August4,2015 

U.S. Department of Transportation 

Docket Operations, West Building 

Ground Floor, Room W12-140 

1200 New Jersey Ave. SE 

Washington, D.C. 20590 

RE: Request for Exemption 

To whom it may concern, 

. 1,~~ ......_... __ ..,., .. AVIATION 

My name is Holly Nehls, Owner and General Manager of Konect Aviation Oregon, LLC in 

McMinnville, Oregon. In March of 2015 our pilot received notification from the Portland FSDO 

that "removal and re-installation of aircraft 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. 

Konect Aviation Oregon is a single-pilot, single-aircraft Part 135 certificate holder operating a 

Robinson R44 Raven II. We specialize in scenic tours and transportation flights however, 

recently, we have begun to offer a time-building promotion for pilots. By offering this 

promotion we can ensure we fly 1300 hours over the next 2 years and raise the funds for the 

required overhaul. Unfortunately, the nature of the flights require that we remove and re-install 

the secondary flight controls fairly frequently. 

While we understand the FAA's concern for proper installation of these very important 

components, it is our experience, and the opinion of qualified maintenance professionals, that 

the simplicity of the Robinson design for both the removable doors and secondary flight 

controls, in addition to the inclusion of the 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 of the information 

provided in this petition warrants an exemption for Konect Aviation Oregon's Robinson R44 

rotor -craft. 

I have sought input from 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 of the Robinson R44 aircraft doors and secondary flight controls. Please review 

the attached information presented in support of this conclusion; the attachments are as 

follows: 

• Letter of support from a certified A & P mechanic 

Konect Aviation 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 
~ ·~-- AVIATION ......... • Letter of support from our 135 pilot 

• R44 Pilots Operating Handbook 7-5 Removable Flight Controls with photos of the 

mechanisms utilized for removal and installation of secondary flight controls 

• R44 Pilots Operating Handbook 8-6 Cabin Doors with photos of the mechanisms 

utilized for removal and installation 

Given the FAA's reservations regarding the re-installation of the doors and secondary flight 

controls on the aircraft, I would like to offer our support for the spirit of the regulation and 

assurances that the re-installation process will not be taken lightly. If it is preferred over a full 

exemption, Konect Aviation Oregon, the certificate holder, will make it our formal policy to 

restrict the re-installation of the 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 under the supervision of, a licensed A & P mechanic. Even though the Robinson 

R44 is the only aircraft in our fleet, we will also limit the scope of the exemption to the R44 

under the policy. 

I hope this information is helpful in understanding our request for exemption and I thank you 

for your consideration of this matter. Please feel free to contact my office with any question or 

concerns. We look forward to hearing from you. 

~ard1)(~ 

Owner/General 

Holl~ls Manager 

4040 S.E. Cirrus Ave. Ste. 3 

McMinnville, OR 97128 

Konect Aviation Oregon, LLC • 4040 SE Cirrus Ave. Ste. 3 • McMinnville, OR 97128 

Phone: 503.376.0190 • mail@konect-aviation.com • www.konect-aviation.com 

Page 2 of2 
Deportment 

of Transportation 

March 1 2015 

Peninsula Helicopters, 

340 

Dundee, OR 97115 

Subject 

Dear Certificate Holder: 

Policy 

Northwest Mountain 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

This is being sent to all of the 

Standards District Office 

NW 229th Avenue 

Hillsboro, Oregon 97124 

503-615<3274, Fax: 503-615-3300 

300-84 7 <]806 

Performed a 

jurisdiction who are operating helicopters. is to provide clarification 

FAA's policy maintenance performed by pilots; sn~ecJncal removal and 

re-installation of doors secondary controls. 

coordination with om Regional Flight Standards Division 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 on an "'"'~''""' n 

addition, if between the Pilot's Operating the 

precedence. 

Please ensure that your company policies and procedures align with the regulatory 

requirement for maintenance to be perfom1ed appropriately authorized as 

m CFR Section 

Manager 
July 28, 2015 

U.S. Department of Transportation 

Docket Operations, West Building 

Ground Floor, Room W12-140 

1200 New Jersey Ave. SE 

Washington, D.C. 20590 

RE: Support for Konect Aviation Oregon's Request for Exemption 

To whom it may concern, 

My name is Graham Goad, a licensed A&P and owner of NW Air Repair in McMinnville, 

Oregon. I have been working with Konect Aviation Oregon, a 135 certificate holder, for the 

removal and installation of the doors and secondary flight controls on their Robinson R44 

Raven II Rotorcraft. I am writing today in support of their petition for exemption of the 

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 of the aircraft doors and secondary flight controls on a Robinson R44. The 

simplicity of the design for both the removable doors and secondary flight controls ensure 

successful installation, even by minimally qualified airmen. Also, the inclusion of the 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 of the aircraft doors and 

secondary flight controls of the Robinson R44. For these reasons, I am of the 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 mechanic for each occurrence is 

unnecessary. Therefore, I recommend exemption from the requirement for a certified 

mechanic to perform the functions of removal and re-installation of aircraft doors and 

secondary flight controls on a Robinson R44 rotor-craft. 

Best regardA / #)/) 

{/(/fA_ L 07{/ 

Graham Goad 

4040 S.E. Cirrus Ave. 

McMinnville, OR 97128 

Phone: (503) 472-4790 
July 29, 2015 

U.S. Department of Transportation 

Docket Operations, West Building 

Ground Floor, Room W12-140 

1200 New Jersey Ave. SE 

Washington, D.C. 20590 

RE: Support for Exemption Petition 

To whom it may concern, 

. ~ ......_.._ .......... AVIATION 

Please accept this letter in support of Konect Avaition Oregon's petition for exemption of the 

requirement to have a certified mechanic perform the removal and re-installation of cabin 

doors and secondary flight controls. I have been flying Robinson helicopters since January 

2008 and have more than 1 000 hours flying Robinson helicopters, during that time I have 

performed the function of removal and re-installation of the aircraft doors and secondary flight 

controls. Crediting the simplicity of the 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 & P for 

performing these tasks and it, at times, limits our ability to provide the desired service to our 

customers. Konect Aviation Oregon would greatly benefit from your consideration of the 

petition for exemption both logistically and financially. 

Sincerely, 

/'1 

./~~)JelL( lngo Ne~ls, CFI 

Operations Manager and Pilot 

4040 S. E. Cirrus Ave. Ste. 4 

McMinnville, OR 97128 

Konect Aviation 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 of 1 
ROBINSON 

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 8-6 

ROBINSON 

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 tow ind up balance spring. To install removable 

cyclic grip, use reverse procedure. 

NOTE 

Later aircraft have a knurled ring next to the 

quick-release pin which may be hand tightened 

to eliminate freeplay. The ring must be loose 

(rotate counterclockwise looking inboard) to 

remove pin. 

CAUTION 

Overrotating cyclic cross tube in either wound 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 7-5 
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