August4,2015

U.S. Department ofTransportation Docket Operations, West Building Ground Floor, Room W12-140 1200 New JerseyAve. SE Washington, D.C. 20590
RE: Request for Exemption
To whom it may concern,

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AVIATION

My name is Holly Nehls, Owner and General Manager of KonectAviation Oregon, LLC in McMinnville, Oregon. In March of2015 our pilot received notificationfrom the Portland FSDO that "removal and re-installation ofaircraft doors and secondary flight controls are considered maintenance functions that are not authorized to be performed by a pilot on an aircraft listed on a Part 135 certificate." Please consider this petition for exemption as prescribed in 14 CFR 11.63. KonectAviation Oregon is a single-pilot, single-aircraft Part 135 certificate holder operating a Robinson R44 Raven II. We specialize in scenictours and transportation flights however, recently, we have begun to offer a time-building promotion for pilots. By offering this promotion we can ensurewefly 1300 hours overthe next 2 years and raise the funds forthe required overhaul. Unfortunately, the nature ofthe flights require that we remove and re-install the secondaryflight controls fairly frequently.
While we understand the FAA's concern for proper installation ofthese very important components, it is ourexperience, and the opinion ofqualified maintenance professionals, that the simplicity ofthe Robinson design for both the removable doors and secondary flight controls, in addition to the inclusion ofthe processes in the Pilots Operating Handbook (POH), ensure successful installation by pilots, esp. 135 pilots. Certainly, for more complex aircraft, this restriction makes complete sense and it is my hope that review ofthe information provided in this petition warrants an exemption for KonectAviation Oregon's Robinson R44 rotor-craft.
I have sought inputfrom both pilots and maintenance professionals and it is my position, as a certificate holder, that flight safety is not compromised by the 135 pilots removal and reinstallation ofthe Robinson R44 aircraft doors and secondaryflight controls. Please review the attached information presented in support ofthis conclusion; the attachments are as follows:

• Letter ofsupport from a certified A & P mechanic

KonectAviation Oregon, LLC • 4040 SE Cirrus Ave. Ste. 3 • McMinnville, OR 97128 Phone: 503.376.0190 • mail@konect-aviation.com •www.konect-aviation.com Page 1 of2

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# ......... AVIATION • Letter ofsupportfrom our 135 pilot • R44 Pilots Operating Handbook 7-5 Removable Flight Controls with photos ofthe mechanisms utilized for removal and installation ofsecondary flight controls • R44 Pilots Operating Handbook 8-6 Cabin Doors with photos ofthe mechanisms utilized for removal and installation Given the FAA's reservations regarding the re-installation ofthe doors and secondary flight controls on the aircraft, Iwould like to offer oursupport forthe spirit ofthe regulation and assurances that the re-installation process will not be taken lightly. If it is preferred over a full exemption, KonectAviation Oregon, the certificate holder, will make it ourformal policy to restrict the re-installation ofthe cabin doors and secondary flight controls to the designated 135 pilot and require that he/she has been trained by, and has successfully performed the processes underthe supervision of, a licensedA & P mechanic. Even though the Robinson R44 is the only aircraft in ourfleet, we will also limit the scope ofthe exemption to the R44 underthe policy.
I hope this information is helpful in understanding our request for exemption and I thank you foryour consideration ofthis matter. Please feel free to contact my office with any question or concerns. We lookforward to hearing from you.

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# Holl~ls Owner/General Manager 4040 S.E. CirrusAve. Ste. 3 McMinnville, OR 97128

KonectAviation Oregon, LLC • 4040 SE CirrusAve. Ste. 3 • McMinnville, OR 97128 Phone: 503.376.0190 • mail@konect-aviation.com •www.konect-aviation.com Page 2 of2Deportment ofTransportation

March 1 2015
Peninsula Helicopters, 340 Dundee, OR 97115 Subject
DearCertificate Holder: Policy Northwest Mountain Colorado, Idaho, Montana, Oregon, Utah, Washington, Wyoming

This is being sentto 

### all ofthe Standards District Office NW229th Avenue Hillsboro, Oregon 97124 503-615<3274, Fax: 503-615-3300 300-847<]806

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jurisdictionwho are operating helicopters. is to provide clarification FAA'spolicy maintenanceperformed 

### by pilots;**sn~ecJncal** removal and re-installation of doors secondary controls.
coordination with om Regional Flight StandardsDivision Offi.ce the iv1aintenance Division, AFS-300, 

### it has reaffim1.ed that removal and doors and secondary flight controls are**,,.~,,iiJH'-'""'** authorized to be performed a pilot onan**"'"'~''""' n**  addition, 

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### the Pilot's Operating the precedence.
Please ensurethatyour companypolicies and procedures align withthe regulatory requirement for maintenance to be perfom1ed appropriately authorized as m 

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ManagerJuly 28, 2015

U.S. Department ofTransportation Docket Operations, West Building Ground Floor, Room W12-140 1200 NewJerseyAve. SE Washington, D.C. 20590
RE: Support for KonectAviation Oregon's Request for Exemption

To whom it may concern, My name is Graham Goad, a licensed A&P and owner of NWAir Repair in McMinnville, Oregon. I have been working with KonectAviation Oregon, a 135 certificate holder, for the removal and installation ofthe doors and secondary flight controls on their Robinson R44 Raven II Rotorcraft. I am writing today in support oftheir petition for exemption ofthe requirement for a certified mechanic to perform the functions of removal and re-installation of aircraft doors and secondary flight controls.
It is my professional opinion that flight safety is not compromised by the 135 pilots removal and re-installation ofthe aircraft doors and secondary flight controls on a Robinson R44. The simplicity ofthe design for both the removable doors and secondary flight controls ensure successful installation, even by minimally qualified airmen. Also, the inclusion ofthe Cabin Doors and Removable Flight Controls process in the Robinson R44 Pilots Operating Handbook (POH) provides on-demand guidance for pilots and illustrates it's common sense nature. Furthermore, the experience and demonstrated knowledge required to become a 135 pilot further mitigates any 'risk' associated with the re-installation ofthe aircraft doors and secondary flight controls ofthe Robinson R44. For these reasons, I am ofthe opinion that the pilot is capable of performing this simple process on the Robinson R44 and the financial and manpower costs associated with scheduling a certified mechanicfor each occurrence is unnecessary. Therefore, I recommend exemption from the requirement for a certified mechanic to perform the functions of removal and re-installation ofaircraft doors and secondary flight controls on a Robinson R44 rotor-craft.
Best regardA / 

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Graham Goad 4040 S.E. Cirrus Ave. McMinnville, OR 97128 Phone: (503) 472-4790July 29, 2015

U.S. Department ofTransportation Docket Operations, West Building Ground Floor, Room W12-140 1200 NewJerseyAve. SE Washington, D.C. 20590
RE: Support for Exemption Petition
To whom it may concern,

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Please accept this letter in support of KonectAvaition Oregon's petition for exemption ofthe requirement to have a certified mechanic perform the removal and re-installation ofcabin doors and secondary flight controls. I have been flying Robinson helicopters since January 2008 and have more than 1000 hours flying Robinson helicopters, during that time I have performed the function of removal and re-installation ofthe aircraft doors and secondary flight controls. Crediting the simplicity ofthe design, I have never experienced, nor observed, an instance where the controls were installed improperly on a Robinson R22 or R44 causing a flight safety risk.
It has been a great challenge for me to coordinate operations with our local A 

### & Pfor performing these tasks and it, attimes, limits our ability to provide the desired service to our customers. KonectAviation Oregon would greatly benefit from your consideration ofthe petition for exemption both logistically and financially. Sincerely, 

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### Ne~ls, CFI Operations Manager and Pilot 4040 S.E. CirrusAve. Ste. 4 McMinnville, OR 97128

KonectAviation Oregon, LLC • 4040 SE CirrusAve. Ste. 3 • McMinnville, OR 97128 Phone: 503.376.0190 • mail@konect-aviation.com • www.konect-aviation.com Page 1 of 1ROBINSON MODEL R44 SECTION 8 HANDUNG AND MAINTENANCE
PARKING

1. Place cydic control in neutral and apply friction. 2. Put collective fuH down and apply friction. 3. Align rotor blades approximately fore and aft. Apply rotor brake. Use blade tie-downs in windy conditions.
CAUTION If using rotor blade tie-downs, do not overtighten tie-down straps (5 lb max tension). Do not pull down on blades to teeter rotor. To lower a blade, push up on opposite blade. 4. During storm conditions, helicopter should be hangared or moved to a safe area. 5. If helicopter is hangared, turn fuel shutoff valve off.
CABIN DOORS

All four cabin doors may be rernoved and installed by maintenance personnel or pilots. To remove a door, disconnect door strut by lifting inboard end of strut while holding door in full open·position, remove cotter rings in upper and lower hinge pins, and then lift door off. To install doors, use reverse procedure. Adjust weight and balance as required when removing or installing doors.

REVISED: 10 MAR 2015 8-6ROBINSON MODEL R44 II SECTION 7 SYSTEMS DESCRIPTION REMOVABLE FLIGHT CONTROLS

Left seat pilot controls may be removed and installed by maintenance personnel or pilots as follows: 1. To remove cyclic grip, remove quick-release pin by depressing button and pulffnq, then pull outward on left gnp while supporting cyclic center post. Rotate rightside cyclic cross tube clockwise to stop, depress stop pin under cyclic pivot, and continue clockwise rotation one turn towind up balance spring. To install removable cyclic grip, use reverse procedure. NOTE Later aircraft have a knurled ring next to the quick-releasepin which may be handtightened to eliminate freeplay. The ring must be loose (rotate counterclockwise looking inboard) to remove pin. CAUTION Overrotating cycliccrosstube in eitherwound or unwound direction will damage balance spring. CAUTION After removing cyclic grip, place plastic cap on exposed cyclic cross tube to prevent possible injury to left seat passenger. 2. To remove collective, eush boot aft to expose locking pins.**~press** locking pins and pull forward on stick. To install, use reverse procedure. It may be necessary to rotate stick slightly to allow pins to snap into place. CAUTION When collective is installed, ensure that both locking pins are fully engaged through holes on each side. 3. To remove tail rotor pedals, depress locking pin while twisting pedal counterclockwise, then pull up. To Install, use reverse procedure. On later aircraft, a cover which is stowed under the floor scuff plate may be rotated up to cover the floor openings when the pedals are removed. REVISED: 21 FEB 2014 7-5I J. 

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