Era Helicopters LLC

• PO Box 6550/70606

• 600 Airport Service Road

• Lake Charles, LA 70605

• 337.478.6131 www.erahelicopters.com June 22, 2016 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. Page

I of2

# Allowing Era Helicopters

to perform these inspections would benefit public interest by allowing our trained personnel

to complete these inspections instead of an outside entity that is often less reliable and cannot always be available

in the timeframe required. This unavailability can often mean aircraft are grounded and the public customers are losing valuable services when Era Helicopters has qualified personnel
on site and can perform the required inspections. Exemption from Title 14 CFR Part 91.411(b) and Part 91.413(c) for Era's Part 135.411(a)(l) aircraft maintained under an Approved Aircraft Inspection Program (AAIP) would provide an equal or higher level 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 b y 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

, 

# EraHdic r.;

C 

# ! ..... · ___ __ _ _ 

# ;~ality Control jseabaugh

@ erahelicopt

e rs

. com

P a g e 2 of 2