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### October 7, 2015
Docket Management Facility US Department ofTransportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590 Re: Exemption from Section 145. 103 (b) 

### To Whom It May Concern : Stewart Industries, CRS#3SWR362B, operating in Roswell, New Mexico formally requests an exemption from 14 CFR §145.103(b) regarding "
...suitable permanent housing to enclose the largest type and model of aircraft listed on its operations specifications". Stewart Industries seeks an exemption to the requirement of providing suitable permanent housing based on the type of maintenance conducted at our 145 Repair Station. This exemption pertains to Boeing 757 and Boeing 767 aircraft. We chiefly perform storage for 121 Air Carrier American Airlines and leasing companies. The maintenance functions we perform in order to meet the storage requirements are not intended, nor required to be accomplished in a hangar. Our intent when placing an aircraft into storage configuration is to protect the aircraft from the elements, as it Is stored outside. We meet such requirements on our storage aircraft. Furthermore, the environment in Roswell, NM is ideal for outside storage of aircraft. American Airlines is aware of our inability to fit the above mentioned aircraft in our hangar. American Airlines finds our maintenance practices acceptable and laudable. We have hangar space and warehouse space for engines and any other removed parts to be stored in prior to shipment. All of our tooling and equipment needed for the maintenance we perform is also stored inside our hangar. We have an agreement with Dean Baldwin Painting, also located in Roswell, NM, to utilize their hangar space in an attempt to satisfy the requirements of §145
.103{b)
. Our local FSDO office in Lubbock, TX rejected our use of this facility
. Please see attached copy of letter from Dean Baldwin Painting and all pertinent correspondence. In addition, we removed all aircraft that will not fit inside Dean Baldwin's hangar from our Capabilities List.
PAGE 1 OF 2Issuance of an exemption to Stewart Industries would not adversely affect safety. We operate on a level of safety at least equal to the existing rule. Should an exemption not be granted to Stewart Industries, and operations would have to cease, the impact on the local economy would be detrimental to say the least. I kindly thank you for reviewing this matter. Please feel free to contact me with any questions, comments or concerns.

Andrea Fitzsimmons Director ofQuality 

## I Chief Inspector Stewart Industries lnt'l Roswell LLC 605 EChallenger St Roswell, NM 88203 Andrea.Fitzsimmons@siiair.com Office: {575) 347-2052 ext. 226 Fax: {575) 347-2085 Mobile: {575) 513-1415 Enclosures: Letter from Dean Baldwin Painting Letter from Steven Miller, Lubbock FSDO Letter addressed to Steven Miller, Lubbock FSDO

PAGE 2 OF 2D5XR212Y
Dale Mullinax Director of MRO Operations Stewart Industries 605 EChallenger St. Roswell, New Mexico 88203-8457
RE: Hanger Space
Dear Mr. Mullinax, April3, 2015

Dean Baldwin Painting LP is in agreement with Stewart Industries to utilize hanger space at our Roswell New Mexico facility. Dean Baldwin Painting lP will make space available to Stewart Industries based on Stewart Industries needs. This hanger space will be 100% enclosed and temperature controlled. Stewart Industries may use this space for task such as gear swings, washing of aircraft, weight and balance of aircraft orothersuch task which require an enclosed hanger
. Dean Baldwin Painting LP reserves the right to cancel or modify this agreement at any time.
Best Regards,

General Manager Dean Baldwin Painting LP 575-347-4168 ext.: 12 575-910-2790 FAX: 575-347-2244 jimb@deanbaldwinpainting.com

Naw Mexico

**Faclll~** 82 Earl Cummings loop West, Bldg 1 003 Roswell, New Mexico 08203 FAAApproved Repair Station II D5XR212Y Phone (575) 347·4168 Fax (575) 347·4172 

# deanbaldwinpaintiQg

New Mexico ·Texas • Indiana

www.deanbaldwinpelntlng
.com Corporate Officerrexas Facility 2395 Bulverde Road Suite 105 Bulverde, Texas 78163 Phone (830) 438·5340

Fax (030) 438·5345U.S. Deportment of Transportation Federal Aviation Administration 

## JUL 2 2 2015 Certified Mail- Return Receipt Requested Mr. Dustin D. Weller, Accountable Manager Stewart Industries International, Roswell LLC 605 East Challenger St. Roswell, NM 88203 Dear Mr. Weller: Flight Star.dards District Office 5225 South Loop 289, Suite 122 Lubbock, Texas 79424-1319 (806) 740-3800 Fax (806) 740-3869 (BOO) 858-4115 http:1/www.faa.govIabout/office_org/lield_offices/fsdollbb/

In our letter dated May 15, 2015, we responded to a proposed revision ofyour Repair Station Manual. The revision incorporated Roswell AirportBuilding 1083 as pa1tofyour 14 CFRPart 145 Repair Station. Our research revealed that another repair station currenLly operates in, and has exclusive control ofbuilding 1083. It is our understandingyour proposed agreement with this repair station is intended to address the housing requirements of 14 CFR §t45.103(b). We have reviewed the proposed hangaragreement, FAA legal interpretations of§145.103(b), and your current Capabilities List. Our review revealed the following concerns:
• The agreement with Dean Baldwin Painting, LP does nol indicate you have control ofthe building/hangar spa,cc. We do not believe that this building agreement meets the intent of 

### §1

45.103(b) as Dean Baldwin currentl y control s and/or operates their repair station in this facility.
• We have discussed the building agreement with Dean Baldwin management and they indicated building 1083 will not house a number ofaircraft (i.e., Boeing 747) currently listed on your Capabilities List. Based on ourreview, we propose you tm.mediately amend your Capabilities LisL lu

**r~muvt** those aircraft you cannotfully enclose within the facilities you control. Continued operations usingyour current Capabilities List may be in violation

# orpertinent Federal Regulations. Please contact us ifyou have any questions. Sincerely,

Principal Maintenance Inspectorr

**·~** FAA RE:PAIR 

### s-rATIOI< #3SWR362[J, MEMBEr< OF THE Sll GROUP 575-347-2052 FAX 575-347-2085 

### October 7, 2015 Steven Miller Lubbock - FSDO 5225 South Loop 289, Suite 122 Lubbock, TX 79424-1319 

## Re: 14 CFR 145.103 (b) 

### Dear Mr. Miller: ;r- · \\,7 

## ) i _;:j \lfv 

### Ll

I recently reviewed the correspondence between the former accountable manager, Dusty Weller, and yourself. As a result of my review ofyour letterdated July 22, 2015 addressed to Dusty Weller, please accept this letter as my formal appeal to your decision. Stewart Industries procured an agreement with Dean Baldwin Painting on April 3, 2015. This agreement allows Stewart Industries to utilize their hangar and schedule for use. In your response to this arrangement you state 'The agreement with Dean Baldwin Paining LP does not indicate you have control ofthe building/hangar space". 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". This section does not state we must have control of the building 

### I hangar space. It clearly states we must only provide suitable permanent housing. Regarding the second bullet in your letter stating building 1083 will not house some of our aircmft including Boeing 717 has resulted in those aircmft heino

**rP.mow~rl** 

### from our Capabilities List and therefore is no longer an issue. 

### I kindly thank you for reviewing this matter. Also, please feel free to contact me directly with any questions, comments or concerns . Si



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### Kndrea Fitzsimmons Accountable Manager, Stewart Industries International Roswell, LLC

605 E. Challenger St. • Roswell, NM 88203-8454