POST OFFICE BOX 90808

 LAFAYETTE, LOUISIANA 70509 USA

 TELEPHONE: 337 235 2452

 FACSIMILE: 337 272-4510

September 1, 2011

U.S. Department of Transportation

Docket Operations

West Building Ground 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 accessible 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

PHI, 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 crews 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 contact with FAA offices is not possible.
PHI, Inc.

Petition for Exemption

September 1, 2011

This Exemption is in the Public Interest

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. Aircraft unavailability 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 supplies, severe financial loss to PHI and its customers, and decreased

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, maintain 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; therefore 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 States 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 facsimiles 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 aircraft when exercising the 

privileges of this exemption.

2. Before any pilot crewmember may utilize 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 utilizes this grant of exemption.

3. Each pilot crewmember who operates under the authority of this grant 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 

conducted under this exemption. PHI, Inc., is authorized to make this application to the FAA on 

behalf of each of its pilot crewmembers. The pilot crewmember must provide a copy of the 

facsimile to PHI, Inc., within 24 hours of the receipt of that facsimile.

This exemption should be granted based 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 this 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