**—"> • • ••-T/ENTO F ^ Bristow ()' • 

:' :: R -' i P ]•• 3 

March 30, 2011 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Dear Sir or Madame: 

Bristow U.S. LLC is a commercial Air Carrier certificated under CFR Title 14, Part 119 and 135. Currently 

we operate and maintain 29 aircraft under 135.411(a) (2) "CAMP" and operate and maintain 60 aircraft 

under 135.411(a) (1) "AAIP". The referenced regulations that follow are the subject of our request for an 

exemption. 

FAR 91.413, ATC transponder tests and inspections, state: 

(b) Following any installation or maintenance on an ATC transponder where data correspondence error 

could be introduced, the integrated system has been tested, inspected, and found to comply with 

paragraph (c), Appendix E, of Part 43 of this chapter. 

(c) The tests and inspections specified in this section must be conducted by— (2) A holder of a continuous airworthiness maintenance program as provided in Part 121 or §135.411 (a) (2) of this chapter. 

FAR 91.411, altimeter system and altitude reporting equipment tests and inspections, state: 

(a) No person may operate an airplane, or helicopter, in controlled airspace under IFR unless— 

(3) Following installation or maintenance on the automatic pressure altitude reporting system of the 

A TC transponder where data correspondence error could be introduced, the integrated system 

has been tested, inspected, and found to comply with Paragraph (c), Appendix E, of Part 43 of 

this chapter. 

(b) The tests required by paragraph (a) of this section must be conducted by— 

(1) The manufacturer of the airplane, or helicopter, on which the tests and inspections are to be performed; 

(2) A certificated repair station properly equipped to perform those functions and holding— 

(i) An instrument rating, Class I; 

(ii) A limited instrument rating appropriate to the make and model of appliance to be tested; 

(Hi) A limited rating appropriate to the test to be performed; 

(iv) An airframe rating appropriate to the airplane, or helicopter, to be tested; or 

(3) A certificated mechanic with an airframe rating (static pressure system tests and inspections 

only). 

Bristow U.S. LLC ^1605 Industrial Drive, New Iberia, Louisiana 70560, United States 

t (337)365 6771 f (337) 364 8222 www.bristowgroup.com 
k 

The Bristow U.S. LLC fleet is positioned in numerous locations along the Gulf Coast area of Louisiana, 

Texas and several international locations. The economic burden involved in contracting with a Part 145 

Repair Station to travel to these locations and perform the required inspections would be excessive for 

the operator to bear. Locating, an FAA Certificated Repair Station at the international locations could be 

especially difficult. Additionally, international Certificated Repair Stations may not have the technical expertise, familiarity or special equipment required to perform the required inspections on Bristow aircraft. 

Since 91.413 provides for a holder of a continuous airworthiness maintenance program to test, inspect, 

and comply with Paragraph (c). Appendix E, of Part 43 of this chapter, we feel it is appropriate for Bristow U.S. LLC to be exempt from the requirements imposed by 91.411 to require a repair station to comply 

with these same requirements. 

Furthermore, literal translation of 91.413 states that a holder of a continuous airworthiness maintenance 

program may conduct the testing required and does not say that the rule only applies to CAMP aircraft, 

and since the complexity of the CAMP aircraft is higher than that of our AAIP aircraft, we (Bristow U.S. 

LLC) request an exemption from requiring a repair station to perform these tests on our AAIP aircraft. 

Allowing Bristow U.S.LLC to perform the inspection and testing with our trained personnel would be in the 

interest of public safety, because of familiarity with the aircraft in our fleet. The alternative would be to 

have an outside repair station, which can be far less reliable and not always available on a timely base, to 

meet our requirements. The unreliability of this method can often mean aircraft are unavailable for customer service even when there are qualified Bristow personnel available on site to perform the required 

inspection and testing. 

In summation Bristow U.S. LLC (ALGA151C) is requesting an exemption to 91.411(b) (2), and an additional exemption io 91.413(c) (2) which will allow AAIP aircraft to be included in this paragraph. 

Granting this exemption would provide an equal or greater level of safety when performing these Inspections or testing requirements. 

Sincerely yours, 

BRISTOW U.S. LLC 

Douglas S. Forslund 

Director, New Iberia Support 

DSF/eds