Feb 22, 2016

Federal Docket Management System

Ref: GSTS Petition for Exemption from 14 CFR part 145.103 B  

Dear Sir or Madam,

This is to notify the Federal Aviation Administration (FAA) of our petition for exemption from

the housing requirements of 14 CFR 145.103 (b).    This petition letter contains two sections;

Section 1 addresses the information required by 14 CFR part 11.81.    Section 2 contains

information required by FAA Order 8900.1 Vol 3 Chapter 2 Section 1.

Section 1: Petition information required per 14 CFR 11.81

(a) Your name and mailing address and, if you wish, other contact information such as a fax

number, telephone number, or e‐mail address;

Global SuperTanker Services LLC (GSTS)

1719 Aviation Way

Colorado Springs Colorado

80916

1‐800‐994‐2523

(b) The specific section or sections of 14 CFR from which you seek an exemption;

14 CFR part 145.103

   Housing and facilities requirements.

(a) Each certificated repair station must provide‐‐ 

(b) 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.

(c) The extent of relief you seek, and the reason you seek the relief;

GSTS is seeking relief from the housing requirement of 14 CFR part 145.103 (b). GSTS is in

possession of a hanger for their Repair Station located at 1719 Aviation Way in Colorado
Springs Colorado. Their hanger is more than adequate for the accomplishment of line

maintenance functions and has ample ramp space directly in front of the hanger;

however the hanger is not large enough to completely house their B‐747 SuperTanker.  

Below is the floor plan layout of the GSTS hanger and photos of the facility:

GSTS has applied for a 14 CFR part 137 Air Operator certificate in order operate a B‐747‐

400 BCF (SuperTanker) aircraft in Fire Fighting Operations.  In order for GSTS to operate

the SuperTanker in Fire Fighting operation in support of the US Forest Service (USFS), the
USFS requires GSTS to also hold a 14 CFR part 145 Air Agency Certificate.  GSTS will only

conduct basic “line maintenance” activities on their SuperTanker aircraft.    All

maintenance above line maintenance shall be conducted via contract with an

appropriately rated part 145 Repair Station.  To obtain a 145 Repair Station certificate

GSTS must comply with all 14 CFR part 145 regulations.    This includes the housing

requirements of 14 CFR part 145.103 (b), excerpt below:

Sec. 145.103

   Housing and facilities requirements.

(a) Each certificated repair station must provide‐‐ 

(b) 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.

  

Since GSTS is only requesting part 145 Repair Station authorization to conduct basic line

maintenance functions, it is believe that requiring GSTS to have a facility large enough to

house the B‐747 SuperTanker is excessive and unnecessary.  All basic line maintenance

functions can be safely and efficiently conducted outside of an enclosed structure.  

Requiring GSTS to acquire a facility large enough to house the B‐747 SuperTanker would

cause an undue financial burden on GSTS and inhibit their ability to provide the badly

needed firefighting capabilities of the B‐747 SuperTanker.   

(d) The reasons why granting your request would be in the public interest; that is, how it would

benefit the public as a whole;

Without this exemption the USFS will be unable to utilize the one of a kind firefighting

capability of the B‐747 SuperTanker.  Granting this exemption to GSTS would allow for

the B‐747 SuperTanker’s entry into service in time for the 2016 fire season in the United

States. Calendar year 2016 is set to be one of the worst fire seasons in recent history.  To

combat this year’s fire season, the USFS is in dire need of the enormous up lift and

delivery capability of the GSTS B‐747 SuperTanker. Loss of our nation’s forest, personal

property and lives can be saved if the USFS has the ability to utilize the capabilities of the

GSTS B‐747 SuperTanker.   
(e) The reasons why granting the exemption would not adversely affect safety, or how the

exemption would provide a level of safety at least equal to that provided by the rule from

which you seek the exemption;

Since GSTS is only requesting part 145 Repair Station authorization to conduct basic line

maintenance functions, it is believe that requiring GSTS to have a facility large enough to

house the B‐747 SuperTanker is excessive and unnecessary.  All basic line maintenance

functions can be safely and efficiently conducted outside of an enclosed structure.  GSTS

Repair Station authorizations, Operations Specifications and Manual system will

specifically limit the type of maintenance GSTS is allowed to perform.   GSTS will only

utilize their 145 Repair Station for line maintenance on only their B‐747 SuperTanker

aircraft.    All maintenance above basic line maintenance will be performed by an

appropriately rated Repair Station.

(f) A summary we can publish in the Federal Register, stating

      (1) The rule from which you seek the exemption; and

      (2) A brief description of the nature of the exemption you seek;

GSTS is petitioning for exemption from the housing requirements of 14 CFR part 145.103

(b).  GSTS is currently in the process of FAA certification to become a 145 Repair Station

with Limited Rating for the purpose of “line maintenance” only.  GSTS’s only purpose for

the 145 Repair Station is to conduct basic line maintenance activities on the very unique,

one of a kind, B‐747‐400 SuperTanker aircraft.  All maintenance above line maintenance

shall be conducted via contract with an appropriately rated part 145 Repair Station.  To

obtain a 145 Repair Station certificate GSTS must comply with all 14 CFR part 145

regulations.  This includes the housing requirements of 14 CFR part 145.103 (b), excerpt

below:

Sec. 145.103

   Housing and facilities requirements.

(a) Each certificated repair station must provide‐‐ 

(b) 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.

  

Since GSTS is only requesting part 145 Repair Station authorization to conduct basic line

maintenance functions, it is believe that requiring GSTS to have a facility large enough to

house the B‐747 SuperTanker is excessive and unnecessary.  All basic line maintenance

functions can be safely and efficiently conducted outside of an enclosed structure.  

Requiring GSTS to acquire a facility large enough to house the B‐747 SuperTanker would

cause an undue financial burden on GSTS and inhibit their ability to provide the badly

needed firefighting capabilities of the B‐747 SuperTanker.   

Without this exemption the USFS will be unable to utilize the one of a kind firefighting

capability of the B‐747 SuperTanker.  Granting this exemption to GSTS would allow for
the B‐747 SuperTanker’s entry into service in time for the 2016 fire season in the United

States. Calendar year 2016 is set to be one of the worst fire seasons in recent history.  To

combat this year’s fire season the USFS is in dire need of the enormous up lift and

delivery capability of the GSTS B‐747 SuperTanker. Loss of our nation’s forest, personal

property and lives can be saved if the USFS has the ability to utilize the capabilities of the

GSTS B‐747 SuperTanker.   

(g) Any additional information, views or arguments available to support your request;  

GSTS is only requesting part 145 Repair Station authorization to conduct basic line

maintenance functions; it is believe that requiring GSTS to have a facility large enough to

house the B‐747 SuperTanker is excessive and unnecessary.  All basic line maintenance

functions can be safely and efficiently conducted outside of an enclosed structure.  

Requiring GSTS to acquire a facility large enough to house the B‐747 SuperTanker would

cause an undue financial burden on GSTS and inhibit their ability to provide the badly

needed firefighting capabilities of the B‐747 SuperTanker.

(h) If you want to exercise the privileges of your exemption outside the United States, the

reason why you need to do so.

GSTS has no intention of utilizing this exemption outside of the United States.

************************

Section 2: Content of Petition as required by FAA Order 8900.1 Vol 3 Chapter 2   

    1. The rule requirement from which exemption is sought;

14 CFR part 145.103

   Housing and facilities requirements.

(a) Each certificated repair station must provide‐‐ 

(b) 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.
2. The nature and extent of the requested regulatory relief;

GSTS has applied for a 14 CFR part 137 Air Operator certificate in order operate a

B‐747‐400 BCF (SuperTanker) aircraft in Fire Fighting Operations.    In order for

GSTS to operate the SuperTanker in Fire Fighting operation in support of the

USFS, the USFS requires GSTS to also hold a 14 CFR part 145 Air Agency

Certificate.    GSTS will only conduct basic “line maintenance” activities on the

SuperTanker aircraft.    All maintenance above line maintenance shall be

conducted via contract with an appropriately rated part 145 Repair Station.  To

obtain a 145 Repair Station certificate GSTS must comply with all 14 CFR part 145

regulations.  This includes the housing requirements of 14 CFR part 145.103 (b),

excerpt below:

Sec. 145.103

     Housing and facilities requirements.

(a) Each certificated repair station must provide‐‐ 

(b) 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.

  

Since GSTS is only requesting part 145 Repair Station authorization to conduct

basic line maintenance functions, it is believe that requiring GSTS to have a

facility large enough to house the B‐747 SuperTanker is excessive and

unnecessary.   All basic line maintenance functions can be safely and efficiently

conducted outside of an enclosed structure.  Requiring GSTS to acquire a facility

large enough to house the B‐747 SuperTanker would cause an undue financial

burden on GSTS and inhibit their ability to provide the badly needed firefighting

capabilities of the B‐747 SuperTanker.

3. A description of each person or aircraft to be covered by the exemption;

This exemption would apply to GSTS 145 Limited Airframe Repair Station

certificate located at 1719 Aviation Way in Colorado Springs Colorado, 80916.
4. Any information, views, or arguments to support the action sought;

GSTS is petitioning for exemption from the housing requirements of 14 CFR part

145.103 (b).  GSTS is currently in the process of FAA certification to become a 145

Repair Station with Limited Rating for the purpose of “line maintenance” only.  

GSTS’s only purpose for the 145 Repair Station is to conduct basic line

maintenance activities on the very unique, one of a kind, B‐747‐400 SuperTanker

aircraft.  All maintenance above line maintenance shall be conducted via contract

with an appropriately rated part 145 Repair Station.    To obtain a 145 Repair

Station certificate GSTS must comply with all 14 CFR part 145 regulations.  This

includes the housing requirements of 14 CFR part 145.103 (b), excerpt below:

Sec. 145.103

     Housing and facilities requirements.

(a) Each certificated repair station must provide‐‐ 

(b) 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.

  

Since GSTS is only requesting part 145 Repair Station authorization to conduct

basic line maintenance functions, it is believe that requiring GSTS to have a

facility large enough to house the B‐747 SuperTanker is excessive and

unnecessary.   All basic line maintenance functions can be safely and efficiently

conducted outside of an enclosed structure.  Requiring GSTS to acquire a facility

large enough to house the B‐747 SuperTanker would cause an undue financial

burden on GSTS and inhibit their ability to provide the badly needed firefighting

capabilities of the B‐747 SuperTanker.

5. The reasons why a grant of exemption would be in the public interest;  

Without this exemption the USFS will be unable to utilize the significant one of a

kind firefighting capability of the B‐747 SuperTanker.  Granting this exemption to

GSTS would allow for the B‐747 SuperTanker’s entry into service in time for the

2016 fire season in the United States. Calendar year 2016 is set to be one of the

worst fire seasons in recent history.  To combat this year’s fire season the USFS is

in dire need of the enormous up lift and delivery capability of the GSTS B‐747

SuperTanker. Loss of our nation’s forest, personal property and lives can be saved

if the USFS has the ability to utilize the B‐747 SuperTanker.   
6. The action to be taken by the petitioner to provide a level of safety equivalent to that

provided by the rule from which exemption is sought or the reason why a grant of

exemption would not adversely affect public safety;

GSTS is only requesting part 145 Repair Station authorization to conduct basic

line maintenance functions.    GSTS currently has the facilities, equipment and

trained personnel that are necessary to conduct line maintenance functions.  It is

believe that requiring GSTS to have a facility large enough to house the B‐747

SuperTanker is excessive and unnecessary.  All basic line maintenance functions

can be safely and efficiently conducted outside of an enclosed structure.   GSTS

Repair Station authorizations, Operations Specifications and Manual system will

specifically limit the type of maintenance GSTS is allowed to perform.  GSTS will

only utilize their 145 Repair Station for line maintenance on only their B‐747

SuperTanker aircraft.

For any clarification or questions the VP of Maintenance, Mr. Scott Olson can be reached via

the above address or phone number (503) 883‐3324.