August 31, 2011

Mr. Carl Pascual Director of Quality Control F&E Aircraft Maintenance (MIAMI), LLC

P.O. Box 660707 Miami Springs, FL 33266

Dear Mr. Pascual:

This letter is to inform you that we have de nied your petition for rulemaking. It transmits our decision and explains its basis.

The Basis for Our Decision

This is in response to your Septem ber 7, 2009, le tter to Mr. Javier R odriguez, Mr. Carlos Grillo, and Mr. Donald Schoonover with the Federal Aviation Ad ministration (FAA) Flight Standards District Office in Miami, Florida. You petitioned for rulemaking, on

behalf of F&E Aircraft Maintenance (MIAMI) LLC, CRS # F8 ER2322Y, to amend part 145 of Title 14, Code of Federal Regulations (14 CFR).

Your letter voices concern about the curre nt practice of maintaining FAA Operations Specifications (OpSpec) para graph D107, Line Maintenance Authorization. You request the FAA recognize “line maintenance” as a “ limited airframe rating,” rather than an “authorization.” Finally, you request your letter be elevat ed to the Federal Aviation Regulations rulemakers in Washington, D.C., for review and consideration.

OpSpec paragraph D107 authorizes approved repa ir stations to perform line maintenance

at a location other than the fixed base of operation, referenced in OpSpec paragraph A003. For repair stations, OpSpec paragraph A003, Airplane/Aircraft Authorization, references ratings, capability list, and the repa ir station’s fixed base of operation. OpSpec paragraph D107 is also issued to a repair station that only performs line station maintenance at the fixed base of operation referenced in OpSpec paragraph A003. In either case, the repair station must at least hold a limited airframe or airframe class rating to perform the maintenance associated with the line maintenance authorization. The

FAA does not consider line maintenance as a rating but as an aut horization to provide maintenance support to an air carrier certificat ed under part 121, part 135, or a foreign air carrier or foreign person ope rating a U.S.-registered airc raft in common carriage under part 129. The repair station should not perf orm line maintenance beyond the scope of its ratings and authorizations indi cated in its OpSpecs. Furthe r, a repair station can only perform line maintenance at the main ba se or locations listed in OpSpec D107.2

Presently, your repair station performs line maintenance to se veral U.S. air carriers and foreign air carriers at eight locations thr oughout the United States. If the FAA was to

reflect line maintenance as a limited airfra me rating, you would have to account for the additional eight line maintenance locations as additional fixed locations (within close proximity to the main base), satellite repair station facility, or stand alone certificated repair station, which are maintained via Op Specs. We would like to inform you the FAA maintains electronic Web OpSpecs that would aid in maintaining revisions to OpSpecs.

Based on the criteria above, we have reviewed your petition and determined that a change to the present FAA policy for the authorization of line station maintenance is not warranted and you have not raised a safety concern.

Our Decision

Pursuant to the authority contained in 49 U.S.C. §§ 40113 and 44701 delegated to me by the Administrator, your petition for rulemaking is hereby denied.

Sincerely,

/s/

John W. McGraw Acting Director, Flight Standards

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