Chevron 

Ill 

Chevron USA 

September 1, 2015 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue 

96 Runway Road 

Picayune, MS 39466 

SE West Building Ground Floor Room W12-140 

Washington, DC 20590 

Subject: Petition for Renewal of Exemption #10895 

Chevron Aircraft Operations is requesting renewal of Exemption #10895 from the 

Federal Aviation Administration (FAA) concerning §91.9(a) of Title 14, Code of Federal 

Regulations (14CFR). The requested exemption, if renewed, would allow Chevron USA to 

operate Sikorsky S-92A (S-92A) helicopters with limited exposure to engine failure 

during takeoff and landing while carrying up to 19 passengers 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 renewal of the exemption is for operations conducted in our Sikorsky 

S-92A aircraft when operating between land-based and offshore facilities or 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 that the request to renew the exemption will allow us to continue to provide 

the same level of safety that is currently in place for our offshore operations. Under 

current Chevron USA usage of the 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 during takeoff or landing. 

Chevron USA 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 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 of operational 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 of the 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 offer to 

our customer'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 USA believes that granting of this petition would be in the public interest 

because the S-92A 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 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 of our 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 takeoff from the 

same or like locations. We train at the same FFS (Full Flight Simulator) facility and by all 

accounts, have the exact level of experience with the S-92A aircraft based on our fleet 

size. 

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 USA office located in Picayune, MS. 

My email is rsqy@chevron.com. 

Rick Sloan 

Chief Pilot 

Cc: Kevin Tauzier