### May 26,2015 4 CORPORATE WAY MISSOULA, MT 59808 406-544-0402 Phone 406-728-2943 Fax


### U.S. Department ofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 NewJersey 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: HIOA429I This letter is to serve as an official request/application perthe procedures stated in 14 CFR 11.61 through 14 CFR 11.103 for an exemption from 14 CFR43.3(h) and (i) for approval to allowpilots to be able to remove/reinstall doors onhelicopters while in field conditions. Homestead Helicopters, Inc. seeks relieffrom these regulations by adding the ability to have a properlytrained pilotremove/reinstall doors inthe field due to the nature ofour helicopter missions. Granting this request would be inthe public interest and would benefit thepublic as a whole because we oftenperform manyjobsthat require the removal andreinstallation ofthe crew/passenger doors (as allowed bythe Helicopters manufacturers FlightManual) for a multitude ofmissions to include butnot limited to: Fire Fighting Operations, Search and Rescue, Lidar PowerLine Patrols/Survey, Photography, Filming, External Load Operations, Survey/Mapping, and Patrol work. The ever changing environment (weather) and nature ofour missions demand that we have the flexibility to be able to remove orreinstall 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 onboardthe helicopters at all times when door removal might berequired. An example ofthis is initial attack fire operations. We fly detection flights in ourhelicopters with a full complement offire fighters onboard searching for smoke or signs ofa fire. We do this withthe doors onbecause removing the doors reduces our VNE perthe RFM thus reducing the effective range we can cover as well as protects the occupants from any inclement weather and wind that mightbe encountered. When we find a fire, we assess the tactic andbegin fire suppression operations. This requires the pilots door to be removed so the pilot can look out and belowthe 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 ofthe ground forces. We are typically ini I I -1 

### remote areas away from any mechanics. This isjustone ofthe many fire missions that require the doors to be removed and/or reinstalled. There are also dozens ofother 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 ofa 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 ofthe doors. Helicopters are weight sensitive and having to travel with a mechanic to remove/reinstall the doors wouldbe a huge disadvantage to our operation. This would not only take away the limited payload that we have, causing us lost revenue orperhaps restrict us from even being able to perform the mission but would also add to the risk/complexity ofour missions especially in our high altitude mountainous environment. I believe this type ofmechanical 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 beenremoving doors onhelicopters since their inception. The doors are considered removable items. Doors offoperations 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 ofour helicopter doors simplifiing the removal/installation process and eliminating any use of tools in order to provide a level ofsafety 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 onthe removal and installation ofhelicopter 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). Ifgranted, Homestead Helicopters, Inc. would like to request exercising the privileges of this exemption outside ofthe United States because our Authorized Areas ofEnRoute Operations in our 135 Operation Specifications (B050-1) include Canada and Mexico. HHI also has several contracts for Fire Fighting with bothFederal and State agencies that require operations in Canada and Mexico. Thank you for your assistance withthis matter. I look forward to hearing from your office.



# ~J;;j)J Todd M. Donahue PresidentU.S. Department of Transportation Federal Aviation Administration February 18, 2015 NorthwestMountain Region Colorado, Idaho, Montana, Oregon, Utah, Washington, Wyoming

Mr. Todd M. Donahue, Director ofOperations 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 interpretationregarding·pilot-performed maintenance, which specifically addresses theremoval and installation ofdoors or dual controls on an aircraft operatedunder Title 14 ofthe Code ofFederal Regulations (14 CFR) part 135. An extraction ofthis formal legal clarification follows: 14 CFRsection(§) 43.3(h) allows a Part 135 certificate holder, who operatesrotorcraftin a remote area, to train and allowthe pilotto perform specific preventive maintenance items, providedthe items ofpreventive maintenance 

### are a result of a known orsuspected mechanical difficulty or malfunction that occurreden route to or in a remote area. This regulation does not apply for the "removal andreinstallation ofdoors and dual controls" because these items are not a simple or minorpreservation operation, and are not listed as preventive maintenance in Appendix A ofPart43. In addition, neither ofthese tasks could be considered the result ofa known or suspectedmechanical difficulty or malfunctionthat occurred enroute to orin a remote area. 14 CFR § 43.3(i) allows apilot ofa Part 135 certificate holder, who is operating an aircraft type certificated for nine (9) or fewer passenger seats, to performthe removal and reinstallation of

### approvedaircraft cabin seats, approvedcabin-mountedstretchers, and when no tools are required, 

### approvedcabin-mountedmedical oxygen bottles. Tins regulation also does not apply for the "removal and installation ofdoors and dual controls" because these neither ofthese tasks is included in the maintenance tasks that are listed. In FAA guidance related to this matter, Order 8130.2G, Paragraph 210, "Operation ofa Civil Aircraft with a Door Open orRemoved for Parachuting, Skydiving, or other Special Operations", subparagraph (e) stipulates that, "Removal or installation ofa cabin door for the specialized aircraft is considered maintenance and as suchmustbe accomplishedby persons authorized under 14 CFRpart43." To summarize, 14 CFR § 43.3(h) and§ 43.3(i) provide relieffor Part 135 pilots to perform limited preventive maintenance and installation and removal ofseats, stretchers, and medicaloxygen bottles. Thepilots must betrained and the certificate holder musthave written procedures to accomplishthe tasks. 2

Therefore, based on our beliefthatthe potentially safety-sensitive tasks ofinstalling a door or dual controls in an aircraft is a form ofmaintenance, thesetasks cannotbe performed by a pilot on an aircraft whichis operated under 14 CFRpart 135 without an 

### approved exemption. Please referencetheprocedures stated in 14 CFR §§ 11.61 through 11.103 if you wish to apply for an exemption, and showthe equivalentlevel ofsafety. Ifyou 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 throughFriday. Sincerely,



# (t'fJ
..{t·h1L-- Tin1o;cW. 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 iftransported. Also be sure the interior ofthe 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 ofthe 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

DETAILA 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. Nutplate 20. Rivet**~14** Replaced 16**~** by Quick Release Pins

10 9

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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

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### Manuals & 

### TrainingReceipt Signature Form I acknowledge receipt ofthe following HHI company manuals: 1. Company Operations Manual 2. Company Rotorcraft External Load Combination Manual 3. Company FARPart 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 onthe 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 FARPart 135 "WillNot 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 & 

### PositionLights D 10. Fire Extinguisher Monthly Inspection Procedure Signed (Employee) Witness (Company Representative) Date Date Printed Name PrintedNarne & 

### Title3!tnit&

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**~~-·** lnstallation ofCertified Technology, Inc. quick release door pins in accordance with Certified Technology Drawing list CT9801, Revision New Release, dated June 3, 1998.
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**~t'H'ltiukHzd.-** Approval ofthis change in type design applies to the rotorcraft models listed on the AMP only. This approval should not be extended to other aircraft ofthis 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 ofthat aircraft. A copy ofthis Certificate and FAAApproved Model list {AML) No. SR00532SE must be maintained as part ofthe permanent records for the modified aircraft. Ifthe 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. 

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Any alteration of this certificate is punishable by a fine of not exceeding $1,000, orimprisonment not exceeding3 years, orboth.
FAA FORM 8110·2{10·68) October 30, 2000

This certificate may be transferredin 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 - **~-_J- -~---1-**  CERTIFIED TECHNOLOGY, INC.

FAA APPROVED MODEL LIST(AML) NO. SR00532SE FOR INSTALLATION OF QUICK RELEASE DOOR PINS Original Issue: July 1, 1998

ORIGINAL CERT.BASIS FAA SEALED REVISION FAA APPROVED AML
TYPECERT. FOR DRAWING/ NO. AND INSTALLATION AMENDMENT

NO. ALTERATION DRAWING LIST DATE INSTRUCTIONS DATE

NO. NO. & REV. DATE

H2SW CAR6 CT9801 New Release CT9801-1, Revision-, N/A
(SeeH2SW) June 3, 1998 dated June 2, 1998

H2SW Part27 CT9801 New Release cT9sot-1!

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(See H2SW) June 3, 1998 dated June 2 998

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Seattle Aircraft Certification! Office

Page 1 of 1 '

# MeekerAviation Services LTD #206 19142 122nd Ave. Pitt Meadows, BC V3Y1 P9 Canada


# Certificate of Compliance We herebycertifythatthe parts/materials contained within the kits as designated as 206 (PN 9801300) 

### I 206 L(PN9801301)/407 (9801302) Quick Release Door Pins underSTC SR00532SE are infull accordance with the requirements, specifications and drawings__cgvering these items. 

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CertifiedTechnology/Library/Forms/CertificateofCompliance.doc

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Certified Technology, Inc. 3080 Thorntree Drive #95 Chico, CA. 95973 530-897-0369 Voice 530-897-0378 Fax

Homestead Helicopters Todd Donahue 4CorporateWay 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 2061206U407Series quick release door pin kits.