Chevron 

# Ill

Chevron USA

September 1, 2015
Docket Management Facility US Department ofTransportation 1200 NewJersey 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) ofTitle 14, Code of Federal Regulations (14CFR). The requested exemption, ifrenewed, would allow Chevron USAto operate Sikorsky S-92A (S-92A) helicopters with limited exposure to engine failure duringtakeoffand landingwhile carrying up to 19 passengers between land-based and offshore facilities orwhen operating between two offshorefacilities, day, night, visual flight rules, and instrumentflight 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 ourSikorsky S-92A aircraft when operating between land-based and offshore facilities orwhen operating between two offshore facilities.Chevron USA's Sikorsky S-92A helicopters were certified under Part 29, amendment

### 47, which relates to safety and ditchingequipmentwhich providesthe highest level of safetytoday. The S-92A's are equipped with aircraftfloatation 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 oroutsidethe aircraft. European operators, usingthe same aircraft, operatethe S-92A in accordance withJoint Aviation Requirement-OPS-3 which already permits similar operations with limited exposure to engine failure. We have operated ourSikorsky S-92A aircraft underthis exemption since 2013.
We believethatthe requestto renewthe 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 tothe engine reliability and it shows that we have never had an inflight shutdown ofan engine in 4_726 hours operated.
Chevron USA has operated underthis exemption in the United States since 2013 which authorized operations similarto International Civil Aviation Organization (ICAO) Performance Class 2 with limited exposure. Duringthis period, no S-92A accidents have been caused by power loss dueto engine failure duringtakeoffor landing.
Chevron USAwill further mitigate exposure by: (1) Conductingflight operationsto and from helidecks and shore based heliportsthat meetor exceed size and weight requirements appropriate tothe 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 thatthe 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 ofour U.S. based operations that use the S-92A aircraft operate them in accordance with HlOO standards. This experience demonstrates that when takeoff and landingtechniques are used to minimize exposure toforced landing due to define failure, thatthis aircraft can be operated at an equivalent level ofsafetyto Category A. Additionally, withoutthe exemption relief, because ofthe removal ofOpSpec HlOO it would become economically unfeasible to operate this aircraft which would likely result in their removal from service. Withoutthe exemption relief, we would have to offerto our customer's smaller, older, less sophisticated aircraftthat do not provide the same level ofsafety. 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 matteror 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