PETITION FOR EXEMPTION

Petitioner: Capt. Dana A. Raaz

VP / Director of Operations Era Helicopters LLC P

. O. Box 6550 Lake Charles, LA 70606 (337) 478

- 6131 draaz@erahelicopters.com Era Helicopters LLC (Era) presently own s and operate s over 170 helicopters worldwide and hold s FAA CFR part 133 and 135 certificates. Our operating specifications within the applicable certificates allow IFR, NVG, Air Medical and Extern al Hoist class D amongst others to sup port our daily operations throughout a variety of helicopter makes and models as specified within the limits of those operating specifications. We crew two dedicated 24 hr 365 days a year, Air Medical Search and Rescue AW139 helicopters with highly exper ienced pilots and medical crewmembers qualified under Era’s CFR part 135 and 133 training programs . The crew training program(s) include Air Medical specific training and the use of Night Vision Goggles (NVG). T raining curriculums for 24 hr hoisting o perations over fixed structures, vessels, offshore evacuation or water rescues have been completed and are maintained in a monthly currency program . The crewmembers co nsist of a five (5) person team; 2 pilots, an advanced life support paramedic, a hoist operator and a rescue swimmer. All medical crewmembers at a minimum are qualified emergency medical technicians. Additionally, the aircraft and pilots are qualified and current both for day and night, IFR and VFR fl ights and accept flight requests after completing a risk assessment
. Era is requesting an exemption from 14 CFR 133.45 (e) (1) for two (2) dedicate d Air Medical Search and Rescue AW

- 139 Helicopters servicing the oil and gas i ndustry both in domestic U.S. waters and International waters within the Gulf of Mexico basin. While all hoisting operations are conducted at sea level, there are circumstances where range and temperature limitations prevent single engine hover capability in the AW139. Currently hoisting operations are conducted at the minimum fuel load allowable to meet single engine hover requirement to conduct hoists. At the higher temperature ranges this can put the crews into a minimum reserve fuel situation; this adds a higher risk of potential fuel starvation and severely limits the level of response for which the industry is in desperate need. This is currently mitigated by maintaining the aircraft at the lowest available empty weight, maintaining on ly the critical equipment necessary onboard the aircraft, a very high l evel of training and currency of the crews, very specific planning and fine tuned adjustments when on scene with a site assessment of the situation or a flat out no -go for that mission. There are approximately 65 fu el sites throughout the several hundred square miles in the Gulf of Mexico that can support the AW139 Helicopter

. With larger helicopters, the fuel locations available would be dramatically reduced due to helideck weight and or dimension limitations. We believe the AW139 is the best helico pter for this service in the Gulf of Mexico

. T here are no commercially available h elicopters on the market today that can meet a 200 nm range and +2 0 degree Celsius temperature single engin e hover performance requirement that is needed for the offshore evacuation profile when human life or health is in jeopardy

. The two (2) AW139 aircraft requested for exemption are: N892SN, serial number 41244 and N385RH, serial number 41013.This proposed exemption, if granted, would provide the Oil and Gas Industry with an important

resource of Air Medical Search and Rescue Helicopters at critical time s of personal jeopardy . It would allow full fuel range for enroute to scene and time on station rescues, multiple hoisting rescues to be conducted in succession, rap id response times and by prov iding safe hoisting operations for evacuations on structures and or vessels that do not have helidecks, or situations where in the helideck may be fouled or where the helideck’ s maximum authorized landing weight is below the ope rating weight of the helicopter

. The Gulf of Mexico offshore oil and natural gas industry is instrumental to the United States both from an energy supply perspective and due to its contribution to U.S. GDP and job creation. In 2010, over 30 percent of the oil and 11 percent of the natural gas produced in the United States was produced in the Gulf of Mexico. The Gulf of Mexico has over 4000 fixed structures, employs approximately 175 ,000 people and maintains a vast supporting structure to conduct the necessary daily activities. As recently witnessed with the Deepwater Horizon explosion and tragedy, the need of Air Medical Search and Rescue aircraft is very evident. Era started Air Medical Search and Rescue operations with the AW139 in August of 201 0 and currently conducts, on average, 10 missions a month for a diverse group of oil and gas and service companies. The U.S. Coast Guard under the Homeland Security Agency currently provides federal enforcement and rescue mission capability in the Gulf of Mexico through three air stations; Corpus Christi , Tx, Houston , Tx and New Orleans, La. They utilize the H

- 65 “ Dauphine” Helicopter which is limited in range and in power . The H

- 65 cannot meet the single engine requirements of conducting hoi sting operations and have a max range of 125 to 150 nm

. With the offshore drilling in the Gulf of Mexico moving beyond the practical range of the Coast Guard helicopters assigned to this area and that emergency medical evacuation is not part of their mis sion profile, the oil and gas industry ha s taken it upon themselves to contract for larger helicopters with superior speed, range and full emergency medical response capabilities.
The Agusta

-Westland AW

- 139 helicopters have superior single engine hover performance and are FAA certificated to Category A performance criteria for Transport Category Helicopters

. The external hoist can be operated at a speed of up to 245 feet per minute with a load of > 250lbs on the hook (4 feet per second). If the weight is < 250lbs then the cable speed is 150 feet per minute. At an average hoist height of anywhere between 40

- 100 feet, thi s puts the patient and rescue specialist on the cable from hook

- up to cabin level in anywhere between 10

- 30 seconds. We view this tim e as the exposure time in a case of single engine failure. In a worst case scenario, with operating weights above the single engine hover performance weight, based on those hoisting heights and if a single engine failure were to happen at the time of hoi sting, it is projected that the aircraft would settle into the wate r, cushioned by the power of the remaining engine, after which the floatation equipment would be automatically deployed and crews evacuated into life rafts and await rescue. Any additional height gained by being over an elevated structure would be additional altitude to the hoist height to gain necessary airspeed to fly away single engine. Although Era is requesting an exemption to the single hover requirement, Era would maintain the appropriate operational weight at all times and would only go beyond that single engine hover weight at times where human life or health was in immediate jeopardy.
The AW

- 139’s are powered by Pratt & Whitney PT6

-67C engines. The P&W PT6 series turbo shaft engine ha s been around for more than 40 years and ha s earned an unequaled reputation for reliability. In the 40 million flight hours amassed on some 9,000+ engines they have a recorded in flight failure rate of 1 in 1,500,000 flight hours. Based on these superior reliability of the AW139 and Era’s highly qualified ,current and proficient crew members we believe an exemption to th e single engine hover capability

provision of 14 CFR 133.45 (e) (1) wou ld not adversely affect safety and overall less e n the total risk associated with operating at minimum reserve fuel should any unforeseen complications to the rescue arise. In researching past exemption grants, the Federal Aviation Administration issued a Grant of Exemption No. 6740, regulatory docket no. 28569, and exemption No. 7118 A, B, C, D, E, F, G, regulatory docket number 2002

- 11655, to another commercial helicopter operator for situations materially similar to the circumstances described in our request and the exemption of CFR 14 133.45 (e) (1)

. We see this as a solid basis to review and approve this petition for exemption. Era Helicopters seeks exemption from the single engine hover performance requirements of 14 CFR 133.45 (e) (1). This exemption would allow our Air Medical Search and Rescue AW139 aircraft to carry suitable mission fuel during the summer months, allowing Era to respond accordingly to the potentially life critical situation and meet the public interest in the Gulf of Mexico.