. My email is rsqy@chevron

.com
.

Rick Sloan Chief Pilot Cc: Kevin Tauzier