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LlDER SIGNATURE SIA - Rua HafOklo Paranh05, 400 _ Aeropono de COI1gonhas CEP 04357-060 _ S'o PauloJSP _ 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 The United States Of America And The 

Government Of The Federative Republic Of Brazil For Promotion Of Aviation 

Safety, done at Brasilia on March 22"', 2004 and 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 Gilligan - Associate Administrator for Aviation Safety 

Subject: Reconsideration for Denial of Exemption number 10149, issued on 

September 30th, 2010 (Regulatory Docket No. FAA-2009-0249) 

Dear Ms. Gilligan, 

On February 2009, the Federal Aviation Administration 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 Principal Maintenance 

Inspector (PM I) during the referenced renewal inspection: 

"HANGARS: 

1) CFR 14 section 145.103 (b) states: a certificated repair station with an 

airframe rating 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 applicable technical maintenance 

procedures, regulation requirements and agreements, Lider 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 stations numbers AV5Y741M and AV52741M (See Regulatory DOCket 

No. FAA-2009-0249 at www.regulations.gov, to obtain detai led information 

about this petition). 

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UOER SIGNATURE SIA _ Rua Harolda Paranhos. 400 _ Aeropol'1o de CongOl'lhas CEP 04357-060 - sao PaukllSP - FAA e RS AV5274 1 M 

The FAA, under the authority of the Acting Director - Fli~ht Standards 

Service, denied Lider's petition on the letter dated September 301 , 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 requesting the reconsideration 

of the FAA's Decision at the instance of the Associate Administrator for 

Aviation Safety. 

lider Signature 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 Republic 

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-registered aircraft 

since 1998 at the AV52741M repair 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 (the 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 require an enclosed 

area (See Brazilian CAA original regulation and translation below). 

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LiOER SIGNATURE SIA - Ru .. Haroklo Paranhos. 400 - Aeropono de Congonhas CEP 04357-060 sao PaulolSP _ FAA eRS AV52741M 

145.37 · REOU1SlTOS ESPEC1A1S PARA lNSTALACOES E FAC1LlDADES 

(b) 0 I"Cqucrcntc de urn ccrtificado PadrJo C deve pro\"cr urn hangar. local izado em aerodrom~ abcrto ao 

tnlfcgo publico. adcquado para pelo menos uma acronavc do tipo mais pcsado prCYiSIO no rcqucrimcnto 

de homologa<;iio [l'USU 0 ni,'el de trllbalho a ser excculando exija]. Adicionalrncnte, deve prover lircas 

dcs('obcrtas, pura seu usa permanente, ande possam scr exocutados 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 way to improve substantiation for this reconsideration, Lider 

Signature S/A has surveyed some related regulations that calls for 

maintenance implementation procedures. Advisory Circular 145-8A, appendix 

1, calls for JAA special conditions contained in the maintenance implementation 

procedures of a Bilateral Aviation Safety Agreement. Under the section 3.0.1, 

paragraph b, it states that Repair stations with airframe or limited airframe 

ratings must have appropriate covered hangar(s) for the base maintenance of 

aircraft. 

Advisory Circular 145-9, item 4.6 sates the following: 

NOTE: The authorization to perform line station maintenance for an air carrier is 

not a rating. A certificated repair station must have established housing and 

facilities. However, only the requirement to provide suitable housing to enclose 

the largest type and model aircraft for airframe-rated repair stations has been 

waived by section 145.205(d). The FAA understands that housing and facilities 

at airports is extremely difficult to obtain and expensive to maintain. 

This statement is particularly related to Air Carriers, but it is interesting to 

note that by the AC, sometimes the requirement to provide suitable housing to 

enclose the largest type and model aircraft for airframe-rated repair stations 

may be waived, considering economical and infra-structural reasons. It is also 

important to note that Lider Signature S /A may also perform maintenance tasks 

on 135 US operators. 

During lhe FAA evaluation of the petition, Lider Signalure has surveyed a 

lot of different options for providing an enclosed area. We consulted national 

and international suppliers, made quotations and found out that to adapt the 

enclosure to the hangars structures, Lider would have to take impracticable 

actions. The national suppliers do not offer a product that we consider suitable 

for our structure and type of operation, and international solutions are not worth ~ 

considering logistical and financial aspecls. ~ 

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UOER SIGNATURE SJA - RUB Haroida Paranllos. 400 _ Aeroporto de Coogonhas CEP 04357-060 _ SIo Pluk>lSP - FAA CRS AV5274 1 M 

Furthermore, Uder also submitted 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 special environment condition 

(Enclosed 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 

conditicns which shows that the work performance and quality would not be 

affected by adverse elements of the environment. The hangar areas are 

considerably big to safely accommodate the workers and aircraft under 

maintenance even with no doors installed. 

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 

Assertive and Stop (Stopcard) the work when situations where their 

performance may be affected arise. Lider has a recognized Quality Safety 

Management System (QSMS) implemented, and it's primary objective is to 

provide the basis for a Safe Operation, using management tools like regular 

management meetings of Operational Safety, weekly safety practices meetings 

with supervisory and maintenance personnel, internal periodic audits, Drug and 

Alcohol program , Individual 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 under the FAR 145 as a repair station in order to provide excellence 

service for the public, specially for the November Registered aircraft when flying 

through Brazil. Lider Signature S/A is the unique authorized Hawker Beechcraft 

Service Center in Brazil with a high quality support for Hawker Beechcraft 

customers that fly over the South America and most important, Lider is located 

at the sao Paulo Airport - Congonhas (AV52741M) and at the Belo Horizonte 

Airport - Pampulha (AV5Y741M), which are responsible for the majority of 

domestic and executive flight operations in Brazil. Providing this high quality 

support to the public 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 Signature S/A is sure that maintaining the 145 repair station certification 

with this exemption will completely benefit the public as whole without affecting 

safety and security. 

Through these reasons, Lider Signature S/A considers that both hangars ..... ~ 

are a suitable permanent housing that perfectly encloses the largest type and c¢'\ 

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lIDER SIGNATURE SIA _ Rill Haroklo Paranhos, 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 rule. 

Yours Faithfully. 

{ '1.",flu a(]!j 

Cyn}hia C. E. d Oliveira 

Maintenance irector 

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