October 21 , 2015

Mr. Amer Machlah President, Aircraft Technical Support Roswell, 72 Earl Cummings Loop West, Building 1081 Roswell, New Mexico 88203

RE: Petition for Exemption

To whom it may concern,

This letter has been written on behalf of Aircraft Technical Support Roswell for an exemption from Sections 145.103(b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if granted, would permit ATSR to perform aircraft storage related maintenance on transport category airplanes wi thout meeting all of the housing and facility requirements of Sections 145.103.

ATSR requires relief from the following regulations:

Sections 145.103 Housing and facilities requirements.

(a) Each certificated repair station must provide

— (1) Housi ng for the facilities, equipment, materials, and personnel consistent with its ratings. (2) Facilities for properly performing the maintenance, preventive maintenance, or alterations of articles or the specialized services for which it is rated. Faci lities must include the following: (i) Sufficient work space and areas for the proper segregation and protection of articles during all maintenance, preventive maintenance, or alterations; (ii) Segregated work areas enabling environmen tally hazardous or sensitive operations such as painting, cleaning, welding, avionics work, electronic work, and machining to be done properly and in a manner that does not adversely affect other maintenance or alteration articles or activities; ( iii) Suitable racks, hoists, trays, stands, and other segregation means for the storage and protection of all articles undergoing maintenance, preventive maintenance, or alterations; (iv) Space sufficient to segregate articles and materials stocke d for installation from those articles undergoing maintenance, preventive maintenance, or alterations; and (v) Ventilation, lighting, and control of temperature, humidity, and other climatic conditions sufficient to ensure personnel perform maintenance, preventive maintenance, or alterations to the standards required by this part. (b) A certificated r epair 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) A certificated repair station may perform maintenance, preventive maintenance, or a lterations on articles outside of its housing if it provides suitable facilities that are acceptable to the FAA and meet the requirements of §145.103(a) so that the work can be done in accordance with the requirements of part 43 of this chapter.

ATSR supp orts its request with the following information:The climatic conditions of southeastern New Mexico, namely Roswell, are dry, warm and ideal for ATSR

to complete storage related maintenance in an outdoor environment on a year round basis without adversely affecting the quality of work being performed. Additionally, ATSR anticipates that the volume of aircraft to be stored at the Roswell Industri al Air Center under its custody/control and under the conditions of the proposed exemption would be well above 50 aircraft . There is no hangar in the world that could hold that many planes at one time in a storage condition . The idea of moving that many aircraft around to facilitate maintenance in a hangar would be completely impractical and therefore requires storage to be done outdoors . The aircraft will not be disassembled in a manner that would cause deterioration of any kind. ATSR will use materials that meets or exceeds manufacturers’ specifications for the applications performed and provides adequate safeguards against contamination and weather elements.

The maintenance that ATSR anticipates performing would only be for outside related storage of aircraft. ATSR owns and maintains equipment (i.e. ladders, service trucks, scissor lifts and man lifts) and tooling

n ecessary to perform storage maintenance on airplanes up to and including all series of Boeing 767’s.

ATSR has provided copies of the manufacturers’ storage maintenance programs for the Boeing MD

- 80, Boeing 757 and Boeing 767 airplanes outlining the type of storage maintenance to be performed under the terms of the proposed exemption. It is the determination of ATSR that the storage maintenance functions of cleaning the airplane, covering windows, pressure ports, applying tape to areas of the fuselage and gear assemblies do not require the airplane to be disassembled or housed. Any lubrication, checking of tire/strut pressures are accomplished in a closed system, meaning that contaminates are not permitted in the system because of the way the system is desi gned. Any interior servicing and checks required by the storage cards are not affected by how the airplane is housed either. ATSR operates a single dayshift crew so lighting is not an issue. Ventilation, temperature, humidity, and other climatic conditions are naturally maintained to a sufficient degree to comply with standards. Parts removed for storage purposes will be maintained inside current facility, which has sufficient space for segregation or will be shipped out per customer requirements.

ATSR has received letters of support from the offices of New Mexico Senators Tom Udall and Martin Heinrich, as well as, New Mexico’ s Governor, Susana Martinez, New Mexico’s State Secretary Jon Barela
, Roswell Mayor Dennis Kintigh and Roswell City Manager Steve Pol asek . ATSR currently does business with several aircraft companies a nd has an established list of customers from around the country, including major airlines that would like to do business with ATSR, but require the 145 certification. Additionally, ATSR c ontinually acquires tooling, equipment and personnel in preparation for performing the storage related maintenance on transport category aircraft under the terms of the proposed exemption.

ATSR assures that a level of safety equivalent to that provided by the regulations from which relief is sought would be maintained under the proposed exemption. ATSR has equipment and tooling suitable for use during the preservation of airplanes and is available for inspection at any time. ATSR provides equipment and op erational training to all applicable maintenance personnel.

ATSR maintains that granting the proposed exemption would be in the public interest. The state of New Mexico ranks in the bottom six for economic climate, maintains one of the highest unemployme nt rates and in particular, the city of Roswell ranks lower in median household income and highest in poverty and pub lic assistance. Granting the proposed exemption would allow ATSR to grow, providing high tech, high income employment opportunities from wi thin state and out of state , thereby pumping muchneeded income into local businesses, grocery and housing markets . High tech jobs would also help the

local university (Eastern New Mexico University Roswell) by providing opportunities for graduate job placement and advancing the current aviation based curriculum. Additionally, the proposed exemption would allow ATSR t o provide major airlines and aviation based customers from all over the country with an ideal l ocation to store their aircraft.

Please also note that Exemption No. 7364 was granted to Southern California Aviation, Inc., under similar circumstances on Octo ber 6, 2000.