**Contact Information:**

Gulfstream Aerospace Corporation, Inc. (“Gulfstream”) P. O. Box 2206 Savannah, GA 31402 Tony Costa Senior Quality Manager/Chief Inspector anthony.costa@gulfstream.com Office: 912
-965
-5854 Mobile: 912
-667
-3631 Max Mills Director of Quality and Product Safety max.mills@gulfstream.com Office: 912
-965
-3355 Mobile: 912
-658
-7991 **The Exemption:** Within the guidance of Order 8900.1, Volume 2, Section 2, paragraph 2
-1214 (F)(3), Gulfstream Aerospace Corporation, Inc. (“Gulfstream”) hereby petitions for a permanent exemption to 14 CFR 145.107(a)(1) of the Federal Regulations

. Gulfstream is in pursu it of a managerial/satellite repair station and seeks an exemption to not have the managerial repair station hold a rating equal to or greater than the satellite repair stations. **Rationale for Exemption request:** The Gulfstream Savannah Product Support repair station will be the repair station with managerial control under a satellite organization with Limited Airframe ratings; where as some of the Gulfstream repair stations have one or more Airframe class ratings. All Gulfstream repair stations with Airframe ratings have Limited Powerplant ratings and under the guidance for an exemption , an exemption for a Power Plant rating would not be applicable. The Savannah Product Support repair station does have Class 1, 2, and 3 ratings for Radio, Accessories and Instrument, which equal or exceed all other Gulfstream satellite repair station ratings and are not applicable to this petition for exemption

. Gulfstream’s headquarters is in Savannah, GA and most of the Enterprise functions critical to the success of the managerial repair station (Corporate Quality Office, SMS office, and COS office) are located in Savannah. In addition, the current FAA Flight Standards office in Atlanta already provides a high level of dedicated manpower to Gulfstream oversight

.In reviewing the requirement of 14 CFR 145.107(a)(1) and the associated guidance, the

only regulatory concern Gulfstream can foresee is a potential for a Supervisor or Inspector from the repair station with managerial control, to be shared with a satellite repair station and those individuals not having the experience required on an article to be supervised by him or her

. Gulfstream addresses this potential concern as follows: It is understood that each Supervisor and Inspector must be certificated in accordance with 14 CFR 145.153 and 145.155 and under the limitation as noted in 14 CFR 65.81

. Supervisors in the Savannah Product Support repair station that supervise airframe maintenance are all certificated Airframe and Powerplant Technicians

. While it is not a Gulfstream practice to share supervisory personnel between repair stations, a stipulation will be placed in the enterprise Repair Station/Quality Control Manual that will only allow Gulfstream Savannah supervisory personnel, dispatched to other Gulfstream repair stations, to be restricted to supervision of Gulfstream model airframes, as listed in the repair station, GR4R216M, Operational Specifications page A003
-1.
**Control Measures** To assu re compliance, Gulfstream has three levels of auditing: 1. Each Gulfstream repair station has an audit system in place to identify and take corrective action on deficiencies in accordance with 145.211 (c)(1)(ix)

. 2. Gulfstream Corporate Quality Assurance, on a routine bases, audits all Gulfstream repair stations for compliance to 14 CFR part 43 and 145. 3. An SMS program which allows any discrepancies to regulation and safety to be identified by employees at the lowest level. Applicable discrepancies are rolled back into our requirements under 145.211 (c)(1)(ix)

. Within the Gulfstream intranet, all Gulfstream repair stations and rosters are available for review in accordance with 14 CFR145.161. In addition, training records are available for review at all repair stations through the corporate intranet and it is the responsibility of each manager at the next upper level to validate that people within their repair station or shared from another Gulfstream repair station , are only assigned to supervise or inspect the work they have training or experience on

. **Effect on Safety** A review of our audit programs, SMS risk analysis and past FAA surveillance discrepancies, shows no instances of shared unqualified individuals supervising work performed at any of the Gulfstream repair stations with airframe class ratings. Gulfstream does not see where this exemption request would adversely affect safety

.**Best Interest to the Public**

In the best interest of the public, some of the Gulfstream repair stations, in addition to supporting the Gulfstream fleet, have Airframe Class ratings to support the local and transient CFR part 23 and part 25 aircraft flying public by providing the availability of services on a routine and non
-routine basis. In addition, although not implemented, the FAA, in the Federal Register Volume 77, number 98 (Monday, May 21, 2012) NPRM Paragraph II (5)(iv)(h), had proposed to remove this requirement and we cannot find any other past submittal or cause for rejection

. h. Satellite Repair Stations (Current Sec. 145.107/Proposed Sec. 145.1107) In proposed Sec. 145.1107(a), the FAA proposes to remove the current restriction in Sec. 145.107(a)(1) that a satellite repair station may not hold a rating not held by the certificated repair station with managerial control. The FAA believes that the agency should not impose these restrictions on satellite repair stations.
**Conclusion** The granting of this petition does not add any additional expense to the FAA in their surveillance requirements and may be less costly with the current CMU team which has geographic oversight of the Southeast repair stations (Savannah Product Support Service Center, Savannah Final Phase, Savannah Manufacturer’s Repair Station and Brunswick Repair Station.) Gulfstream anticipates the addition of domestic Repair Stations in the future as business needs dictate; the permanent granting of this exemption would relieve future complications with the addition of domestic capability. Not granting this petition will increase costs and man hours required by the FAA to revise repair station Operation Specifications for six of the eleven Gulfstream repair stations. For Gulfstream, changes to the Operation Specifications would require up to twenty
-six revision submissions to foreign NAA’s with a potential cost exceeding $100,000.00 between certificate change fees and potential audits due to repair station certificate changes With no impact to safety and the past proposed NPRM to remove the requirement, if there are specific regulatory concerns; Gulfstream requests specific concerns be identified to develop appropriate mitigation strategies. **Summary**Gulfstream Aerospace Corporation, Inc. (“Gulfstream”) petitions the FAA for a

permanent exemption from 14 CFR 145.107(a)(1)

. Approval of this petition will allow Gulfstream to form a satellite repair station organization without the repair station with managerial control having all of the same ratings as its satellite repair stations. There will be no impact to safety and at the same time would allow Gulfstream repair stations to continue to serve the general aviation public.