~.i ... ® 

~1per 

June 1, 2012 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor, 

Room W12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

j;i ~ l" IJit,l -l A II: I I' l.t!t_ .._,JII \ "-t 

Subject: Exemption No. 1 0115 extension request- Docket F AA-201 0-07 49 

Docket Operations, 

Piper Aircraft, Inc. ("Piper") herby partitions the Federal Aviation Administration for an 

extension to exemption 10115, Docket FAA-2010-0749 from Title 14 Code of Federal 

Regulations Section 47.65 (14 CFR §47.65) to permit Piper to continue its Dealer's 

Aircraft Registration Certificate without meeting the United States citizenship 

requirements. 

14 CFR §47.65 provides that to be eligible for a Dealer's Aircraft Registration 

Certificate, the applicant must have an established place of business in the United 

States, must be substantially engaged in the manufacturing or selling of aircraft of 

aircraft and must be a citizen of the United States as defined by 49 USC 

§401 02(a)(15)(c). 

In support of this petition, Piper states that it is incorporated under the laws of the State 

of Delaware, it has an established place of business in the State of Florida where it is 

headquartered and it is substantially engaged in the manufacturing of aircraft. 

As a result of its May 2009 acquisition by Piper Holdings Cooperatief, a Dutch company, 

Piper no longer met one of the United States criteria under 49 USC §401 02(a)(15)(C) 

relating to citizenship of shareholders. As such, Piper submitted a petition request by 

letter on July 22, 2010 for FAA exemption to this requirement. Exemption Number 

10115, Regulatory Docket Number FAA-201 0-07 49 granted Piper's exemption request 

on August 13, 2010. 

Per DOT/FAA emption extension request (attachment C), Piper is attaching copies of its 

original request petition (attachment A) and a copy of the FAA exemption grant 

(attachment B) and submits that all statements made in its original petition still hold true 

• 2926 PIPER DRIVE • VERO BEACH FLORIDA 32960 • TEL 772.567.4361 
~- .i~ ® r-lper 

and factual. Piper petitions by way of this letter and supporting documentation that an 

extension to FAA-2010-0749 be granted. 

If you require any further information in support of this emption extension request, 

please contact Jeffrey A. Rogers (772-299-2357; jeffrey.rogers@piper.com) or, in the 

alternative, me directly (772-299-2349; mike.hinderberger@piper.com ). 

Thank you for your cooperation. 

Sincerely, 

tf£1£~ Vice President Engineering and Operations 

mike.hinderberger@piper.com 1 www.piper.com 

P: 1.772.299.2349 I F: 1.772.978.65621 C: 1.772.473.2006 

Piper Aircraft, Inc., 2926 Piper Drive, Vera Beach, FL 32960 

Attachments 

(A) Piper Aircraft Petition for Exemption, dated July 22, 2010 

(B) Regulatory Docket No. FAA-2010-0749, dated August 13,2010 

(C) FAA Notification for exemption extension, rec'd 5/2/2012 by mail 

Cc: Jennifer M. Anderson, ASI OMIDO 

Francis J. Harkins, Piper Aircraft Vice President & General Counsel 

Jeffrey A. Rogers, Piper Aircraft Quality Systems Manager and FAA MIDO Liaison 

• 2926 PIPER DRIVE • VERO BEACH FLORIDA 32960 • TEL 772.567.4361 
.~ .... 1per 

July22, 2010 

Mr. Jolm M. Allen 

Director, Flight Standards Service 

Federal Aviation Administration 

Room 821 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Dear Mr. Allen: 

Attachment A (4 pages) 

Piper Aircraft 

Docket No. FAA-2010-0749 

6/1/2012 

By FDMS/FedEx 

Piper Aircraft, Inc. ("Piper") hereby petitions the Federal Aviation Administration for an 

exemption from Title 14 Code ofFederal Regulations Section 47.65 (14 CFR §47.65) to permit 

Piper to obtain a Dealer's Aircraft Registration Certificate without meeting the United States 

citizenship requirements. 

14 CFR §47.65 provides that to be eligible for a Dealer's Aircraft Registration Certificate, the 

applicant must have an established place of business in the United States, must be substantially 

engaged in the manufacturing or selling of aircraft and must be a citizen of the United States as 

defmed by 49 USC §40102(a)(15)(C). 

In support of this petition, Piper states that it is incorporated under the laws of the State of 

Delaware, it has an established place of business in the State of Florida where it is headquartered 

and it is substantiaiiy engaged in the manufacturing of aircraft. 

As a result of its May 2009 acquisition by Piper Holdings Cooperatief, a Dutch company, Piper 

no longer meets one of the United States citizenship criteria under 49 USC §40102(a)(15)(C) 

(that relating to citizenship of shareholders). It is for this reason that Piper submits this petition. 

We believe that good cause exists for the FAA to grant this petition because the requested 

exemption would not set a precedent and delay in acting on this petition would be detrimental to 

Piper. Issuance of a Dealer's Aircraft Registration Certificate would facilitate Piper's operation hu P11rnirl':.t~nn thP r,:~o.nn1rPTn~nt tn nht~J~~'t"'' -::. ,....ort;f';,....Qta n..fT'omC"trtJf-;nn .f.;._...,. oonh o~-rl"'rl'lft- ,....,,-1 +'h,-u·• VJ Vl..UUU.J.U.1.J.U,5 LllV 1.V"fUll.VJ1J.V11\. LV VULUlJ..l U \..oV.lU.l.H..•UU.• V.l J\.1,51o:lUUL-JVJl lVl \.ICI.Vll QJ.l\.llUU., Q.UU llJU~ 

enable it to test and demonstrate aircraft in a more timely manner. It would also benefit the FAA 

by reducing the number of applications for registration processed and certificates issued by the 

FAA. 

Piper understands that should this exemption be granted, it would pertain to citizenship 

requirements only. Piper will adhere to all other requirements and limitations set fm1h in 14 

CFR Part 47, Subpart C, Dealer's Aircraft Registration Cert{ficate. 

I am attaching a summary of our responses to the required items in the format set forth in 14 CPR 

§ 11.81 for your convenience. If you require any further information in support of this petition, 

• 2926 PIPER DRIVE • VERO BEACH FLORIDA 32960 • TEL 772.567.4361 • 
P . ~it.. . 1per 

please contact Alex Valderrey (772-299-2674; alex.valderrey@piper.com) or, in the alterp.ative, 

me directly (772.299.2776; frank.harkins@piper.com). 

Thank you for your cooperation. 

Sincerely, 

Francis J. Har ns 

Vice President & General Counsel 

Attachment 

cc: Jennifer Anderson 

M. Dombroff, Esq. 

G. Koenig, Esq. A ,T...,.1Aorro"t:r L'"l... VOJ.U\...111'-'J 

• 2926 PIPER DRIVE • VERO BEACH FLORIDA 32960 • TEL 772.567.4361 • 
.~ .. e lper 

The following is a summary of responses to the enumerated information that must be included in 

a petition for an exemption as set forth in 14 CFR § 11.81 : 

(a) Your name and mailing address and, if you wish, other contact information such as a 

fax number, telephone number, or e-mail address; 

Piper Aircraft, Inc. 

Attn: Francis Harkins 

Vice President & General Counsel 

2926 Piper Drive 

Vero Beach, FL 32960 

Telephone: (772) 299-2776 

Fax: (772) 978-6562 

Email: frank.harkins@piper.com 

(b) The specific section or sections of 14 CFR from which you seek an exemption; 

Title 14 Code ofFederal Regulations Section 47.65 (14 CFR §47.65). 

(c) The extent of relief you seek, and the reason you seek the relief; 

Piper seeks relief from the citizenship requirements set forth in 14 CFR §47.65 because as a 

result of its May 2009 acquisition by Piper Holdings Cooperatief, a Dutch company, Piper no 

longer meets the United States citizenship requirement of 14 CFR §47.65. Specifically, 14 CFR 

§47 .65 requires meeting the citizenship criteria under 49 USC .§40 1 02( a)(15)(C). As a result of 

the aforementioned acquisition, Piper does not meet the requirements relating to citizenship of ~h,...,.~k."l,..lo.,..,., 

.,11Gll VllUiUCI-1..:). 

(d) The reasons why granting your request would be in the public interest; that is, how it 

would benefit the public as a whole; 

Granting this request would permit issuance of a Dealer's Aircraft Registration Certificate to 

Piper. This would be in the public interest because it would enable the flight test and 

demonstration of Piper's US-manufactured aircraft in a more timely manner than if other forms 

of recistration were sought for individual aircraft. It would also benefit the FAA bv reducing the ....... ......... ., ....... 

number of applications for registration processed and certificates issued by the FAA. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek the exemption; 

• 2926 PIPER DRIVE • VERO BEACH FLORIDA 32960 • TEL 772.567.4361 • 
• 

.~ ... 1per 

Granting this request would not adversely affect safety. To the contrary this exemption would 

enhance safety by facilitating flight test and demonstration of these aircraft under FAA 

registration. 

(f) A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

Piper Aircraft, Inc. seeks exemption from 14 CFR §47.65 to permit Piper to obtain a Dealer's 

Aircraft Registration Certificate without meeting United States citizenship requirements. Piper is 

incorporated ul).der the laws of the State of Delaware, has an established place ofbusiness in the 

State of Florida where it is headquartered and it is substantially engaged in the manufacturing of 

aircraft. However, as a result of its May 2009 acquisition by Piper Holdings Cooperatief, a 

Dutch company, Piper no longer meets one of the United States citizenship criteria under 49 

USC §40102(a)(15)(C) (that relating to citizenship of shareholders). Granting ofthis exemption 

would permit issuance of a Dealer's Aircraft Registration Certificate and would enhance safety 

and facilitate flight test and demonstration of these aircraft under FAA registration. It would also 

benefit the FAA by reducing the number of applications for registration processed and 

certificates issued by the FAA. 

(g) Any additional information, views or arguments available to support your request; and 

See the attached petition letter. 

(h) If you want to exercise the privileges of your exemption outside the United States, the 

reason why you need to do so. 

Piper does not seek to exercise the privileges of the requested exemption outside the United 

States. 

• 2926 PIPER DRIVE • VERO BEACH FLORIDA 32960 • TEL 772.567.4361 • 
US Deportment 

of Transportation 

Federal Aviation 

Administration 

August 13, 2010 

Ms. Francis J. Harkins 

Vice President and General Counsel 

Piper Aircraft, Inc. 

2926 Piper Drive 

Vero Beach, FL 32960 

Dear Ms. Harkins: 

Attachment B (2 pages) 

Piper Aircraft 

Docket No. FAA-2010-0749 

6/1/2012 

Exemption No. 10115 

800 Independence Ave .. SW. 

Washington. D.C. 20591 

Regulatory Docket No. F AA-201 0-0749 

This lette! is to. info.rm yo1:1 t4at 'Ye ]lay~ _ _granted your request .for ~X~Illption_. It tran~mits our __ 

decision, explains its basis, and gives you the conditions and limitations of the exemption. 

The Basis for Our Decision 

By letter dated July 22, 2010, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Piper Aircraft, Inc. (Piper) for an exemption from§ 47.65 of Title 14, Code of 

Federal Regulations (14 CPR) to the extent necessary to allow Piper to obtain a Dealer's 

Aircraft Registration Certificate without meeting the U.S. citizenship requirements. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Piper. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 5259 (copy enclosed), the FAA 

found that issuance of a Dealer's Aircraft Registration Certificate would facilitate the 

petitioner's operation by eliminating the requirement to obtain a certificate of registration for 

each aircraft and thus enable it to test and demonstrate aircraft in a more timely manner. It 

would also benefit the FAA by reducing the number of applications for registration processed 

and certificates issued by the FAA. 

AFS-10-349-E 
Piper has petitioned for an exemption from§ 47.65 under circumstances similar to those 

above. The petitioner states that it is incorporated under the laws of the State of Delaware, 

has an established place of business in the State of Florida where it is headquartered, and is 

substantially engaged in manufacturing of aircraft. 

fu addition, Piper states that as a result of its May 2009 acquisition by Piper Holdings 

Cooperatief, a Dutch company, Piper Aircraft, fuc., the holder of a valid Dealer's Aircraft 

Registration Certificate, no longer qualifies as a U.S. citizen corporation as defined by 

49 U.S.C. 40102(a)(15). 

Having reviewed your reasons for requesting an exemption, I fmd that2 

• they do not differ materially from those presented by the petitioner in the enclosed grant of 

exemption; 

• the reasons stated by the FAA for granting the enclosed exemption also apply to the 

situation you present; and 

• a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant Piper Aircraft, fuc., an exemption from 14 CFR § 47.65 to 

the extent necessary to allow Piper to obtain a Dealer's Aircraft Registration Certificate 

without meeting U.S. citizenship requirements, subject to the conditions and limits described 

below. 

Conditions and Limitations 

1. This exemption pertains to citizenship requirements only. Piper must adhere to all 

other requirements and limitations ofthe Dealer's Aircraft Registration Certificate 

as stated in 14 CFR Part 47, Subpart C- Dealer's Aircraft Registration Certificate. 

2. Piper will be issued a Dealer's Aircraft Registration Certificate upon receipt of a 

completed Dealer's Aircraft Registration Certificate Application and the required 

fee. 

This exemption is effective immediately and remains in effect unless sooner superseded or 

rescinded. 

Sincerely, 

Is/ 

Raymond Towles 

Acting Director, Flight Standards Service 

Enclosure 
Attachment C {1 page) 

Piper Aircraft 

Docket No. FAA-2010-0749 

6/1/2012 

Date: 04/26/2012 

Exemption No: 10115 from 14 CFR (FAR Section)- ·~··~ • .~'9. Part: 47.65 J.:~ · ·-~.#.':.'!; will expire on 0813112012. If appropriate, please submit "_.ax ;.(~ .r.·".: 

your request to extend this exemption (including the · • : 

docket n~mber_FAA-2010-~749) within 30 days of the -~··L date of thts notice. Otherwtse, the FAA may not be able 1': -1- · • 

to process your request for extension before the :. t/. 

expiration date. You may either submit your request 

$00.329 

Mai!e<i From 20591 

US POSTAGE 

electronically through the internet using the Docket 

Management System web site at: 

http://Regulations.govl or mail your request to: 

Francis J. Harkins 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor, 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Submission to other locations may delay processing. 

Any request for extension must meet the 

requirements of 14 CFR part 11. If you have already 

requested an extension for this exemption or no longer 

need this exemption, please ignore this notice. · 

Vice President and General Counsel 

Piper Aircraft Inc. 

2926 Piper Drive 

Vero Beach, FL 

32960