Dana Raaz

I have read the letter written by Mr. Jeffery Trang with American Eurocopter. I note that it was submitted after the closing date of 24 Oct 2011. I have also been informed by a representative of American Eurocopter that an FAA representative contacted Mr. Trang and requested he submit a comment. This seems somewhat unusual to me. I have also read the comments posted by Mr. Burl Brim, Jr.. Mr Brim is misinformed in many areas. He claims that the Coast Guard operates HH-60 Jayhawks in the Gulf of Mexico which can accomplish this mission. He is mistaken. There are no Operational Jayhawk units in the Gulf of Mexico. The Coast Guard uses short-range H-65 Dolpins for Search and Rescue along the Gulf Coast. Mr. Brim also states that other commercially available aircraft can meet the requirements of 133.45 (e)1 and the only reason Era requested an exemption was because we operate the AW-139. He is mistaken again. The AW-139 was selected by Era because it can meet the requirements of 133.45(e) 1 more often than other available aircraft, including the Sikorsky S-92 and the EC-225. I find Mr. Brul's position that Era is sacrificing safety by using the AW-139 for this type of mission when his organization apparently carries human external cargo with single-engine helicopters on a routine basis.