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October 11,2011 

U.S. Department of Transportation 

Docket Management System 

400 7* Street, SW., Room PL 401 

Washington, DC 20591-0001 

FAA Exemption Section 

Request for re-issuance/continued use of Exemption 8697B, Docket No. FAA-2005-2131 

1. Exemption 8697B is due to expire on March 31, 2012; Prism HeJicopters respectfiiJJy 

petitions for re-issued /continue to use the same exemption when Exemption 8697B 

expires on or about March 31, 2012. Prism Helicopters requests no further changes 

to exemption 8697B. 

2. Section 43.3(g) prescribes, in pertinent part, that: 

(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate 

issued under part 61 may perform preventive maintenance on any aircraft owned 

or operated by that pilot which is not used under part 121, 129, or 135 of this 

chapter. 

Section 43.7(f) prescribes, in pertinent part, that: 

(f) A person holding at least a private pilot certificate may approve an aircraft for 

return to service after performing preventive maintenance under the provisions of 

§43.3(g). 

Section 135.443(b)(3) prescribes that, for airworthiness release or aircraft 

maintenance log entry: 

(b) The airworthiness release or log entry required by paragraph (a) of this 

section must -

(3) Be signed by an authorized certificated mechanic or repairman, 

except that a certificated repairman may sign the release or entry only for the 

work for which that person is certificated. 

Requestor: Prism Helicopters Inc. Certificate Numbers: 

P.O. Box 872807 Part 135: EOOA634I 

Wasilla, Alaska 99687 Part 133: EOOL634D 

Ph: 907-376-3444 Part 145: EOOR634D 

Fx: 907-373-0167 

prisminc(3)prismhelicopters.com 

Request for Inclusion: 43.3 App, A (c) or 43.3-i for the removal of helicopters cabin/cockpit 

doors on the MD500D and the AS350B2/3, provided a pilot may perform the removal and 

reinstallation when no tools are required provided - (1) The pilot has satisfactorily completed an 

approved training program and is authorized in writing by the certificate holder to perform each 

Box 872807, Wasilla, Alaska 99687 Ph: (907) 376-3444 Fax: (907) 373-0167 
task; (2) the certificate holder has written procedures available to the pilot to evaluate the 

accomplishment of the task. 

Background: Prism Helicopters Inc. is a Part 133 (Rotorcraft External-Load Operator) and Part 

135 Operator based in Wasilla, Alaska. Operations primarily consist of very remote utility work 

for mining and oil companies, land survey, mountain top communication site transport, aerial and 

wildlife survey. Prism Helicopters Inc. operates year-round in all types of Alaskan weather, to 

include extreme low temperatures (-30 to -40 degrees Fahrenheit) 

Often most jobs have long flights to a remote work area with no facilities or roads, where we 

perform the sling or survey work. Due to the limited size of the MD500D and AS350B2/3 ail 

operations are single pilot, with the customers aboard. Sling work is conducted single pilot by 

vertical reference (pilot leaning out the door for all visual reference cues) utilizing 50ft to 150ft 

sling lines requiring very precise placement of loads. Survey work may consist of flying 30-5 0 

miles with the customer aboard to begin the survey. 

In the above examples, continued operational safety, public/crew economical efficiency, comfort 

and pilot fatigue, necessitates flying to the work site or area, doors on; then removing one or more 

doors to conduct the sling operations or aerial survey. When the survey is complete or the sling 

load is moved, the door/doors are reinstalled for the return to base. 

Currently the removal of the doors requires a holder of a mechanic certificate, or a repairman 

certificate perform the task. Very limited passenger space in the aircraft and economical 

constraints forbid Prism Helicopters to carry a mechanic solely to perform a function that requires 

no tools and takes less than one minute to perform per iteration (see CD video). 

Prism Helicopters is trying to perform these operational missions with significantly less 

operational risk and greater operational efficiency. Pilots and the public (customers) must accept 

uncomfortable climatic conditions and increased pilot/public fatigue in trade for, good visibility 

during sling loads/surveys, because pilots can not remove the door(s) at the survey/sling site. The 

pilots are forced to fly the entire mission doors off rather than only in the area needed. During 

times of extremely low temperature the challenge for operational safety is to perform sling/survey 

work s with doors installed. 

For many years Prism Helicopters has had a FAA approved training program to instruct our pilots 

how to remove and install doors in the field. Our Director of Maintenance instructs the class and 

we both document the training in the individual pilot records and issue a qualification card to the 

pilot to show proof to perform the procedure just like removal of the aircraft seats lAW 43.3-1. 

There are no bolts or screws and the procedure requires absolutely no tools of nay type. The pilot 

then notes the change on the weight and balance form (preprinted standard entry) in the aircraft 

and makes a notation in the log book. Prism Helicopters Inc. meets the regulations 43-3-h and 

43-3-i. This procedure is significantly less complex than the currently approved ability of the 

pilot under, remote conditions, to remove and check the Engine Chip Detector, whish requires a 

few simple tools Part 43.3 App. A (c). Both helicopter operating manuals allow for routine doors 

off operations. 

Under public law the administrator is allowed to make exemptions for Alaska Operators 

operating in remote locations. For all the above reasons Prism Helicopters Inc. is requesting the 

ability to use the FAA approved Training Program currently in place so our pilots can remove and 

install the helicopter cabin doors in the field without the aid of a holder of a mechanic certificate 

if one is not available at the site. This program would mirror Part 43.3-1 or could be included on 
the list of items in 43.3 App. A(c). The ability of our pilots to accomplish this very simple task 

will result in a more efficient, economical and most importantly, a safe operation for both the 

pilot and the public (customers). 

For Prism Helicopters to maintain continued operational safety we respectfully petition for the 

exception to run concurrently with Exemption No. 8697B. 

Please find enclosed a copy of Exemption No. 8697B. 

Sincerely 

Dave Zall 

Director of Operations 

Prism Helicopters Inc.