U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Mr. Nicolas Finazzo 

Chief Executive Officer 

AerSale 

121 Alhambra Plaza 

Suite 1700 

Coral Gables, FL 33134 

MAR -4 2015 

Office of the Chief Counsel 

800 Independence Ave., SW. 

Washington, DC 20591 

Re: Request for Interpretation on Whether 14 C.P.R.§ 145.103(b) 

Requires a Repair Station with a Limited Airframe Rating to 

Have Housing Large Enough to Enclose the Largest Aircraft 

Listed on its Operations Specifications 

Dear Mr. Finazzo: 

This letter responds to your October 9, 2014 request for a legal opinion on the applicability of the 

housing requirement in 14 C.P.R. § 145.103(b) to an FAA-cetiificated repair station holding a 

limited airframe rating. You state that your company, AerSale, holds an FAA-issued air agency 

certificate, which authorizes it to operate as a repair station with, among other things, a limited 

airframe rating. AerSale's limited airframe rating includes, by reference to its FAA-accepted 

Capability List, Boeing Model 747 aircraft listed on the company's Operations Specifications. 

You asked for an advisory opinion on the question: "Must a FAR Part 145 Repair Station 

holding a Limited Airframe Rating have a hangar to house the largest aircraft on its Operations 

Specifications if the maintenance it is authorized to do under its Capability List on its largest 

aircraft do not require such work be performed inside a hangar?" The answer is yes. Because a 

limited airframe rating is an airframe rating, AerSale must have a hangar to enclose a Boeing 

Model 747 because that is the largest aircraft listed on AerSale's operations specifications. 

Section 145.103(b) provides: 

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. 

To the extent that AerSale suggests that § 145.103 (b) applies only to a repair station holding a 

class airframe rating issued under§ 145.59(a), thereby excluding a repair station with a limited 

airframe rating issued under§ 145.61 from the reach ofthe regulation, the FAA does not agree. 
Nothing in the regulatory history or the plain language of the regulation supports a conclusion 

that the airframe rating of§ 145.103(b) applies only to class airframe ratings and excludes 

limited airframe ratings. 

In support of your position that a repair station holding a limited airframe rating is not required 

2 

to provide a hangar large enough to enclose the largest aircraft on its operations specifications (in 

AerSale's case a Boeing Model 747), you referenced a statement in the agency's denial of an 

exemption request that addressed this issue: In the matter of the petition of Short Brothers PLC 

[Shorts], Docket No. FAA-2009-0084. The FAA's denial ofthe requested exemption found that 

what Shmis sought to do did not require relief from§ 145.103(b), but instead could be permitted 

under a different regulation that was more directly on point-§ 145.203, which permits a repair 

station to perform maintenance at a place other than its fixed location if the repair station meets 

the criteria of that section. Accordingly, under the facts presented, Shorts did not need an 

exemption from the housing requirement or any other regulation. While the Shorts denial 

appeared to distinguish between repair stations that hold only a limited airframe rating and those 

that hold a class airframe rating for purposes of a § 145.1 03(b) analysis, this discussion 

distinguishing between a limited airframe rating and a class airframe rating was dicta-not 

necessary for the agency's decision-and it reflected an incorrect interpretation of the agency's 

regulation. 

This response was prepared by Edmund Averman and Benjamin Borelli, attomeys in the 

Regulations Division in the Office of the Chief Counsel, and coordinated with the Aircraft 

Maintenance Division (AFS-300) in the Flight Standards Service. If you have additional 

questions regarding this matter, please contact us at your convenience at (202) 267-3073.