~ !f111l!}; ABOVE AND BEYOND RLC,LLC 

430 North Eola Road 

Broussard, LA 70518 

MAIN 337.837.6038 

FAX 337.837.9938 

www.rlcllc.net 

US Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, D.C. 20590 

Request for Excemption from 14 CFR Part 135.160 {a) 

As per the requirements of 14 CFR 11.63 and 11.81 

Requester's Name and Complete Mailing Address 

Rotorcraft Leasing Co LLC (d.b.a. RLC.LLC) (Air Carrier# YTRA264L) 

Dru Milke, CEO 

430 N. Eola Rd. 

Broussard, La 70518 

9milke@rlcllc.net 

337-837-6038 

Applicability: 

Bell Helicopter Model 206B, 206L 1, 206L3, 206L-4 and 407. 

Description of Proposed Exemption: 

Rotorcraft Leasing Co LLC (RLC) would like to be granted a exemption from 14 CFR 

Part 135.160 (a). The rule requires that: 

"After April 24, 2017, no person may operate a rotorcraft unless that 

rotorcraft is equipped with an operable FAA-approved radio altimeter, or 

an FAA-approved device that incorporates a radio altimeter, unless 

otherwise authorized in the certificate holder's approved minimum 

equipment list" 

RLC currently operates a fleet of 39 BHT Model 206B, 206L 1, L3, L4 and 407 

helicopters. Our primary business is to provide transportation services to the offshore 

Oil and Gas Industry. 

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RLC requests an exemption from the rule based on the economic burden that would be 

placed on the Company. Currently there are three manufacturers of radio altimeters 

available that are compatible for these models of aircraft. The Freeflight Systems 

RA4500 has a unit cost of $10,839.00, the Garmin GRA5500 has a unit cost of 

$13,300.00 and the Honeywell KRA405 has a unit cost of &11,050.00. Installation cost 

tor any of these units would be approximately $5,000.00 for each aircraft. This results in 

a total cost for the least expensive unit of $600,171.00 to upgrade 39 aircraft. This does 

not include lost revenue due to the aircraft being out of service during the installation 

period. 

RLC operates exclusively in the offshore environment supporting exploration and 

production activities. This industry is suffering extensively due to an extended term of 

low commodity prices. Many of our customers (and some of our competitors) are 

teetering on their ability to survive versus go out of business. All of our customers have 

asked for and received concessions on service charges as a result of this low 

commodity price environment and their efforts to sustain their businesses. Due to low 

revenues, RLC has been forced to reduce workforce and defer capital expenditures in 

order to remain a viable entity. This requirement for the upgrade of the radar altimeters 

by April 2017 would create a significant economic burden on RLC and could threaten 

our ability to meet our obligations and maintain operations. RLC requests the exemption 

to allow RLC to operate its aircraft for another two years while it begins the process of 

installation. This would put the effective date of the rule beginning April 24, 2019. 

An equivalent level of safety can be maintained during that two year period because of 

our flight following use of Satellite Tracking system and our enhanced Operational 

Control abilities. 

Summary: 

RLC is requesting an exemption from 14 CFR part 135.160 (a) for a period of two years 

after the effective date of April 24, 2107 due to economic burden. 

Dru Milke, k1..-- ~ Rotorcraft Leasing Co LLC 

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