BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, DC
In the matter of the cancellation of the Air Taxi authority issued to: VIH COUGAR HELICOPTERS, INC. ) ) ) ) ) ) ) ) ) Docket DOT - OST - 2012 - 0022

MOTION OF PETROLEUM HELICOPT ERS, INC. NORTHERN PIONEER HELICOPTERS LLC AND SOLOY HELICOPTERS LLC TO WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE

Communications with respect to this document should be sent to: John L ongstreth john.longstreth@klgates.com 202
- 661
- 6271 Timothy H obbs tim.hobbs@klgates.com 206
- 370
- 7664 K&L Gates LLP 1601 K Street NW Washington, DC 20006

- 1600 202
- 778
- 9100 (fax)1 BEFORE THE DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, DC
In the matter of the cancellation of the Ai r Taxi authority issued to: VIH COUGAR HELICOPTERS, INC. ) ) ) ) ) ) ) ) ) Docket DOT - OST - 2012 - 0022

MOTION OF PETROLEUM HELICOPTERS, INC. NORTHERN PIONEER HELICOPTERS LLC AND SOLOY HELICOPTERS LLC TO WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE Pursuant to Rule 12 of the Department’s Rules of Practice, 14 C.F.R. § 302.12, Petroleum Helicopters, Inc. (“PHI”), Northern Pioneer Helicopters LL C (“Northern”) and Soloy Helicopters LLC (”Soloy”) hereb y m ove to withhold from public disclosure the unredacted O pposition of Petroleum Helicopters, Inc., Northern Pioneer Helicopters LLC, and Solo y Helicopters LLC to VIH Cougar Helicopters, Inc. and Construction Helicopters, Inc.’s Motion for Reconsideration of Final Order and for a Hearing filed in this docket on July 12, 2013. The motion is necessary because the Motion contains information that has been designated as confidential b y V IH Cougar. In filing this motion, movants do not concede that any of that material has been properl y designated as confidential. Movants believe that the information on which this pleading relies and an y other information on which VIH Cougar has relied in responding to the Department’s Order to Show Cause and in responding to Movants’ Motion for Final Disposition in this matter sho uld be made public. As Movants have previously pointed out, VIH Cougar has previously2

filed in the pubic docket information it has designated as purportedly confidential, and its lack of any principled and consistent basis in treating its designated material as confidential is itself a basis to make this information public, as it suggests VIH Cougar’s goal is more to disrupt to the proceeding and Movants’ ability to respond than it is to protect any legitimately confidential information. A redacted versi on of the Response has also been filed electronically in the docket, which public filing does not contain any of the material that has been designated as confidential.
Respectfully submitted, _______/s/_______________ John L ongstreth Timothy Ho bbs K&L Gates LLP 1601 K Street NW Washington, DC 20016 Counsel for Petroleum Helicopters, Inc. Dated: July 12, 20133 CERTIFICATE OF SERVICE I certif y that I have on this 12 th day of July , 2012 served the foregoing Motion to Withhold Materials from Public Disclosure upon the persons listed below, and have also filed a cop y electronically in the docket of this proceeding: Susan L . Kurland Office of the Assistant Secretary for Aviation and International Affairs U.S. Department of Transportation 1200 New Jersey Avenue, SE Room W96
- 495 Washington, DC 20590 Laural yn Remo Office of the Assistant Secretary for Aviation and International Affairs U.S. Department of Transportation 1200 New Jersey Avenue, SE Room W96
- 495 Washington, DC 20590 Peter Lync h, AGC

- 300 Asst. Chief Counsel for Enforcement Federal Aviation Administration 800 Independence Ave. SW Washington, DC 20591 William J. Weber Certification Section Manager FAA AFS
- 900 45005 Aviation Drive Suite 131 Dulles, VA 20166 Roy Hardie Aviation Sa fety Inspector Federal Aviation Administration 1601 L ind Avenue SW, Suite 260 Renton, W A 980574

David M. Nadler David Y. Yang Andrew E. Smith DI CKSTEIN SHAPIRO LLP 1825 Ey e Street, NW Washington, DC 20006 Telephone: (202) 420

- 2200 Facsimile: (202) 420

- 220 1 nadlerd@dicksteinshapiro.com yangd@dicksteinshapiro.com smitha@dicksteinshapiro.com Counsel to VIH Cougar Helicopters, Inc.

________/s/______________________ John L ongstreth