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F -1 I (~RS c:JSJJ' R362TJ 

October 7, 2015 

Docket Management Facility 

US Department of Transportation 

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 2 
Issuance 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 of Quality I Chief Inspector 

Stewart Industries lnt'l Roswell LLC 

605 E Challenger 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 2 
D5XR212Y 

Dale Mullinax 

Director of MRO Operations 

Stewart Industries 

605 E Challenger 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 or other such 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 

FAA Approved Repair Station II D5XR212Y 

Phone (575) 347·4168 

Fax (575) 347·4172 

dean baldwin paintiQg 

New Mexico ·Texas • Indiana 

www.deanbaldwinpelntlng .com 

Corporate Officerrexas Facility 

2395 Bulverde Road 

Suite 105 

Bulverde, Texas 78163 

Phone (830) 438·5340 

Fax (030) 438·5345 
U.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. g ov I a bout/office_ org/li eld _ offices/fs doll b b/ 

In our letter dated May 15, 2015, we responded to a proposed revision of your Repair Station Manual. 

The revision incorporated Roswell Airport Building 1083 as pa1t of your 14 CFR Part 145 Repair 

Station. Our research revealed that another repair station currenLly operates in, and has exclusive 

control of building 1083. It is our understanding your proposed agreement with th is repair station is 

intended to address the housing requirements of 14 CFR § t 45.1 03(b ). 

We have reviewed the proposed hangar agreement, FAA legal interpretations of§ 145.1 03(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 of the 

building/hangar spa,cc. We do not believe that this building agreement meets the intent of 

§ 145.103(b) as Dean Baldwin currently contro ls 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 of aircraft (i.e., Boeing 74 7) currently listed 

on your Capabilities List. 

Based on our review, we propose you tm.mediately amend your Capabilities LisL lu r~muvt those 

aircraft you cannot fully enclose within the faci lities you control. Continued operations using your 

current Capabilities List may be in violation or pertinent Federal Regulations. 

Please contact us if you have any questions. 

Sincerely, 

Principal Maintenance Inspector 
r 

·~ 

FAA RE:PAIR s-r ATIOI< #3SWR362[J, 

MEMBEr< OF THE Sll GROUP 575-34 7-2052 

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 of your letter dated 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 of the 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 =~eeY ·ely. , , _ _ 

{ !J A ,., / I \ I \../ L/. '--'7----·l _____ .,· 

Kndrea Fitzsimmons 

Accountable Manager, Stewart Industries International Roswell, LLC 

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