US Department of Transportation 

Docket Operations, M-30 

West Building Ground Floor, 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

Subject: Request for Exemption Amendment to Exemption No. 15102, Regulatory Docket No. FAA2005-20038, Exemption from 14 CFR Part 91.41l(b) and 91.413(c) 

Filed electronically using the Federal Document Management System, 

http://www.regulations.gov, on this date. 

Dear Sir or Madam: 

Era Helicopters, LLC (Era Helicopters) is a commercial Air Carrier authorized under Title 14 CFR, Part 

119 and Part 135 (Air Carrier Certificate No. UOGA290L). Era Helicopters currently operates 118 aircraft 

on the Air Carrier Certificate. 41 aircraft are maintained in accordance with 135.411(a)(2) and 77 aircraft 

are maintained in accordance with 135.411(a)(l). 

Under the provisions of Title 14 CFR Part 91.413(c)(2) and Part 135.411(a)(2) Era performs the required 

inspections of Part 91.411 and Part 91.413 on all of the 135.411(a)(2) "CAMP" aircraft. 

The literal interpretation of the rule, Title 14 CFR 91.413( c) (2), implies that the holder of a Continuous 

Airworthiness Maintenance Program (CAMP) can perform these tests and inspections. It does not state 

that all aircraft owned or operated by the operator must be maintained under a CAMP to comply with this 

rule. 

The majority of Era's aircraft maintained under Part 135.411(a)(1) are stationed remotely throughout the 

states of Alabama, Alaska, Louisiana, Massachusetts, North Carolina, and Texas. The economic burden to 

contract a Part 145 Repair Station to travel to these locations for these inspections exceeds that which other 

operators must bear. 

Era Helicopters requests the continued ability to comply with the inspections required by Part 91.411 and 

Part 91.413 on our aircraft maintained under Part 135.411(a)(l). Era Helicopters' trained personnel 

currently perform these inspections on larger, more complex aircraft maintained under Part 135.411(a)(2). 

Their familiarity with Era's aircraft exceeds that which an outside Part 145 contractor can provide. 

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of safety as the current rule. 

The language in our current Exemption No. 15102 needs to be clarified. It should clearly state that this 

exemption is for our 135.411(a)(l) aircraft maintained under an Approved Aircraft Inspection Program 

(AAIP). 

The same conditions and limitations from our previous Exemption No. 8852C would apply. 

Proposed Conditions and Limitations: 

1. All ATC transponder tests and inspections and altimeter reporting equipment tests and inspections 

must be conducted under Era's Part 135 General Maintenance Manual. 

2. All tests and inspections must be recorded in the aircraft's maintenance log by the person performing 

each inspection and test. This record must identifY the person performing the inspection, the date of 

the inspection, and this exemption number. 

3. All records of these tests and inspections must be kept in Era's maintenance recording system for its 

aircraft operated under Part 13 5. 

Sincerely, 

EraHdicr.;C ! ..... · 

______ _ 

;~ality Control 

jseabaugh@erahelicopters.com 

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