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Era Helicopters LLC • PO Box 6550/70606 • 600 Airport Service Road • Lake Charles, LA 70605 • 337.478.6131 

www.erahelicopters.com

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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 Federal Regulations 11.15 and 11.81, Era Helicopters 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 following S-92A Rotorcraft Flight Manual limitation when 

operating between land-based and offshore facilities, or when operating between two offshore facilities. 

TYPES OF OPERATION 

Category ’A’ with a maximum of 19 passenger seats, or Category ’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 while 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 amendment 47), and equipped 

with state-of-the-art safety systems and technology, routinely transport workers 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 avionics and electronics allow these rotorcraft 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 requirements 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. 
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Equivalent Level of Safety 

The S-92A has operated under Operations Specification H100 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 the 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 takeoff 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 like 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 hazards 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 operations 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 failure 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 Class 2 operations (limited exposure to engine failure), Sikorsky Aircraft 

periodically submits engine reliability 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 manufacturer’s recommended takeoff and landing procedures 

whenever feasible. Operations will not be conducted unless the current aircraft 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. 

 
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Era Helicopters further mitigates exposure risk by; 

• Conducting flight operations to and from heliports and 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 flight simulator), and ensuring the highest levels of 

proficiency and competency; 

• Conducting route checks to confirm that Era flight crews remain procedurally 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 Manual, through flight data monitoring. 

Summary 

Other US S-92A operators have accumulated over 90,000 hours of operational experience in this make/model, 

all in accordance with H-100 and Performance Class 2 profiles. This experience demonstrates that when takeoff 

and landing techniques are used to minimize 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 operations, helideck size and off-airport basing, 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