POST OFFICE BOX 90808

L AFAYETTE, LOUISIANA 70509 USA

TELEPHONE: 337 235 2452

FACSIMILE: 337 272

- 4510

September 1, 2011

U.S . Department of Transportation Docket Operations West Building G round Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590.

To Whom It May Concern;

In accordance with 14 CFR Part 11.61 thru 11.71, and 11.81, PHI, Inc. requests an exemption from 14 CFR, part 61.3(a)(1) and (c) (1) , which states, in part;

§ 61.3 Requirement for certificates, ratings, and authorizations. (a) Pilot certificate. No person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person

-- (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessi ble in the aircraft when exercising the privileges of that pilot certificate or authorization... [continues]

..... (c) Medical certificate. (1) A person may serve as a required pilot flight crewmember of an aircraft only if that person holds the appropriate medical certificate issued under part 67 of this chapter, or other documentation acceptable to the FAA, that is in that person's physical possession or readily accessible in the aircraft... [continues]

Loss or mutilation of a required certificate currently results in aircraft unavailability which can impose hardship to the individual crew, loss of revenue, and possibly create unsafe conditions for the passengers and/or customer. PHI maintains photocopies of both the airman and medical certificates, and has the ability in most cases to provide immediate copies of those certificates to the flight crew, thus eliminating the negative consequences of the loss of certificate until a FAA provided replacement can be obtained. Extent of Relief Sought and Reason for the Relief

PH I, Inc., seeks this exemption from 14 CFR § 61.3(a) and (c) to the extent necessary to allow its pilot crewmembers to be issued company provided facsimiles of their pilot and medical certificates when those certificates are lost, destroyed, or misplaced

.

PHI, Inc, holder of Air Carrier Certificate HEEA, conducts Part 135 operations domestically and internationally in support of natural resource exploration and production, air medical transport, science support, and general air taxi services. Our flight cr ews live and work in areas where immediate access to obtaining replacement airman and FAA medical certificates is often impossible due to remoteness and work schedule. Additionally, our hours of operation dictate

work schedules during "off" hours when con tact with FAA offices is not possible.PHI, Inc. Petition for Exemption September 1, 2011

This Exemption is in the Public I nterest

As stated above, PHI, Inc's operations are often conducted in areas where air transportation is the only practical or safe means of transport. In Air Medical operations, air transport is often the difference between life or death for the passenger. Aircr aft u navailability or undue delay in medical transport due to lack of a required airman or medical certificate is clearly not in the public interest. In other remote operations, lack of air transportation can impose severe hardship

due to lack of needed s upplies, severe financial loss to PHI and its customers, and decrease d safety margins during times of crisis and evacuations.

For these reasons, this exemption is in the general public interest.

Equivalent Level of Safety

PHI is required, and does, main tain training and qualification records on its pilots, including copies of current airman and medical certificates. Our operational control processes insure that no pilot is assigned to flight crew duty unless that pilot meets CFR and company requirements for his or her duty position. Based on this knowledge, loss of a required certificate , which can be replaced quickly from PHI and FAA files, imposes no safety risk; the refore demonstrating an equivalent level of safety to 14 CFR, Part 61.3.

Summary

PHI, Inc., seeks an exemption to 14 CFR, Part 61.3(a)(1), and (c),(1), which requires a pilot to have in his or her possession their original airman and medical certificate. Specifically PHI, Inc. requests that

, in the event of a lost or mutilated airman or medical certificate, PHI can provide a copy of the current airman and/or medical certificate to the pilot to be used temporarily until a replacement certificate can be obtained from the FAA. This temporary replacement copy may be
hand carried, mailed, or sent electronically via email or facsimile to the pilot.

PHI, Inc., requests that this exemption be allowed outside the United S tates due to our international operations in remote areas such as Africa and Antarctica where the hardship

conditions stated above are even more severe.

PHI, Inc., agrees that under the terms of this exemption, it will meet the following conditions :

This exemption was granted from 14 CFR § 61.3(a) and (c) to the extent necessary to allow its pilot

crewmembers to be issued fac similes of their pilot and medical certificates when those certificates are lost, destroyed, or misplaced, subject to the conditions and limits described below.

Conditions and Limitations

1. A copy of this grant of exemption must be carried onboard the a ircraft when exercising the privileges of this exemption.

2. Before any pilot crewmember may util ize this grant of exemption, PHI, Inc., must prepare an original record and a copy of that document on each of its pilot crewmembers that contains the following information:

a. Name and permanent mailing address;

b. Pilot certificate number, grade of pilot certificate, ratings, limitations, and date of issuance;PHI, Inc. Petition for Exemption September 1, 2011

c. Date of birth;

d. Height and weight, color of hair, color of eyes, and sex;

e. Nationality;

f. Class of medical certificate and date of issuance;

g. Medical examiner's name and number; and

h. A statement prepared by PHI, Inc., and is printed on each record that states: "Issued under the authority of Exemption No. [ ]."

i. This record must be carried by each pilot crewmember that ut ilizes this grant of exemption.

3. Each pilot crewmember who operates under the authority of this gra nt of exemption must comply with 14 CFR § 61.29(d) and (e)(2). A request for a facsimile from the FAA confirming the pilot crewmember's certificate must be requested within 72 hours of the initiation of any flight

cond ucted under this exemption. PHI, Inc

., is authorized to make this application to the FA A on behalf of each of its pilot crewmembers. The pilot crewmember must provid e a copy of the facsimile to PHI, Inc., within 24 hours of the receipt of that facsimile.

This exemption should be granted ba sed on the following:

**•** No risk to flight safety would exist due to this exemption.

**•** The conditions imposed by the requested exemption insure and equivalent level of safety to the standing rule (61.3).

**•** The exemption is in the public interest.

**•** The FAA has issued a grant of exemption in circumstances similar or identical in all material respects to those presented in this petition, specifically, exemptions 9944 and

5318.

If there are any questions concerning this petition, or to report the disposition of th is request, please contact me as indicated below.

Sincerely,

Michael C. Hurst

Chief Pilot
PHI, Inc.

P.O. Box 90808 Lafayette, LA 70509

337.272.4242 email: mhurst@phihelico.com