_____________________________________________________________________________________ Era Helicopters LLC • 600 Airport Service Road • PO Box 6505 / 70606 • Lake Charles, LA 70605 • 337.478.6131

www.erahelicopters.com

May 3, 2013

US Department of Transportation

Docket Management System

400 7 th Street, SW, Room PL 401

Washington, DC 20591

‐ 0001

Subject: In accordance with 14 CFR Part 11, Era Helicopters LLC petitions for exemption from 14

CFR Part 91.9(a) to allow operations in the Eurocopter EC

‐ 225 aircraft when operating

between land

‐ based and offshore facilities or when operating between two offshore

facilities.

1. The EC

‐ 225 was certified under Part 29, amendment 47 relating to safety and ditching

equipment, which provides the highest level of safety. The EC

‐ 225 aircraft are equipped with

aircraft floatation gear and are certified for ditching in up to sea state 6. Additionally, when

operating over water, each occupant is provided, and wears, personal floatation equipment.

Also, the EC

‐ 225 is equipped with life rafts that can be deployed from inside or outside the

aircraft.

2. European operators, using the same aircraft, operate them in accordance with Joint Aviation

Requirement OP

‐ 3 which already permits similar operations with limited exposure to engine

failure. In additions the EC

‐ 225 has operated under operations specification (Op Spec) H

‐ 100

since 2004. Era Helicopters requests this exemption be extended for operations conducted

outside the United States.

3. Era Helicopters believes the same level of safety will be provided currently in place for off shore

operations. This belief is supported by the data collected reflects less than 5 engine inflight shut

downs per 1,000,000 flight hours.

4. Era Helicopters has operated under Op Spec H

‐ 100 in the United States since 2004 which

authorized operations similar to International Civil Aviation Organization (ICAO) Performance

Class 2 with limited exposure. During this period, no EC

‐ 225 accidents have been caused by

power loss due to engine failure during takeoff or landing.

5. Era Helicopters has instituted operational controls through its general operations manual,

training program, and management surveillance. Era 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 150 feet per minute 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.6. Era Helicopters further mitigates 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 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 operations; and (4) Using Era’s Flight

Operations Quality Assurance (FOQA) Program to ensure flight profiles are in accordance with

Performance Class 2 procedures.

7. Era understands the FAA his issued notice to rescind Op Spec H

‐ 100. Era has accumulated over

4000 hours of operational experience in the EC

‐ 225 all in accordance with Op Spec H

‐ 100 and

Performance Class 2 profiles. This experience demonstrates that when takeoff and landing

techniques are used to minimize exposure to forced landing due to engine failure, that this

aircraft can be operated at an equivalent level safety to Category A. The rescission of H

‐ 100 will

make the EC

‐ 225 economically unfeasible, forcing its removal from service. This removal from

service will force the use of smaller, older, and 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.

Regards,

Stephen P. Smeltzer Jr.

Director of Operations