•• = s. =• • r1stow March 5, 2015 Docket Management Facility US Department
of Transportation 1200 New Jersey Avenue 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 expo

s ure to engine failure. We have operated our U.S

.based

S -92A aircraft under operations specifica

t ion (OpSpec) H-100

s i n c e 2008. When renewed the exemption extends
to our certificate operations conducted outside the United States when applicable

. Bristow

U

.S .LL C 46051ndustrial Drive

.Ne w Iber

i a, L o ui s

i ana 70560

,Un

i ted States

t (337) 365 6771

f (337) 365 6152 br

i stowgroup

.comWe believe that the request
to renew the exemption will allow us to continue

to provide the same level of safety that is currently
in p l ace for our offshore operations. Under current Bristow U.S. LLC usage of the S-92A aircraft, we have collected data related to the engine reliability and it shows that we have never had an inflight shutdown of an engine in 9,565 hours operated. Bristow U.S. LLC has operated under OpSpec HlOO in the United States since 2008 which 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
t o 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 operat

i onal 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 techn

i ques 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. Add

i tionally

,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 exempt

i on relief

,we would have to offer to our clients smaller, older, less sophist

i c a ted aircraft that do not provide the same level of safety

.This would result in an o verall

d egrada tion of safety and not serve the most important stakeholder

,the passenger. Bristow
U

.S .LLC believes that grant

i ng of this petition would be in the public interest becaus

e the S -92A
a ir craft have rep
l aced older designs wh
i ch do not offer the same safety enhancement

s , and those aircraft are not required
to meet the stringent performance requirements imposed on the S-92A and other similar aircraft.In closing, another United States helicopter operator,whousesthe S-92A, petitionedandwas grantedanexemption (No. 10507) to OpSpecHIOO. Bothofourcompanies S-92Aaircraft operate dailyinthesameenvironment, flyingthesamemissionsand flight profiles.Weserv

ice thesameclientsinsomecases,andlandandtakeofffromthesameorlikelocations.Wetrainat thesameFFS (Full Flight Simulator) facilityand byall accounts,havetheexactlevelof experience withthe S-92Aaircraftbasedonourfleetsize. IfI maybeoffurther assistance

inthismatterorif yourequire additional information, pleasedo nothesitate
tocontactmeortheBristow U.S.LLCofficelocated
inNew Iberia, Louisiana. My emailis don.robson@bristow

group.com. cc:Robert Phillips lg