AFS-12-038-E 

February 27, 2012 

 Exemption No. 8697C 

 Regulatory Docket No. FAA-2005-21317 

Mr. David Zall 

Director of Operations 

Prism Helicopters Inc. 

P.O. Box 872807 

Wasilla, AK 99687 

Dear Mr. Zall: 

This letter is to inform you that we have granted your petition to extend, and amend, 

Exemption No. 8697, as amended. It explains the basis for our decision, describes its effect, 

and lists the revised conditions and limitations. 

The Basis for Our Decision 

By letter dated October 11, 2011, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Prism Helicopters, Inc. (Prism), for an extension of Exemption No. 8697, as 

amended, which expires on March 31, 2012. Exemption No. 8697 granted relief from 

§§ 43.3(g), 43.7(f), and 135.443(b)(3) of Title 14, Code of Federal Regulations (14 CFR). 

The relief granted allows pilots employed by Prism to remove and install the cabin/cockpit 

doors on Prism’s MD500D (HU369D), AS350B2, and AS350B3 helicopters. 

Prism is the holder of part 133 and part 135 certificates, and operates small helicopters that 

are type certificated for a passenger seating configuration, excluding any pilots seat, of nine 

seats or less. This grant of exemption applies to only helicopters operated under part 135. 

In addition to granting the extension to Exemption No. 8697, we are also amending it to 

remove the exemption from § 135.443(b)(3) and add exemptions to §§ 43.5(a) and 91.407(a). 

The petitioner does not require relief from § 135.443(b)(3) because its aircraft are maintained 

in accordance with § 135.411(a)(1), which permits aircraft listed on part 135 certificates that 

have a passenger seating configuration, excluding any pilots’ seat, of nine seats or less, to be 
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maintained under parts 43 and 91. Prism’s helicopters therefore can be maintained in 

accordance with parts 43 and 91. The provisions of § 135.443(b)(3) do not apply and it is 

therefore removed from the extended grant of exemption relief. Record keeping requirements 

and approval for return to service are addressed by conditions contained in the exemption. 

The amended exemption continues to be granted for the same reasons cited as the basis for 

Exemption No. 8697, and it will achieve the relief originally intended by the FAA. 

As such, the removal and installation of cabin/cockpit doors does not require an airworthiness 

release or log entry be signed by an authorized certificated mechanic or repairman. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption. 

Our Decision 

The FAA has determined that the justification for the issuance of Exemption No. 8697, as 

amended, remains valid with respect to this exemption and is in the public interest. 

Therefore, under the authority provided by 49 U.S.C. §§ 40113 and 44701, which the FAA 

Administrator has delegated to me, I grant your petition. 

The Effect of Our Decision 

Our decision extends the termination date of Exemption No. 8697, as amended, to 

March 31, 2014, unless sooner superseded or rescinded. Because the FAA finds that 

§ 135.443(b)(3) does not apply to the helicopters described in your October 11, 2011 letter, 

your request for § 135.443(b)(3) is denied. All conditions and limitations of Exemption 

No. 8697, as amended, are listed below. 

Conditions and Limitations 

1. The privileges of this exemption are applicable only to the MD500D (HU369D), 

AS350B2 and AS350B3 helicopters listed on Prism’s Operations Specification D085 

and operated by Prism Helicopters Inc. and to pilots employed by Prism Helicopters 

Inc. 

2. Before exercising the privileges of this exemption, Prism must provide or establish 

written instructions, acceptable to the FAA Flight Standards District Office (FSDO) 

having certificate responsibility for its operations, on the removal and reinstallation of 

cabin doors. 

3. Prism must apply for and receive from its certificate holding district office (CHDO) an 

amendment to its operations specifications to require that certificated maintenance 

personnel employed by Prism conduct spot checks to certify the procedures are being 

adhered to properly. 
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4. Before exercising the privileges of this exemption, Prism must demonstrate to the 

FSDO having certificate responsibility for its operations that its pilots can 

satisfactorily perform the door removal/reinstallation tasks on its aircraft. 

5. Prism must include in its company and aircraft manuals the instructions and 

procedures necessary for the removal/reinstallation of cabin doors. Pilots must have 

the written instructions required by this exemption available and must use those 

instructions when performing the cabin door removal/reinstallation tasks. 

6. Any pilot employed by Prism performing maintenance under this exemption must 

make a maintenance record entry in the aircraft logbook that conforms to the 

provisions of § 43.9. 

7. All pilots employed by Prism and who operate the MD500D (HU369D), AS350B2, 

AS350B3 and seek authorization under this exemption to remove/reinstall aircraft 

cabin doors must be trained by an airframe and powerplant mechanic on the 

removal/reinstallation procedures. To exercise the privileges of this exemption, the 

pilot must have satisfactorily completed an approved training program and be 

authorized in writing by the certificate holder to perform each task. 

a. The training program must include a description of the door attachments, 

procedures for installing and removing the door, care of the door while 

performing the task, proper storage of the door when removed, and instructions 

for checking door security after installation and making the logbook entries for 

weight and balance calculations. 

b. Each pilot must receive hands-on practice on the type of helicopter on which 

the maintenance is to be performed. Training will be accomplished under the 

supervision of an appropriately rated mechanic using the rotorcraft flight 

manual and maintenance manual, when appropriate. Specific instruction 

should be provided on which doors may be removed and which operational 

restrictions apply, as outlined in the rotorcraft flight manual. 

c. Instructional delivery methods must be in the form of lecture and 

demonstration. 

d. Pilots must be tested regularly by an airframe and powerplant mechanic on the 

cabin door removal/reinstallation procedures. 

8. All cabin conversions performed under the privileges of this exemption must conform 

to the aircraft type design or other forms of FAA-approved data, such as supplemental 

type certificates or rotorcraft flight manuals. 

9. When the aircraft manufacturer does not provide specific instructions on the 

procedures to be used to change an aircraft cabin door configuration, these instructions 

and procedures must be developed by Prism and approved by Prism’s CHDO. 
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10. This exemption does not permit or authorize deviation from any of the required 

equipment or operation requirements of parts 121 or 135. 

This letter must be attached to, and is a part of, Exemption No. 8697, as amended. 

Sincerely, 

/s/ 

John M. Allen 

Director, Flight Standards Service