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 owns and operates over 170 helicopters worldwide and holds FAA 

CFR part 133 and 135 certificates. Our operating specifications within the applicable certificates allow 

IFR, NVG, Air Medical and External Hoist class D amongst others to support 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 experienced 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). Training curriculums for 24 hr hoisting operations over fixed 

structures, vessels, offshore evacuation or water rescues have been completed and are maintained in a 

monthly currency program. The crewmembers consist 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 flights and accept flight requests after completing a risk 

assessment.

Era is requesting an exemption from 14 CFR 133.45 (e) (1) for two (2) dedicated Air Medical Search and 

Rescue AW-139 Helicopters servicing the oil and gas industry 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 

only the critical equipment necessary onboard the aircraft, a very high level 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 fuel 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 helicopter for this service in the Gulf of 

Mexico. There are no commercially available helicopters on the market today that can meet a 200 nm 

range and +20 degree Celsius temperature single engine 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 times 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, rapid response times and by providing safe hoisting operations for evacuations 

on structures and or vessels that do not have helidecks, or situations wherein the helideck may be 

fouled or where the helideck’s maximum authorized landing weight is below the operating 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 2010 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 hoisting 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 mission profile, the oil and gas industry has 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, this puts the patient and rescue specialist on the cable from 

hook-up to cabin level in anywhere between 10-30 seconds. We view this time 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 hoisting, it is projected that the aircraft would settle into the water, 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 

has been around for more than 40 years and has 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 the single engine hover capability 

provision of 14 CFR 133.45 (e) (1) would not adversely affect safety and overall lessen 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.