# ~!f111l!};ABOVEAND BEYOND RLC,LLC 430 North Eola Road Broussard, LA 70518
MAIN 337.837.6038
FAX 337.837.9938 www.rlcllc.net

US DepartmentofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 NewJerseyAvenue, SE. Washington, D.C. 20590 

## Requestfor Excemption from 14CFR Part 135.160 {a) As perthe requirements of14CFR 11.63and 11.81 Requester's Nameand 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, 206L1, 206L3, 206L-4 and 407. Description ofProposed 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 afleet of39 BHT Model 206B, 206L1, L3, L4 and 407 helicopters. Our primary business is to providetransportation servicesto the offshore Oil and Gas Industry.

1RLC requests an exemption from the rule based on the economic burden thatwould 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 ofthese unitswould be approximately $5,000.00for each aircraft. This results in atotal cost forthe 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 ofbusiness. All ofour 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 orderto remain a viable entity. This requirement forthe upgrade ofthe radar altimeters by April 2017 would create a significant economic burden on RLC and could threaten ourabilityto meetourobligations 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. Thiswould putthe effective date ofthe rule beginning April 24, 2019.
An equivalent level of safety can be maintained during thattwo 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 oftwo years afterthe effective date ofApril 24, 2107 dueto economic burden.

Dru Milke,

# k1..--**~** Rotorcraft Leasing Co LLC

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