# <-- LIDEFL .**ma cao**  LlDER S IGNAT UR E SI A - Ru a HafOklo Paranh05, 400 _ Aeropono de COI1gonhas CEP 04357-06 0 _ S'o Pau loJ SP _ FAA CRS AV52741M

Doc. Number: 060-12-10-SAO Reference Doc.: FAR 145 , AC 145-8A, AC 145 -9 , AC 20-106 , Agreement 

### Between The Government Of Th e United States Of America And The Government Of The Federative Republi c Of Brazil For Promotion Of Aviation Safety , done at Brasilia on March 22"', 2004 a nd Denial of Exemption number 10149 (Letter dated September 30 ' h , 2010) . Date: 21-DEC-2010 

## To US Department of Transportation Federal Aviation Administration 800 Independence Avenue , SW Washington, DC 20591 

### In Att. : Ms . Margaret Gi l ligan - Asso ciate Administrator for Aviation Safety Subject: Reconsideration for Denial of Exemption number 10149 , issued on September 30 th , 2010 (Regulatory Docket No . FAA-2009-0249) Dear Ms . Gill igan , 

### On February 2009, the Federal Aviation Administrat ion performed the annual renewal inspection of the foreign Repair Stations numbers AV52741M and AV5Y741M , both certified under the provisions of the Federal Aviation Regulation 145. 

### The following discrepancy was noted by the Princ ipal Maintenance Inspector ( PM I ) during the referenced renewal i nspection:



### "HANGARS : 1) CFR 

### 14 section 145.103 (b) states: 

## a certificated repair station with an airframe rati ng must provide suitable permanent housing to enclose the largest type and model of aircraft listed on its operations specifications. Lider Fix wing hangar , does not have doors. Therefore it is requested that Lider respond within 

### 30 days 

### as to the corrective action to be taken to comply with the above 

### 14 CFR regulation and its operations specifications. " After performing a deep analysis of the applicab l e technical maintenance 

### procedures, regulation requirements and agreements , Lide r Signature 

### S/ A submitted a petition for exemption of the CFR 14 section 145 . 103 (b) , only 

### regarding the existence of doors in the front of the hangars for both certified repair stat ions numbers AV5Y741M and AV52741M (See Regulatory**DOCke t**  

### No . FAA-2009-0249 at www . regula tions .gov , to obtai n de tai led information about this pet ition). 115

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# LID ER yiaCtlCl U OER S IGN ATURE S IA _ R ua Harolda Pa ranhos . 400 _ Aeropol'1o de CongOl'lha s CEP 0435 7-060 - sao Pa ukll SP - FAA e RS AV5274 1M The FAA , under the authority of the Acting Director -**Fli~ht** Standards Service , denied Lider's petition on the letter dated September 30 1 , 2010 for the exemption No. 10149 , A grant of exemption was not considered to be in the public interest (See Denial of Exemption No . 10149 at www .aes.faa .gov) . Through this letter , Lider Signature S/A is request i ng the reconsideration 

### of the FAA's Decision at the instance of the Associate Administrator for Aviation Safety . lider Signatu re S/A is committed to promote aviation safety and environmental quality as predicted on the Agreement Between the Government of the United States of America and the Government of the Federative Republi c of Brazil done on March 22"' , 2004. lider Signature 

### S /A would like the Federal 

### Aviation Associate Administrator to specially consider Article I , section A, paragraph 2 and Article 111, section A, paragraph 3 of the referenced agreement for this reconsideration (Please find the Bilateral Agreement at the FAA website - Search Bar). Lider Signature S/A performs maintenance tasks on N-regi stered aircraft since 1998 at the AV52741M repa ir station and since 1979 at the AV5Y741M repair station . Both repair stations have suitable permanent housing , but there are no front doors in the hangars (See Pictures Below) . CRS AV52741M CRS AV5Y741M

Brazilian aviation regulation for repair stations certified under the section 145 . 37 (b) says that the company must provide an adequate hangar for at least one aircraft (t he heaviest) predicted on the application , 

### if the maintenance level requests it. In other words , there is no specific requirement in Brazil for an enclosed place, if the service to be performed does not requi re an enclosed area (See Brazilian CAA original regulat io n and translation below) .

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# i::::::**~naca!l** Li OER S IGNATURE SIA - Ru .. Haroklo Paran hos. 400 - Ae ropo n o de Cong onhas CEP 04 357-060 sao Pa ulolSP _ FAA eRS AV52741M 

### 145 . 37 · REOU1SlTOS ESPEC1A1S PARA lNSTALACOES E FAC1LlDADES (b) 0 I"Cqucrcntc de urn ccrtific ado Padr Jo C deve pro\" cr urn hangar. local izado em**aerodrom~** abcrto ao tnlfcgo publico. ad cqu a do p ara p elo menos uma ac ro navc do t ip

o m ais p cs ado prCYiSIO n o rcqu crimcnto de homologa<;iio [l'USU 0 ni,'el de trllbalho a s er excculando exija]. Ad i cion alrncnte, deve prover lircas dcs('obcrtas , pura seu usa permanente, ande possam scr ex ocut ados trabalhos que nao exijOllll**pr tc~i'io**  contra as intcmperics. 

### "145 . 37
- SPECIAL REQUIREMENTS FOR FACILITIES 

### (b) An applicant for an airframe rating must provide an adequate hangar for at least one of the heaviest aircraft within the weight class of the rating he seeks (if the work to be performed requires) . Additionally, the applicant must provide opened areas, for permanent use, where work that does not require specific climatic conditions can be performed." As a wa y to improve substantiation for this re consideration , Lider Signatu re S /A has surveyed some related regulations that calls for maintenan ce implementatio n procedures . Advisory Circular 145-8A , appendix 1 , calls for JAA spe ci al conditions conta i ned in the ma i ntenance implementation p rocedu res of a Bilateral Av iation Safety Agreement. Under the section 3 .0 . 1 , 

### paragra ph b , it states tha t Repair stations with airframe or limited airframe rati n gs m u st have appropriate covered hangar(s ) for the base ma i ntenance of ai rcraft . Advisory Circular 145-9 , item 4 .6 sates the following: NOTE : The authorizati on to perform line station maintenance for an air carrier is not a rating . A certifi cated repair stati on must have established housing and facilities . However , onl y the requirement to provide suitable hous i ng to en c lose the largest ty pe and model aircraft for airframe-rated repair stati o ns has been 

### w aived by se ction 145 .205 (d) . The FAA understands that housing and facilities at a i rp orts is extremely difficult to obtain and expensive to maintain . This statement is particularly related to Air Carriers , but it is in terest i ng to note th at by t he AC, sometimes the requ i rement to provide suitable housing to e ncl ose the largest type and mode l aircraft for airframe-rated repair stations may be wa ived , considering economical and infra -structural reasons . It is also i mportant to n ote that Lider Signature 

### S/ A may also perform maintenance tasks o n 135 

### US operato rs . 

### During lhe FAA evaluation of the petit ion , Lider Signalure has surveyed a lot of d ifferent options for providing an enclosed area . We consulted national and international suppl i ers , made quotat ions and found out that to adapt the enclo s u re to the hangars structures , Lider would have to take impracticable action s. The national suppliers do not offer a product that we cons ider suitable f or ou r stru cture and type of operation , and international solutions are not worth

### ~ consi d ering logistical and financial aspecls .**~** 3 / 5

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U OER SIGNATU R E SJA - RUB Haroida Paranllo s. 400 _ Aeroporto de Coogonhas CEP 04357-060 _ SIo Pluk>lSP - FAA CRS AV5274 1M Furthermore , Uder al so subm itted additional information on how to 

### provide a level of safety equivalent to that provided by paragraph 145 . 103 , under the aspects of the maintenance requirements predicted on the 

### Manufacturers maintenance manuals . No specia l environment condition (Enclose d Area) is required for the items evaluated . The FAA clarified on the Denial saying that 

### " the regulation that Lider seeks relief extends beyond protection and security of the aircraft. It also relates to the condition of the work environment itself, which is not addressed 

### by Lider . " The additional information that lider submitted contained historical climatic conditi c ns which shows that the work performance and quality would not be affected by adverse elements of the envi ronment. The hangar areas are 

### considerably big to safely accommodate the workers and aircraft under maintenance even w ith no doors insta ll ed . Lider Signature S/A President and Directorate are fully committed with the Human Factors and Safety issues , which are common practices in our maintenance environment. All employees are trained and encouraged to be As s ertive and Stop (Stopcard) the work when situations where their performance may be affected arise . Lider has a recogn ize d Quality Safety Managem ent System (QSMS) imp l emented , and it's primary objective is to 

### provide the basis for a Safe Operatio n , using management tools like regular management meetings of Operational Safety , weekly safety practices meetings w ith supervisory and ma i ntenance personnel , internal periodic audits , Drug and Alcohol program , Individua l observation and record of the evaluation of the human performance during work (NOS Program) , prevention reports , incidenUaccident communication and analysis , annual award for personnel that demonstrates accomplishment with the best safety practices , between others . This exemption , if granted , will permit Lider Signature S/A to continuously 

### operate unde r the FAR 145 as a repair station in order to provide excellence service for the public , specially for the November Registered aircraft when flying thro ugh Brazil . Lider Signature S/A is the u n ique authorized Hawker Beechcraft Service Center i n Brazil with a high quality support for Hawker Beechcraft customers that fly over the South America and most i mportant , Lider is located 

### at the sao Pau lo Airport - Congonhas (AV52741M) and at the Belo Horizonte Airport - Pampulha (AV5Y741M) , which are respons i ble fo r th e majority of domestic and executive flight operations in Brazi l . Providing this high quality support to the publ ic for so many years has been a priority for Lider , and that 

### gave us the title of the biggest executive aviation company in South America . Lider S ignature S/ A is sure that ma in ta ini ng the 145 repair station certification with this exemption will complete ly benefit the public as w h o l e without affecting safety and security . Through these reasons , Lider Signature S/A considers that bo th h angars .....**~** 

### are a suitable permanent housing tha t perfectly encloses the la rgest type and 

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:=.: R A . _ . ,/ lYIa(d d lIDER SIGNATURE SIA _ Rill Haroklo Pa ranhos , 400 _ Ael'(lporlo de Coogonhas CEP 0"357-060 - SAo PaulolSP - FAA eRS AV52741 M



### model of aircraft listed on its operations specifications without adversely affecting safety and provides a level 0 safety equal to the existing ru le . 

### Yours Fai thfully . 

### { '1.",fl

### u 

## a(]!j Cyn}hia C. E. d Oliveira

Maintenance irector

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