y 

SE West Building Ground Floor Room W 12-140 

Washington, DC 20590 

Subject: Petition for Renewal of Exemption #I 0773 

Dear Sir: 

Bristow U.S. LLC is requesting renewal of Exemption #10773 from the Federal Aviation 

Administration (FAA) concerning §9l.9(a) of Title 14, Code of Federal Regulations (14CFR). 

The requested exemption, if renewed, would allow Bristow U.S. LLC to operate Sikorsky S92A (S-92A) helicopters with limited exposure to engine failure during takeoff and landing 

while carrying up to 19 passengers between land-based and offshore facilities or when operating 

between two offshore facilities, day, night, visual flight rules, and instrument flight rules. 

Specifically, we are requesting relief from Section 9l.9(a). Section 91.9(a) prescribes, in part, 

that no person may operate a civil aircraft without complying with the operating limitations 

specified in the approved Rotorcraft Flight Manual. 

This request for renewal of the exemption is for operations conducted in our Sikorsky S-92A 

aircraft when operating between land-based and offshore facilities or when operating between 

two offshore facilities. 

Bristow U.S. LLC's Sikorsky S-92A helicopters were certified under Part 29, amendment 47, 

which relates to safety and ditching equipment which provides the highest level of safety today. 

The S-92As are equipped with aircraft floatation gear and are certified for ditching in up to sea 

state 4. Additionally, when operation over water, each S-92A occupant is provided, and wears, 

personal floatation equipment. Also, the S-92A is equipped with life rafts that can be deployed 

from inside or outside the aircraft. 

European operators, using the same aircraft, operate the S-92A in accordance with Joint Aviation 

Requirement-OPS-3 which already permits similar operations with limited exposure to engine 

failure. We have operated our U.S. based S-92A aircraft under operations specification 

(OpSpec) H-100 since 2008. When renewed the exemption extends to our certificate operations 

conducted outside the United States when applicable. 

Bristow U.S. LLC 46051ndustrial Drive. New Iberia, Louisiana 70560, United States t 

(337) 365 6771 f (337) 365 6152 bristowgroup.com 
authorized operations similar to International Civil Aviation Organization (ICAO) Performance 

Class 2 with limited exposure. During this period, no S-92A accidents have been caused by 

power loss due to engine failure during takeoff or landing. 

Bristow U.S. LLC has instituted operational controls through its general operations manual, 

training program, and maintenance surveillance. Bristow U.S. LLC 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 100 feet per minute rate of climb at 1 ,000 feet above the takeoff surface 

with one engine inoperative and the remaining engine at maximum continuous one engine 

inoperative (OEI) power. 

Bristow U.S. LLC will further mitigate exposure by: (1) Conducting flight operations to and 

from helidecks and shore based heliports that meet or exceed size and weight requirements 

appropriate to the aircraft configuration; (2) Training its crews in a Level D, FFS (Full Flight 

Simulator) initially and annually, ensuring the highest levels of proficiency and competency; (3) 

Conducting route checks to confirm that its crews remain procedurally compliant and use crew 

resource management principles during all flight operation; and (4) Using Bristow U.S. LLC's 

Helicopter Flight Data Monitoring program (known as HFDM) to ensure flight profiles are in 

accordance with Performance Class 2 procedure. 

Bristow U.S. LLC has been informed that the FAA will rescind OpSpec HIOO. To date, Bristow 

U.S. LLC has accumulated over 9,565 hours of operational experience in this make and model. 

Meanwhile, Bristow Group, worldwide, has accumulated over 251,923 hours in the S-92A. All 

of our U.S. based operations that use the S-92A aircraft operate them in accordance with HlOO 

standards. This experience demonstrates that when takeoff and landing techniques are used to 

minimize exposure to forced landing due to define failure, that this aircraft can be operated at an 

equivalent level of safety to Category A. Additionally, without the exemption relief, because of 

the removal of OpSpec HI 00 it would become economically unfeasible to operate this aircraft 

which would likely result in their removal from service. Without the exemption relief, we would 

have to offer to our clients smaller, older, less sophisticated aircraft that do not provide the same 

level of safety. This would result in an overall degradation of safety and not serve the most 

important stakeholder, the passenger. 

Bristow U.S. LLC believes that granting of this petition would be in the public interest because 

the S-92A aircraft have replaced older designs which do not offer the same safety enhancements, 

and those aircraft are not required to meet the stringent performance requirements imposed on 

the S-92A and other similar aircraft. 
If I may be of further assistance in this matter or if you require additional information, please do 

not hesitate to contact me or the Bristow U.S. LLC office located in New Iberia, Louisiana. My 

email is don.robson@bristowgroup.com. 

cc: Robert Phillips 

lg