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 

pursuit 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 assure 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.