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POST OFFICE BOX 90808 

LAFAYETTE. LOUISIANA 70509 USA 

TELEPHONE: 337 235 2452 

Augusts, 2011 

U.S. Department of Transportation 

Docket Operations, West Building Ground Floor 

RoomW12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

Dear Sir or Madam, 

PHI, Inc. is a commercial air carrier authorized under Title 14CFR Part 119 and 135 that 

provides transportation services to the offshore oil Industry and emergency medical 

services industry. PHI, Inc. operates a mixed fleet of approximately 240 aircraft. These 

aircraft are maintained in accordance with a Continuous Airworthiness Maintenance 

Program (CAMP) or an Approved Aircraft Inspection Program (AAIP) in accordance with 

Title 14 CFR Part 135.411(a)(1) and 135-411(a)(2). 

As the holder of a CAMP, PHI, Inc. air carrier trained personnel are authorized to 

perform air traffic control (ATC) transponder tests and inspections in accordance with 

Title 14 CFR Part 91.413, and the altimeter systems and altimeter reporting equipment 

test and inspections in accordance with the PHI, Inc. CAMP on all PH114 CFR, Part 135 

aircraft that maintained under the PHI, Inc. CAMP. 

PHI, Inc. is requesting an exemption from Title 14 CFR Part 91.411(b) and 91.413(c). 

This exemption if granted, would allow PHI, Inc. air carrier trained personnel to perform 

air traffic control (ATC) transponder tests and inspections in accordance with Title 14 

CFR Part 91.413 and the altimeter systems and altimeter reporting equipment test and 

inspections in accordance with the PHI, Inc. CAMP (which includes the same tests and 

inspections required by Title 14 CFR Part 91.411) on PHI, Inc. 14 CFR, Part 135 aircraft 

that are maintained on an AAIP. 

This exemption would benefit the public interest by allowing PHI, Inc. air carrier trained 

personnel to perform these test and inspections whose familiarity and knowledge of the 

aircraft is equal to or often exceed that of contracted Title 14 CFR Part 145 repair 

stations. There is also the benefit of reduced aircraft downtime since many of the PHI, 

Inc. AAIP aircraft are emergency medical services (EMS) aircraft that are stationed 

remotely throughout the United States that must be taken out of service due to 

scheduling and travel requirements that arise with the contracting of outside Title 14 

CFR Part 145 repair stations. With reduced downtime, there is a higher availability of 

EMS aircraft to provide life saving transportation services for the benefit of the public as 

a whole. 

As requirement of the CAMP, PHI, Inc. has a full time training staff that trains air carrier 

personnel in the testing and inspection procedures and the use of the test equipment. 
Documented procedures and guidance is provided in the PHI, Inc. General Maintenance 

Manual as required by Title 14 CFR Part 135.21. 

PHI, Inc. trained personnel that perform the required tests and inspections using the 

same test equipment and procedures as personnel from a Title 14 CFR Part 145 repair 

station would be able to make the same determination of ainworthiness therefore 

maintaining a level of safety at least equal to the one required by Title 14 CFR Part 

91.411 and 91.413. 

Thank you for your consideration. 1 look forward to answering any questions you might 

have. 

Sincerely, 

Jeffrey J. Jenkins 

Chief Inspector Part 135 

PHI, Inc. 

Ph: 337-272-4331 

email: ijenkins@phihelico.com