Docket Management Facility ' • T r.'PAi ;L'! .3 

US Department of Transportation 

1200 New Jersey Avenue, SE --;•> -y 13 3 2^03 

West Building Ground Floor,Room Wl2-140 

Washington, DC 20590 

Attn: Aircraft Certification Service / Office of the Director 

08 March, 2012 

Ref: Request for exemption: Emergency Evacuation Crewmember 

Greetings, 

Halliburton Energy Services has maintained a corporate flight department since the early 1920's. 

We have operated Gulfstream corporate aircraft continuously to this day since the 1959 purchase 

of a Gulfstream I turbo-prop aircraft. A second Gulfstream I aircraft was added in 1963. The first 

Gulfstream II aircraft operated by the company went into service in 1979 and was operated until 

being phased out of service in 2011. Two additional Gulfstream II aircraft were also operated 

between 1985 and 2006. Our present fleet consists of three aircraft, a Gulfstream V aircraft, S/N 

616, (added to the fleet in 2003), a Gulfstream IV aircraft, S/N 1387, (added in 2006), and a G550 aircraft, S/N 5085 placed in service in 2011. 

The Halliburton Energy Services flight department is based at Atlantic Aviation at Houston 

Intercontinental Airport in Houston, Texas. We currently employ one Chief Pilot, eleven line 

pilots, four maintenance technicians, one maintenance assistant, and two administrative support 

personnel. Our maintenance personnel have a combined eighty-two years of Gulfstream 

experience and complete recurrent training and advanced maintenance courses. A maintenance 

technician, operating as a flight engineer / Emergency Evacuation Crewmember, will generally 

accompany our aircraft on international trips. Our pilots are type rated in both the G-IV and GV/550 aircraft and attend yearly recurrent training. Our excellent operating record is the direct 

result of the above experience, training, and strict adherence to our policy and procedures 

manual. 

The Halliburton Energy Services flight department is a FAR Part 91 operation. We regularly 

travel to destinations world-wide. Our passengers consist of top company executives, to include 

but not limited to, the members of the Board of Directors, C.E.O., Presidents, Vice-Presidents, 

Directors, Managers, etc., and their invited guests. Our passenger's vary the use of each aircraft 

based on the mission profile and aircraft availability and are not assigned to, nor do they 

exclusively use, a particular aircraft. 

At the time the GV was certified in 1997, the four emergency exits were considered by the FAA 

to be equivalent to two larger Type III exits. The FAA, however, asked Gulfstream to redesign 

the G550's emergency exit system to include the requirement for a Type III exit. An Equivalent 

Level of Safety, (ELOS), was granted which allowed the G550 to be certified without the 
addition of a Type HI exit, but requires an "Emergency Evacuation Crewmember " on all flights 

with (10) or more passengers. For flights with less than 10 passengers, the FAA restriction does 

not exist, and there is no requirement for an evacuation crewmember. This FAA requirement 

exists for N registered aircraft only. 

The G-550 Operafing Manual Supplement, G550-OMS-1 details the crewmember training 

requirements. 

G550~OMS-01 Revision 2, Page 2. EVACUATION CREWMEMBER TRAINING 

REQUIREMENTS dated November 20, 2008 States: 

EVACUATION CREWMEMBER TRAINING 

General 

NOTE: It is not required that the evacuation crewmember be trained in any other flight 

attendant functions other than those listed in this supplement. 

1. A crewmember trained in evacuation is an additional required crewmember for all 

flights having 10 or more passengers. 

2. The required pilot and co-pilot cannot ser\>e this fiinction. 

3. The evacuation crewmember must be trained in the recommended methods fr)r 

evacuating through the Gulfstream elliptical exits. 

4. The evacuation crewmember must be trained in the procedures for directing passenger 

flow to the available exits to prevent someone who may not fit through, or may have other 

personal disabilities which may preclude them from using the elliptical exit, from 

blocking it so that others may utilize the exit. 

The source of the data used in this supplement is the FAA-approved Gulfstream 

Engineering Report number GVSP~GER-6111, GV-SP Evacuation Crewmember Training 

Requirements, Revision C, dated November 19, 2008. 

The Halliburton Aviation Department believes that based on the reasons stated below, that an 

Equivalent Level of Safety exists to justify operations without the required Emergency 

Evacuation Crewmember as mandated by G-550 Operating Manual Supplement, G550-OMS-1, 

Applicable Regulations: FAR 25.807(a) (3): 25.807(g) (2). and (3); and 25.807(1) (2). 

Emergency Exits and FAR 25.807 at Amendment 25-98, Description of compensating design 

features or alternative standards which allow the granting of the ELOS (including design 

changes, limitations or equipment needed for equivalency). 

We are asking for a fijll exemption from the requirement of an Emergency Evacuation 

Crewmember as required by the above listed documents, based on the following reasons: 

1). The excellent history and operating record of the Halliburton Energy Services flight 

department. 

2). Halliburton Energy Services company aircraft and the aircraft safety equipment are strictly 

maintained in accordance with the manufacturers CMP, (Computerized Maintenance Program), 

system. 
3). Our G-V and G-550 aircraft have identical interior seating arrangements and all three of our 

aircraft have identical evacuation exits and doors. Since our passengers utilize all of the aircraft, 

they arc more familiar with the layout and the evacuation procedures due to repetition, thus 

providing better egress ability fi'om the G550 as well as the other aircraft. In comparison, no 

actual flight time requirements exist for an Emergency Evacuation Crewmember. A person may 

theoretically be ftilly trained in accordance with G550-OMS-1 and fianction as the required 

crewmember having never flown in an aircraft, have limited time in the aircraft, or can serve in 

the required capacity up to one year fi'om their last training date. 

4). Halliburton Energy Services flight crews are consistent in the use of thorough safety briefings 

given to the passengers prior to each flight. Verbal and / or electronic safety briefings are given 

to the passengers for each flight and include, but are not limited to, briefings for take-off, landing 

and extended overwater flight. These safety briefings include the required information for 

operation of the emergency exits, (corporate and commercial passengers are given the 

responsibility for the operation of the emergency exits on thousands of flights daily), use of 

emergency safety equipment and the evacuation from the aircraft. Passenger safety briefmg cards 

are located in all of our aircraft and are customized for each aircraft. 

5). As stated above in the EVACUATION CREWMEMBER TRAINING REQUIREMENTS line 4, 

'''The evacuation crewmember must be trained in the procedures for directing passenger flow to 

the available exits to prevent someone who may notflt through, or may have other personal 

disabilities which may preclude them from using the elliptical exit, from blocking it so that others 

may utilize the exit". The concern of an exit being blocked is obviously a concern in any 

Gulfstream aircraft fi-om the G-I through the G-550 whether there is more than or less than 10 

passengers, yet there is no requirement for any aircraft other than the GV-SP / G500 / G550. To 

dispel this concern, an analysis / review of all accidents and incidents involving Gulfstream 

corporate aircraft, (G-I through G550), using F.A.A., N.T.S.B., Air Safety Network websites and 

internet searches was done and revealed the following: 

Seventy-six records were found. Of these only thirty-five appeared to be accidents or 

incidents in which there was, or possibly was, some type of evacuation. For the purpose of 

this analysis, the term evacuation shall include, but not be limited to, passengers and / or 

crew exiting the aircraft by any exit while the aircraft was at a location other than a 

designated aircraft parking ramp, (i.e. E.M.A.S. area, runway, taxiway, off airport, etc.). 

Of these thirty-five records there were only seven accidents / incident records found in 

which there were (10) or more passengers aboard the aircraft. All involved Gulfstream I 

turbo-prop aircraft. Of these seven, only one accident resulted in a fatality to a passenger. 

1990: A U.S. registered Gulfstream I operated by Rowan Drilling Co, crashed on 

take-off in Houston, Texas. The (2) pilots and (1) of (13) passengers received fatal 

injuries. However, in this accident the passenger was actually a non-company 

employee, a commercial pilot, who was "hitchhiking" aboard the aircraft to return 

to his home town. He was located in the cockpit jump seat at the time of the crash 

and killed instanfly with the pilot and co-pilot. All (12) passengers in the cabin 

survived. 
There were sixteen records found that involved aircraft with (1) to (9) passengers aboard. Of 

these accidents / incidents, four involved Gulfstream I aircraft; five involved Gulfstream II 

aircraft; one involved a Gulfstream III aircraft; four involved Gulfstream IV aircraft; one 

involved a Gulfstream V aircraft; and one involved a Gulfstream VSP aircraft. Of these 

sixteen, only three resulted in fatalities. They are: 

1974; A non-U.S. registered Gulfstream If operated by the Toga Government, 

crashed on approach to Lome, Toga. (3) crewmembers received fatal injuries and 

all (3) passengers survived after evacuating the aircraft. 

2003: A non-U.S. registered Gulfstream I operated by Afiican Commuter Services 

and leased by the Kenyan Government, struck power lines and crashed in Busia, 

Kenya after an attempted overweight takeoff. (2) of (3) crewmembers and (1) of (9) 

passengers received fatal injuries. (I) crewmember and (8) passengers evacuated 

the aircraft. A photograph of the crash shows that in all probability the crew and 

passenger received fatal injuries and were incapacitated by the crash sequence and 

not due to the inability to exit the aircraft. 

2012: A U.S. registered Gulfstream IV, operated by the Congo Government, over 

ran the runway in Bukavu, D.R. of Congo, and crashed. (2) crewmembers and (2) of 

(9) passengers received fatal injuries. (7) passengers evacuated the aircraft. 

Photographs of the crash indicate that the emergency exits were opened fi:om the 

inside by the passengers. Photographs of the crash also show that in all probability 

the (2) passengers that received fatal injuries were incapacitated by the crash 

sequence and not due to the inability to exit the aircraft. (2) farmers on the ground 

also received fatal injuries fi'om the aircraft. 

Twelve records were found involving accidents / incidents involving no passengers or an 

unknown number of passengers. There were no fatalities to passengers or crew involved. 

No record could be found that indicated in any way that a crewmember or passenger was 

unable to exit an aircraft due to an elliptical emergency exit being blocked by a passenger 

who was unable to exit the aircraft through that emergency exit. 

Accidents in which there was no evacuation required or no evacuation possible, (i.e. taxi 

accident, controlled flight into terrain, loss of aircraft control - en-route, shoot down, etc.) 

were not included in the analysis. 

Three incidents, all occurring in 1982, involving G-159C commuter aircraft with more than 

(10) passengers were not included in the analysis. They were intentionally omitted as 

incomparable due to additional exits being added to these aircraft during the lengthening 

process of the fuselage to accommodate more passengers. In all these incidents though, 

there were no fatalities to passengers or crew. 
6). The G550 aircraft received FAA certification in August 2003 and validation fi'om the 

European Aviation Safety Agency (EASA) in March 2004. The requirement for an emergency 

evacuation crewmember, as previously stated, exists only for N registered aircraft. The 

requirement does not exist for aircraft registered in European Aviation Safety Agency 

(EASA)/European Union (EU) states, or by any other aviation governing body. 

7). The G550 is a state of the art aircraft. The G550 is the first civil aircraft to receive a Type 

Certificate issued by the Federal Aviation Administration (FAA) that includes an Enhanced 

Vision System (EVS) as standard equipment on an aircraft. The aircraft also contained the first 

cockpit to incorporate PlaneView®, an integrated avionics suite featuring four 14-inch (36 cm) 

liquid crystal displays in landscape format. In 2004, Gulfstream was awarded the 2003 Collier 

Trophy for the development of the G550. 

8). Due to the nature of our business, we occasionally have additional passengers added to a 

flight just prior to departure. Since we are a global operating company, we do not always-have—-

the option to add an emergency evacuation crewmember. This inability is due to the lack of 

availability of such a crewmember in the location we may be or due to the time constraints 

involved. This would prevent us fi^om using our aircraft to its maximum potential. (This is also 

one reason we are asking for a fijll exemption from the requirement for domestic and 

international operations). 

To Summarize: The Halliburton Energy Services fliglit department is requesting a fiill exemption 

fi"om the requirements of an "Emergency Evacuation Crewmember " as required by FAR 

25.807(a) (3): 25.807(g) (2). and (3); and 25.807(i) (2), Emergency Exits and FAR 25.807 at 

Amendment 25-98. Description of compensating design features or alternative standards which 

allow the granting of the ELOS (including design changes, limitations or equipment needed for 

equivalency. We feel the facts given to support our request for exemption clearly show that an 

"Equivalent Level of Safety" does exist and negates the requirement for the additional 

crewmember. 

The requested exemption, when granted, will pertain to operations in Gulfstream G550, S/N 

5085, as well as any other Gulfstream GV-SP, G500 and G550 aircraft operated in the future by 

the Halliburton Energy Services flight department. 

Thank you for your consideration in this matter. 

Sincerely, 

Jos^h Fletchall 

Chief Pilot 

Halliburton Energy Services 

17555 J.F.K. Blvd., Suite 110 

Houston, Texas 77032 

281-871-3500 

Joseph.FletchallfgjHalliburton.com