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 without 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) Housing 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. Facilities 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 environmentally 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 stocked 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 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) A certificated repair station may perform maintenance, preventive maintenance, or alterations 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 supports 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 Industrial 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 

necessary 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 designed. 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 Polasek. ATSR currently does business 

with several aircraft companies and 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 continually 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 operational 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 unemployment rates 

and in particular, the city of Roswell ranks lower in median household income and highest in poverty 

and public assistance. Granting the proposed exemption would allow ATSR to grow, providing high tech, 

high income employment opportunities from within state and out of state, thereby pumping much 
needed 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 to provide major airlines and aviation based customers from all over the country with 

an ideal location to store their aircraft.

Please also note that Exemption No. 7364 was granted to Southern California Aviation, Inc., under 

similar circumstances on October 6, 2000.