### ______________________________________________________________________________ Era Helicopters LLC • PO Box 6550/70606 • 600 Airport Service Road • Lake Charles, LA 70605 • 337.478.6131 www.erahelicopters.com

Page 1 of 3 July 2, 2015

US Department of Transportation Docket Operations, M-30 West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE. Washington, DC 20590
Subject: Exemption Request 14 CFR § 91.9(a). Filed electronically using the Federal Document Management System, http://www.regulations.gov, on this date.

Dear Sir or Madam:
In accordance with Title 14 of the Code of Federa l Regulations 11.15 and 11 .81, Era Heli copters LLC, requests an exemption from § 91.9(a) which, in part, states: Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certifying authority of the country of registry. Extent of Relief Sought and Reason for the Relief This petition requests an exemption from the followi ng S-92A Rotorcraft Flight Manual limitation when operating between land-based and offs hore facilities, or wh en operating between tw o offshore facilities.
TYPES OF OPERATION Category ’A’ with a maximum of 19 passenger seats, or Ca tegory ’B’ with 9 or less passenger seats; Day, Night, VFR and IFR. Specifically, Era Helicopters requests approval to operate S-92A helicopters with limited exposure to engine failure during takeoff and landing wh ile carrying up to 19 passengers. This Exemption is in the Public Interest The S-92A, and other 10+ seat rotorcraft certified to the latest standards (§ 29 am endment 47), and equipped with state-of-the-art safety systems and technology, routinely transport work ers to and from offshore platforms to support the oil and gas industry. Equipment such as HUMS, HTAWS, ADS-B, TCAS/TAS, FMS, Fault Tolerant Design and other advanced av ionics and electronics allow these rotorc raft to offer the highest level of safety available today. These aircraft have replaced older designs, which do not offer these advancements, and are not required to meet the current performance require ments imposed on the S-92A and other similar aircraft. The intent of this exemption is to provide those workers, our passengers, with the safest transportation available, while maintaining an efficient transportation system for the oil and gas industry. For these reasons, this exemption is in the general public interest.Page 2 of 3 Equivalent Level of Safety The S-92A has operated under Operations Specification H 100 in the United States, and under JAR- OPS 3 in other countries, since 2003. Both rules allow for limited exposure to engine failure. The requested exemption will continue to provide th e same level of safety that is currently in place for offshore operations. During the period noted above, no accidents (S-92A or other aircraft in the same class) have been caused by power loss due to engine failure during takeoff or landing. If this exemption is granted, the S-92A will continue to operate Category A, with the exception of a brief exposure to engine failure during takeof f and landing. The amount of time the aircraft is exposed to engine failure will depend on many conditions, but the maximum exposure would normally be less than 9 seconds per takeoff/landing. If this exemption is not granted, the S-92A (and other li ke aircraft) would be forced to severely decrease the number of passengers and/or fuel per sortie. Decreased passenger loads will require more sorties to meet demand and effectively increase exposure to h azards unrelated to engine failure. Operations Outside of the United States: Non-U.S., S-92A operators outside of the United States do not require this exemption. JAR-OPS 3, and other equivalent operational rules, already permit operatio ns with limited exposure to engine failure. Era Helicopters, wishes to have this exemption apply to their operations outside the USA for the same reasons stated herein. Mitigation Factors: In the unlikely case of a ditching as a result of an engine fa ilure during takeoff or landing, the following mitigation is provided:

• The S-92A is equipped with aircraft flotation gear and has certified for ditching in up to sea state 6.

• When operating over water, each S-92A occupant is provided, and wears, personal flotation equipment.

• The S-92A is equipped with life rafts that can be deployed from inside or outside the aircraft.

• Era S-92A’s are equipped with a 406 MHZ deployable beacon. To qualify for JAR-OPS 3 Performance Cl ass 2 operations (limited exposure to en gine failure), Si korsky Aircraft periodically submits engine re liability reports to show that the in-flight shutdown rate is less than 1 per 100,000 flight hours. Era Helicopters will conduct operations in such a manner as to minimize the time spent exposed to engine failure. This will be accomplished by following the manufactu rer’s recommended takeoff and landing procedures whenever feasible. Operations will no t be conducted unless the current aircra ft weight, altitude and temperature ensure a 100 feet per minute climb at 1,000 feet above the takeoff surface with one engine inoperative and the remaining engine at maximum continuous OEI power.Page 3 of 3 Era Helicopters further mitigates exposure risk by;

• Conducting flight operations to and from heliports a nd landing areas that meet or exceed the size and weight requirements appropriate to the aircraft configuration;

• Training our flight crews in a Level D, FFS (full fli ght simulator), and ensuring the highest levels of proficiency and competency;

• Conducting route checks to confirm that Era flight crews remain pr ocedurally compliant, and employ crew resource management principles during all flight operations; and

• Ensuring flight profiles are in accordance with Performance Class 2 procedures, as described in the Era Flight Operating Procedures Manua l, through flight data monitoring. Summary Other US S-92A operators have accumula ted over 90,000 hours of operationa l experience in this make/model, all in accordance with H-100 and Perfor mance Class 2 profiles. This experien ce demonstrates that when takeoff and landing techniques are used to mini mize exposure to forced landing due to engine failure, this aircraft can be operated at an equivalent level of safety to Category A (PC-1). Due to the remote nature of our operat ions, helideck size and off-airport ba sing, the viability of full Category A or Performance Class One (PC1) is impractical. If this requirement were to be imposed, the S-92A would become economically unfeasible, and would likely result in its removal from service. The outcome of which would be a reversion to smaller, older, and less sophisticated aircraft that do not provide the same level of safety. This would result in an overall degradation of safety and not in the best interest of our most important stakeholder; our passengers. If there are any questions concerning this petition, or to report the disposition of this request, please contact me as indicated below. Sincerely,

Larry Lippert Director of Operations Era Helicopters, LLC Office: +1 337 656 4541 Mobile +1 337 302 9719 llippert@erahelicopters.com