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 denied your petition for rulemaking. It transmits 

our decision and explains its basis. 

The Basis for Our Decision 

This is in response to your September 7, 2009, letter to Mr. Javier Rodriguez, Mr. Carlos 

Grillo, and Mr. Donald Schoonover with the Federal Aviation Administration (FAA) 

Flight Standards District Office in Miami, Florida. You petitioned for rulemaking, on 

behalf of F&E Aircraft Maintenance (MIAMI) LLC, CRS # F8ER2322Y, to amend 

part 145 of Title 14, Code of Federal Regulations (14 CFR). 

Your letter voices concern about the current practice of maintaining FAA Operations 

Specifications (OpSpec) paragraph 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 elevated to the Federal Aviation 

Regulations rulemakers in Washington, D.C., for review and consideration. 

OpSpec paragraph D107 authorizes approved repair 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 repair 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 authorization to provide 

maintenance support to an air carrier certificated under part 121, part 135, or a foreign air 

carrier or foreign person operating a U.S.-registered aircraft in common carriage under 

part 129. The repair station should not perform line maintenance beyond the scope of its 

ratings and authorizations indicated in its OpSpecs. Further, a repair station can only 

perform line maintenance at the main base or locations listed in OpSpec D107. 
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Presently, your repair station performs line maintenance to several U.S. air carriers and 

foreign air carriers at eight locations throughout the United States. If the FAA was to 

reflect line maintenance as a limited airframe 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 OpSpecs. 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 

 Service 
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