May 26,2015 

4 CORPORATE WAY 

MISSOULA, MT 59808 

406-544-0402 Phone 

406-728-2943 Fax 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

RE: Exemption Request for: 

Homestead Helicopters, Inc. 

4 Corporate Way 

Missoula, Montana 59808 

406-544-0402 Phone 

406-728-2943 Fax 

Air Carrier Certificate Number: HI OA429I 

This letter is to serve as an official request/application per the procedures stated in 14 

CFR 11.61 through 14 CFR 11.103 for an exemption from 14 CFR 43.3(h) and (i) for 

approval to allow pilots to be able to remove/reinstall doors on helicopters while in field 

conditions. 

Homestead Helicopters, Inc. seeks relief from these regulations by adding the ability to 

have a properly trained pilot remove/reinstall doors in the field due to the nature of our 

helicopter missions. Granting this request would be in the public interest and would 

benefit the public as a whole because we often perform many jobs that require the 

removal and reinstallation of the crew/passenger doors (as allowed by the Helicopters 

manufacturers Flight Manual) for a multitude of missions to include but not limited to: 

Fire Fighting Operations, Search and Rescue, Lidar Power Line Patrols/Survey, 

Photography, Filming, External Load Operations, Survey/Mapping, and Patrol work. 

The ever changing environment (weather) and nature of our missions demand that we 

have the flexibility to be able to remove or reinstall doors while out in the field and away 

from the home base where our mechanics are stationed. It is not possible to travel with a 

mechanic on board the helicopters at all times when door removal might be required. An 

example of this is initial attack fire operations. We fly detection flights in our helicopters 

with a full complement of fire fighters on board searching for smoke or signs of a fire. 

We do this with the doors on because removing the doors reduces our VNE per the RFM 

thus reducing the effective range we can cover as well as protects the occupants from any 

inclement weather and wind that might be encountered. When we find a fire, we assess 

the tactic and begin fire suppression operations. This requires the pilots door to be 

removed so the pilot can look out and below the helicopter utilizing vertical reference 

using a long line and operate a bambi bucket delivering water and/or retardant or 

additional fire suppression supplies in support of the ground forces. We are typically in 
i 

I 

I 

-1 

remote areas away from any mechanics. This is just one of the many fire missions that 

require the doors to be removed and/or reinstalled. 

There are also dozens of other operations that require door removal while away from our 

home base and while operating in remote locations. This includes operations such as; 

power line inspections, photography, survey, animal herding, and search and rescue. The 

nature of a helicopter is to use this machine to access remote areas and to perform 

operations/jobs in areas where no other vehicle can travel or offer the unique visibility or 

access that a helicopter can. This usefulness includes removal/reinstallation of the doors. 

Helicopters are weight sensitive and having to travel with a mechanic to remove/reinstall 

the doors would be a huge disadvantage to our operation. This would not only take away 

the limited payload that we have, causing us lost revenue or perhaps restrict us from even 

being able to perform the mission but would also add to the risk/complexity of our 

missions especially in our high altitude mountainous environment. 

I believe this type of mechanical action falls under the same clarifications and complexity 

as the preventative maintenance items as listed in 14 CFR 43 Appendix A (c) or 14 CFR 

43.3 (h) rotorcraft operating in remote areas and granting this exemption would not 

adversely affect safety. Pilots have been removing doors on helicopters since their 

inception. The doors are considered removable items. Doors off operations are approved 

and any operational changes are addressed in the Rotorcraft Flight Manual. The doors 

are designed to be removed easily with limited tools as delivered from the manufacturer; 

however, Homestead Helicopters, Inc. has installed Meeker Aviations FAA Approved 

STC SR00532SE Quick Release door pins (STC Attached to this letter) on all of our 

helicopter doors simplifiing the removal/installation process and eliminating any use of 

tools in order to provide a level of safety not only equal, but greater than that provided by 

the rule from which we seek the exemption. Homestead Helicopters, Inc. has also written 

a training program on the removal and installation of helicopter doors utilizing the 

Meeker STC Door Pins (See attached Training Program). Every pilot employed by 

Homestead Helicopters, Inc. must be given this training annually and have it documented 

in their training folder (See Manuals and Training Receipt Form attached). 

If granted, Homestead Helicopters, Inc. would like to request exercising the privileges of 

this exemption outside of the United States because our Authorized Areas of En Route 

Operations in our 135 Operation Specifications (B050-1) include Canada and Mexico. 

HHI also has several contracts for Fire Fighting with both Federal and State agencies that 

require operations in Canada and Mexico. 

Thank you for your assistance with this matter. I look forward to hearing from your 

office. 

~J;;j)J Todd M. Donahue 

President 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

February 18, 2015 

Northwest Mountain Region 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

Mr. Todd M. Donahue, Director of Operations 

Homestead Helicopters, Inc. 

4 Corporate Way 

Missoula, Montana 59802 

Dear Mr. Donahue: 

Federal Aviation Administration 

Flight Standards District Office 

2725 Skyway Drive, Suite 1 

Helena, Montana 59602-1213 

(406) 449-5270, Fax: (406) 449-5275 

1-800-457-9917 

This office has received a legal interpretation regarding ·pilot-performed maintenance, which 

specifically addresses the removal and installation of doors or dual controls on an aircraft 

operated under Title 14 of the Code of Federal Regulations (14 CFR) part 135. An 

extraction of this formal legal clarification follows: 

14 CFR section(§) 43.3(h) allows a Part 135 certificate holder, who operates rotorcraft in a 

remote area, to train and allow the pilot to perform specific preventive maintenance items, 

provided the items of preventive maintenance are a result of a known or suspected 

mechanical difficulty or malfunction that occurred en route to or in a remote area. This 

regulation does not apply for the "removal and reinstallation of doors and dual controls" 

because these items are not a simple or minor preservation operation, and are not listed as 

preventive maintenance in Appendix A of Part 43. In addition, neither of these tasks could 

be considered the result of a known or suspected mechanical difficulty or malfunction that 

occurred en route to or in a remote area. 

14 CFR § 43.3(i) allows a pilot of a Part 135 certificate holder, who is operating an aircraft 

type certificated for nine (9) or fewer passenger seats, to perform the removal and 

reinstallation of approved aircraft cabin seats, approved cabin-mounted stretchers, and 

when no tools are required, approved cabin-mounted medical oxygen bottles. Tins 

regulation also does not apply for the "removal and installation of doors and dual controls" 

because these neither of these tasks is included in the maintenance tasks that are listed. 

In FAA guidance related to this matter, Order 8130.2G, Paragraph 210, "Operation of a 

Civil Aircraft with a Door Open or Removed for Parachuting, Skydiving, or other Special 

Operations", subparagraph (e) stipulates that, "Removal or installation of a cabin door for 

the specialized aircraft is considered maintenance and as such must be accomplished by 

persons authorized under 14 CFR part 43." 

To summarize, 14 CFR § 43.3(h) and§ 43.3(i) provide relief for Part 135 pilots to perform 

limited preventive maintenance and installation and removal of seats, stretchers, and medical 
oxygen bottles. The pilots must be trained and the certificate holder must have written 

procedures to accomplish the tasks. 

2 

Therefore, based on our belief that the potentially safety-sensitive tasks of installing a door 

or dual controls in an aircraft is a form of maintenance, these tasks cannot be performed by a 

pilot on an aircraft which is operated under 14 CFR part 135 without an approved 

exemption. Please reference the procedures stated in 14 CFR §§ 11.61 through 11.103 if 

you wish to apply for an exemption, and show the equivalent level of safety. 

If you have any questions or comments regarding this interpretation, please feel free to 

contact me at (406) 449-5270, extension 42. Our office is open from 7:30a.m. to 4:00p.m., 

Monday through Friday. 

Sincerely, 

(t' fJ .. {t·h1L--

Tin1o;c W. M;;kle 

Aviation Safety Inspector 
HOMESTEAD HELICOPTERS, INC 

QUICK RELEASE DOOR PINS 

DOOR PIN BUTTON 

DOOR HINGE 

SAFETY PIN ,__.. 0 

MEEKER AVIATION/ CERTIFIED TECHNOLOGY STC SR00532SE 

NOTE: Before removing any door, be sure you have prepared the area to receive the door and that 

nothing is within that area may damage the door if transported. Also be sure the interior of the aircraft 

is clean and free of loose items. 

Door Removal: 

1. Firmly grasp door and locate lower door pin. Remove safety pin by lifting, moving laterally and 

pulling the safety pin from door pin. 

2. On the same pin, find the door pin button. Depress door pin button while pulling door pin strait 

up and out of the door hinge. 

3. Repeat step 1 and 2 for upper pin. 

4. When the door is removed from the helicopter, replace pins back in original holes to prevent 

damage to the door. 

REFERENCE THE APPROPRIATE SECTIONS OF THE ROTORCRAFT FLIGHT MANUAL 

Door Installation: 

1. Remove both upper and lower door pins from the door to be installed. 

2. Carefully place door on the helicopter in the appropriate position. 

3. Place both upper and lower door pins through hinge of door and helicopter. 

4. Install safety pin on bottom of door pin for security. 

5. Be sure door operates smooth and closes properly. 

qEFERENCE THE APPROPRIATE SECTIONS OF THE ROTORCRAFT FLIGHT MANUAL 
HOMESTEAD HELICOPTERS, INC 

QUICK RELEASE DOOR PINS 

DETAIL A 

1. Crew door 

2. Edging 

3. Upper window 

4. Lower window 

5. Track 

6. Exterior handle 

7. Lock 

8. Door seal 

9. Window handle 

10. Window seal 

11. Sliding window 

12. Shim 

13. Screw 

14. Thin aluminum washer 

15. Hinge half 

16. Nut 

17. Hinge half 

18. Shim 

19. Nut plate 

20. Rivet 

~14 Replaced 16 ~ by Quick 

Release 

Pins 

10 

9 

SEE DETAIL A 

Figure 52-3. Crew doors 

BHT -206L4-MM-5 

206L4-M-52·3 

52·00-00 

Page 11 
HDMEST£40 4 CORPORATE WAY 

~ 

• ~ MISSOULA, MT 59808 

406-544-0402 Phone 

~.. ~-~~ 406-728-2943 Fax 

eJicoptets. \~ 

Manuals & Training Receipt Signature Form 

I acknowledge receipt of the following HHI company manuals: 

1. Company Operations Manual 

2. Company Rotorcraft External Load Combination Manual 

3. Company FAR Part 133,135,137 Operations Specifications 

4. Company Alcohol and Drugs Policies Employee Manual 

I have read and understand the above Company Manuals. I further agree to comply with 

all company policies and procedures listed in the above manuals. 

I also acknowledge that I have received training on the following HHI company 

programs, policies, and procedures: 

CHECKOFF ALL THAT APPLY: 

D 1. Company Alcohol and Drugs Substance Abuse Policy 

D 2. Company Alcohol Misuse Prevention Program 

D 3. Company FAR Part 133 "Will Carry" HazMat Training 

D 4. Company FAR Part 135 "Will Not Carry" HazMat Training 

D 5. Engine & Transmission Chip Plug Inspection 

D 6. BHT 206 Series 50 Hour Lubrication 

D 7. Replacing Defective Safety Wire & Cotter Pins 

D 8. Door removal and installation 

D 9. Replacing Landing & Position Lights 

D 10. Fire Extinguisher Monthly Inspection Procedure 

Signed (Employee) Witness (Company Representative) 

Date Date 

Printed Name Printed N arne & Title 
3!tnit& ~rt ~ 

~·n.f ~1JTibttal. ~ »mit1fstralftm, 

hpplttntntal mtWt <tttrttfimtt 

Jli~, SR00532SE 

Certified Technology 

3080 Thorntree Dr. #125 

Chico, CA 95973 

ce..P&r/&ed doc de~ tn de {Wze dB.11f:afo de fil'&-~~6 wd ~ ltnuUdionJ and atm/i~ 

derefo ad ~or/kdl!ueonmat.1 6M tW-UX#'dme# ~~ o/fJOIU'6 * o/de * ~a/"ttJ.n,j. 

&',~fYJ,o-dao&-. ~ ~.r6~.A/unu!'er..· 

~-· 

~I! 

*See attached FAA Approved Model List (AML) 

No. SR00532SE for list of approved rotorcraft models 

and applicable airworthiness regulations 

9lJe3o..P~ o/&~ ~ 9lJe3t?z ~~-· lnstallation of Certified Technology, Inc. quick release door pins in 

accordance with Certified Technology Drawing list CT9801, Revision New Release, dated June 3, 1998. 

5anua&?tm:J and ~t'H'ltiukHzd.- Approval of this change in type design applies to the rotorcraft models listed on 

the AMP only. This approval should not be extended to other aircraft of this model on which other previously 

approved modifications are incorporated unless it is determined that the relationship between this change and 

any ofthoseother previouslyapproved modifi.cations, including changes in type design, will introduce no adverse 

effect upon the airworthiness of that aircraft. A copy of this Certificate and FAA Approved Model list {AML) No. 

SR00532SE must be maintained as part of the permanent records for the modified aircraft. 

If the holder agrees to permit another person to use this certificate to alter the product, the holder shall 

giVfil the other personwritten evidence Of that permission. 

5Z:.1 ce.r6~ and~ :1~6~ clat"a w~ 6:1 ~ tf'adu ~, ~ua/':1//alr .re/TtlZVt m #o6 £Uttt"f 

3an-endenx( 3a~ .re~ tY-/' a; ~iOn date 6:1 u-denu£:Je edWifd~.lp ~ d'dnvu:J~o/~ 

:/;ck,dslv-tat"hn-.#dnvtidhYd&on-. 

May 18, 1998 

July 1, 1998 

Any alteration of this certificate is punishable by a fine of not 

exceeding $1,000, or imprisonment not exceeding 3 years, or both. 

FAA FORM 8110·2{10·68) 

October 30, 2000 

This certificate may be transferred in accordance with FAR 21.47. 
AIRCRAFT AIRCRAFT 

MODEL 

1 Bell Textron 206, 206A, 

206A-l, 206B, 

. 206B-l, 206L, 

206L-1, and 

206L-3 

2 Bell Textron 206L-4 and 407 

CERTIFIED TECHNOLOGY, INC. 

FAA APPROVED MODEL LIST(AML) NO. SR00532SE 

FOR 

INSTALLATION OF QUICK RELEASE DOOR PINS 

Original Is

ORIGINAL CERT.BASIS FAA SEALED REVISION FAA A

TYPECERT. FOR DRAWING/ NO. AND INSTA

NO. ALTERATION DRAWING LIST DATE INSTR

NO. NO. & 

H2SW CAR6 CT9801 New Release CT980

(SeeH2SW) June 3, 1998 dated J

H2SW Part27 CT9801 New Release cT9sot

(See H2SW) June 3, 1998 dated J

fO· · 

~anager, ~p 

~ Seattle Aircraft Certificatio

Page 1 of 1 
Meeker Aviation Services LTD 

#206 19142 122nd Ave. 

Pitt Meadows, BC V3Y1 P9 

Canada 

Certificate of Compliance 

We hereby certify that the parts/materials contained within the kits as designated as 206 (PN 9801300) I 

206 L(PN9801301) /407 (9801302) Quick Release Door Pins under STC SR00532SE are in full accordance with 

the requirements, specifications and drawings__cgvering these items. 

·7 ~~ ...... / 

~~ Dat 

CertifiedTechnology/Library/Forms/CertificateofCompliance.doc 
Cld 

Certified Technology, Inc. 

3080 Thorntree Drive #95 

Chico, CA. 95973 

530-897-0369 Voice 

530-897-0378 Fax 

Homestead Helicopters 

Todd Donahue 

4 Corporate Way 

Missoula, MT 59808 

406-544-0402 

Re: STC SR00532SE 

Mar. 24, 2015 

This letter constitutes permission for Homestead Helicopters to use STC SR00532SE for the installation of the 

2061206U407 Series quick release door pin kits.