November 16, 2015 U.S. Department ofTransportation Docket Operations WestBuilding Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590. To Whom ItMay Concern;

# ~AliNe POST OFFICE BOX 90808 LAFAYETTE, LOUISIANA 70509 USA TELEPHONE: 337 235 2452 FACSIMILE: 337 272-4510 Also Filed Electronically

In accordance with CFR 14 11.15 and 11.81, PHI, Inc., requests an exemption from Part 91.9(a) which, inpart, states: Except as provided in paragraph (d) ofthis section, no person may operate a civil aircraft without complying with the operating limitations specified inthe approved Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed bythe certifying authority ofthe country ofregistry. Extent ofReliefSought and Reason for the Relief This petition requests an exemption from the following S-92A Rotorcraft Flight Manual limitation when operating between land-based and offshore facilities or when operating betweentwo offshore facilities. TYPES OF OPERATION Category 'A' with a maximum of 19 passenger seats or Category 'B' with 9 or less passenger seats; Day, Night, VFR and IFR. Specifically, PHI, Inc. requests approval to operate S-92A helicopters with limited exposure to engine failure during takeoffand landing while carrying up to 19 passengers. This Exemption is in the Public Interest The S-92A, and other 1 0+ seatrotorcraft certified to the latest standards (FAR 29 amendment 47) and equipped with state-of-the-art safety systems and technology, routinely transport workers to and from offshore platforms to support the oil and gas industry. Specifically, equipment such as HUMS, HTAWS, ADS-B, TCAS/TAS, FMS, Fault Tolerant Design and other advanced avionics and electronics allow these rotorcraft to offerthe highest level ofsafety available today. These aircraft replaced older designs which do not offerthese advancements, and not required to meet the current performance requirements imposed onthe S-92 and other similar aircraft. The intent ofthis exemption is to provide those workers withthe safesttransportation available, while maintaining an efficient transportation system for the oil and gas industry. For these reasons, this exemption is inthe general public interest.PHI, Inc. Petition for Exemptionto 14CFR 91.9(a) November 16, 2015 Equivalent Level ofSafety The S-92A has operated under Operations Specification HlOO inthe United States, and under JAROPS 3 in other countries, since 2003. Both rules allow for limited exposure to engine failure. The requested exemption will continue to provide the same level ofsafetythat is currently inplace for offshore operations. Duringthe period noted above, no accidents (S-92A or other aircraft inthe same class) have been caused by power loss due to engine failure during takeoffor landing. Ifthis exemption is granted, the S-92A will continue to operate CategoryA withthe exception ofa briefexposure to engine failure during takeoffand landing. The amount oftime the aircraft is exposed to engine failure will depend onmany conditions, butthe maximum exposure would normally be less than 9 seconds pertakeoff/landing. Ifthis exemption is not granted, the S-92A (and other like aircraft) would be forced to severely decrease the number ofpassengers and/or fuel per sortie. Decreased passenger loads will require more sorties to meet demand and effectively increase exposure to hazards unrelated to engine failure. A discussion onthe merits oflimited exposure to engine failure during offshore operations, explaining howthe overall level ofsafety may be enhanced bythe requested exemption, is provided as Attachment A to this petition. Operations Outside ofthe United States: Non-U.S., S-92A operators outside ofthe United States do not require this exemption. JAR-OPS 3, and other equivalent operational rules, already permit operations with limited exposure to engine failure. PHI, Inc., wishes to have this exemption apply to their operations outside the USA for the same reasons stated herein. Mitigation Factors: Inthe unlikely case ofa ditching as a result ofan engine failure during takeoffor landing, the following mitigation is provided:

• The S-92A is equipped with aircraft flotation gear and is certified for ditching inup to sea state 6. • When operating over water, each S-92A occupant is provided, and wears, personal flotation equipment. • The S-92A is equipped with life rafts that can be deployed from inside or outside the aircraft. To qualify for JAR-OPS 3 Performance Class 2 operations (limited exposure to engine failure), Sikorsky Aircraft periodically submits engine reliability reports to show that the in-flight shutdown rate is less than 1per 100,000 flight hours. The most recent report, dated supports continued PC 2 operations.PHI, Inc. Petition for Exemptionto 14CFR91.9(a) November 16, 2015 PHI, Inc., will conduct operations in such a manner as to minimize the time spent exposed to engine failure. This will be accomplished by following the manufacturer's recommendedtakeoffand landing procedures whenever feasible. Operations will notbe conducted unless the current aircraft weight, altitude and temperature ensure a 150 feet per minute climb at 1,000 feet above the takeoffsurface with one engine inoperative and the remaining engine at maximum continuous OEI power. PHI, Inc., further mitigates exposure by;

• Conducting flight operations to and from helidecks and shore based heliports that meet or exceed size and weight requirements appropriate to the aircraft configuration. • Training our crews in a Level D, FFS (Full Flight Simulator) initially and annually, insuring the highest levels ofproficiency and competency. • Conducting route checks to confirm that our crews remainprocedurally compliant and use CRMprinciples during all flight operations. • Using PHI's Flight DataMonitoring Program (known as LAMP) to insure flight profiles are in accordance withPC-2 procedures. Summary PHI, as the launchcustomerfor the S-92, has accumulated over 150,000hours ofoperational experience in this make/model all in accordance with H-100 and Performance Class 2 profiles. This experience demonstrates that whentakeoffand 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 (PC-I). Due to the remote nature of our operations, helideck size and off-airport basing, the viability of full Category A orPerformance Class One (PC1) is impractical. Ifthis requirementwere to be imposed, the S-92 (and its equivalent competitor aircraft) would become economicallyunfeasible which likely would result in their removal from service. The outcome would be a reversion to smaller, older, less sophisticated aircraft that 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. Ifthere are any questions concerning this petition, or to report the disposition ofthis request, please contact me as indicated below.

# ~:;~~~- Paul A. Perkins, Jr.

# ~ ChiefPilot, PHI, Inc. P.O. Box 90808 Lafayette, LA 70509 337.272.4242 Email: pperkins@phihelico.com AttachmentPHI, Inc. Petition for Exemptionto 14CFR91.9(a) November 16, 2015



### INTENTIONALLY BLANKPHI, Inc. Petition for Exemptionto 14CFR91.9(a) November 16, 2015 

### AttachmentA

The Case for Limited Exposure to Engine Failure Sikorsky Aircraft uses a hazard identification/mitigationprocess that identifies the hazards involved in each area ofoperation and then uses different mitigationprocesses to drive the risk down to the lowestpossible level. Inthe rare case where the mitigationprocess for one hazard adversely raises the risk ofa different hazard, the mitigation mustbe applied to the most likely accident scenario. The following discussion examines the offshore takeoffand landing maneuvers, identifies the historical hazards associated withthese maneuvers, and assigns appropriate mitigationprocesses to eachhazard. Offshore elevated helidecktakeoffprocedure.

ELEVATED HELIDECK

TAKEOFF PROFILE WITH SCHEDULED DROPDOWN

NORMAL TAKEOff 

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Figure 1 Published S-92A Elevated Helideck TakeoffProcedure

Attachment A Page 

### 11 of7PHI, Inc. Petition for Exemptionto 14CFR91.9(a) November 16, 2015

Figure 2. Typical Elevated Platform

The no-exposure takeofffrom an offshore elevated helideck (Figure 1) is initiated by adding powerto establish a vertical climb. The takeoffdecisionpoint (TDP) is defined as a height above the takeoffsurface with a corresponding vertical velocity at that height. Forthe S-92A, the TDP for an elevated helideck is 30 feet with a 1,000 fpm climb rate. Ifan engine should fail prior to the TDP, the takeoffis rejected and the aircraft lands back on the helideck. Ifan engine should fail at or after the TDP, the takeoffis continued and the aircraft flies away. When this procedure is flown at the appropriate weight for the given ambient conditions (pressure altitude, temperature and helideck height) the aircraft has no exposure to engine failure.- i.e. an engine can fail at any point inthe procedure and the aircraft can either safely land back onthe helideck or continue the takeoffand fly away onthe remaining engine. There are two primary hazards associated with this maneuver. Takeoffhazard 1: Contact with the platform structure with All Engines Operating (AEO). The takeoffprocedure is very dynamic. The pilot is required to attain a fairly high climb rate in a short period oftime while maintaining position directly overthe helideck. Visual cues for position maintenance are limited under the best ofconditions and quickly degrade inpoorweather or at night. As the aircraft climbs, there is a tendency to drift aft in an attempt to keep the edge ofthe helideck in sight. Ifthe pilot drifts backwards, the aircraft main ortail rotor may contactthe offshore platform structure. Note the proximity ofobstacles inFigure 2. Mitigation: Lower the TDP height and vertical velocity.

Attachment A Page 

### 12 of7PHI, Inc. Petition for Exemptionto 14CFR 91.9(a) November 16, 2015 Decreasing the TDP height to 15 feet allows the pilotto keep the helideck edge in sight and decreases the time spent in close proximityto the rig structure. Decreasing the TDP vertical speed to 500 fpm makes the maneuver less abrupt and easier to fly. Takeoffhazard 2: Engine failure during takeoff. Large transport (19 passengers) helicopters do nothave sufficient power to hover on one engine when at normal takeoffweights. Ifan engine should fail at, or immediately after TDP, the takeoffprocedure described above takes advantage ofvertical velocity energy and the energy gained by dropping down belowthe helideckto attain a safe One Engine Inoperative (OEI) speed (VToss). Ifsufficient energy is not available at the critical point, the aircraft is exposed to hitting the deck edge or ditching inthe water belowthe platform. Mitigation: Increase the TDP height and vertical velocity. A higher TDP height and vertical velocity provides more energy for a subsequent fly away maneuver ifan engine should fail at orimmediately after the TDP. In addition, it should be noted that, as the helicopter weight decreases (lower fuel/payload), the exposure to engine failure decreases due to increased OEI powermargins. Itis clearthat the mitigation factors for each ofthe two hazards are diametrically opposed, the AEO hazard being mitigated by a lower TDP with a slower initial climb rate, and the OEI hazard being mitigated by a higher TDP with a higher initial climb rate. The hazards associated with lowering the takeoffweight are discussed later in this paper.

Attachment A Page 

### 13 of7PHI, Inc. Petition for Exemptionto 14CFR91.9(a) November 16, 2015

Offshore elevated helidecklanding procedure.

DESCEND 600fPM 40KIAS



# .. ' ' ' ' ' ELEVATED HELIDECK LANDING PROFILE WITH SCHEDULED DROPDOWN



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LDP 50fT ABOVE HELIDECK

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Figure 3 Published S-92A Elevated Helideck Landing Procedure The landing procedure requires an offset approach with an aim point that is one to two rotor diameters to the side ofthe target helideck. The S-92A no-exposure approachis flown at an indicated airspeed no slowerthan 40 knots with a descent rate no greater than 600 fpm. At 50 feet above the helideck, a flaring side step maneuver slows the aircraft to a hover while placing the aircraft overthe landing spot. The Landing DecisionPoint (LDP) is 50 feet above the landing surface with at least 40 knots airspeed and no more than 600 fpm descent rate. Ifan engine fails prior to the LDP, the pilot flies a go-around maneuver, dropping below and to the side ofthe platform. Ifan engine fails at orbeyond the TDP, the pilot performs an OEI landing onthe helideck. The two primary hazards during a landing are very similar to those associated with an elevated helideck takeoff; AEO contact withthe platform and OEI deck edge strike or ditching. Landing hazard 1: Collision with the platform structure with all engines operating (AEO).

Attachment A Page 

### 14 of7PHI, Inc. Petition for Exemptionto 14CFR91.9(a) November 16,2015 Ifzero exposure to engine failure is mandated, the pilotmust fly the OEI profile every approach,justin case an engine fails at the most inopportune time. A single engine landing to a smallplatform (60

- 100 foot diameter circle) requires a very dynamic maneuver involving an aggressive pitchrate andhighpitch attitude. Underthe best of conditions, this type ofmaneuver, in close proximityto the obstructions associated with an offshore platform, is challenging. Whenthe degraded visual cues ofa night mission, along withthe turbulence associated withthe rig structure, are considered, the chances for error are greatly increased. This dynamic AEO landingprocedure is the cause of many offshore accidents. Mitigation: Reduced approach speed Reducing the approach speedresults in a much lower pitch attitude during the flare and consequently a less aggressive maneuver. A 10 knot ground speedprovides a safer, more controlled approach. Landing hazard 2: Engine failure during landing. As noted inthe takeoffdiscussion, the aircraft under discussion do not have an OEI hover capability at the desired operating weight. The helicopterrequires sufficient airspeed to minimize the powerrequired to avoid contact withthe water ifthe engine should fail priorto the LDP. The kinetic energy associated withthis airspeed is also requiredto carrythe aircraft overthe landing surface ifthe engine should fail at orjustafter the LDP. Mitigation: Increased approach speed A 40 knot approach speed is required to ensure sufficient energy for a fly-away maneuver (engine fails priorto LDP) or successful landing (engine fails at or after LDP). Again, it shouldbe noted that, as the helicopter weight decreases (lower fuel/payload), the exposure to engine failure decreases due to increased OEI powermargins. Again, the mitigation factors for the two primary landinghazards are opposite. A slow approach speed is required for an easily flown, controlled approachwhich will decrease the chances of AEO contact with the platform structure. However, a faster approach speedprovides the energy required to perform a successful OEI fly away or landing. 

### Decreased gross weight. Inboththe takeoffand landing maneuvers, a lower aircraft gross weight will improve single engine performance and decrease the hazard ofan OEI accident. However, decreasing the aircraft gross weight canonly be accomplished by decreasing the passenger orfuel load. Hazard ofdecreased passenger load: The total number ofpassengers exposed to an accident does not change. A decreased passenger load oneach sortie will require additional sorties to be flown to service the offshore oil fields. Withthe current fleet ofaircraft operating inthe Gulfof Mexico, ifflight with no exposure to engine failure was mandated, the number ofsorties AttachmentA Page 

### 15 of7PHI, Inc. Petition for Exemptionto 14CFR 91.9(a) November 16, 2015 required would at least double. Each additional sortie increases the likelihood ofAEO accidents caused by Controlled Flight Into Terrain (CFIT), mid-air collision, or mechanical failures. Hazard ofdecreased fuel load: Fuel starvation and increased take-offand landing activity. There are two concerns with a decreased fuel load. 1. The knowledgeable pilot will carry more thanthe minimum required fuel as insurance against the changing offshore environment. Ifrequired to minimize gross weight, there will be increased pressure to launch withthe absolute minimum fuel required. Due to changing weather conditions, this will certainly lead to landings with fuel levels belowthe required minimums and the associated possibility ofditching due to fuel starvation. 2. For longer range missions, what would normally be a "non-stop" flight will require an intermediate fuel stop going to and returning from the intended offshore destination. These additional (unnecessary) offshore takeoffs and landings also increase the likelihood ofthe AEO accidents noted above. The Dilemma: The mitigations for the All Engines Operating (AEO) hazards are directly opposed to the mitigations for the One Engine Inoperative (OEI) hazards. In order to minimize the AEO hazards, it would be necessary to: 1. Fly slow controlled approaches (15 knot ground speed) 2. Utilize lower takeoffdecision points (15 feet at 500 fpm climb rate) 3. Maximize passengers on each sortie to minimize the number ofsorties 4. Carry additional fuel reserves to minimize additional offshore landings and takeoffs to refuel In orderto minimize the OEI hazards, it would be necessary to: 1. Fly faster approach speeds (40 KIAS) 2. Utilize highertakeoffdecision points (30 feet at 1,000 fpm climb rate) 3. Minimize weightby offloading passengers and fuel. 4. Add offshore refueling stages to the mission The offshore oil industry reviewed these hazards to determine the safest route forward. They identified the hazard which, historically, has been the major contributorto accidents and then addressed thathazard. The issue may be summarized as determining whether there are more accidents caused bypilot error with all engines operating or bythe loss ofpower due to a single engine failure.,. A review ofthe last ten years ofworldwide helicopter offshore operations yields eight instances ofpilot error; AEO accidents in which the aircraft struck some portion ofthe platform. There Attachment A Page 

### 16 of7PHI, Inc. Petition for Exemptionto 14CFR 91.9(a) November 16, 2015

were also at least four instances in whichpilot error resulted in an inadvertent AEO ditching/crash into the water. During that same ten-year period, there were no accidents caused by the loss ofpower due to engine failure on multi engine aircraft. The best route forward is clear. The chances ofan accident caused bypilot error with AEO is much greater than the likelihood ofan OEI accident. Procedures that minimize the opportunity for pilot error and permit limited exposure to engine failure provide the highest level ofsafety. Procedures, such as Performance Class II (PC-2) have beenproven worldwide to offer an equivalent level ofsafety as compared to Category A or PC-1 profiles. Recommendation. The FAA should approve this request for exemption from Part 91.9(a) to permit limited exposure to engine failure when operating inthe offshore environment orin other areas where exposure can be minimized using accepted takeoffand landing profiles.

Attachment A Page 17 of7