# ~.i 

# ... ®

# ~1per
June 1, 2012 U.S. Department ofTransportation 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. 10115 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 ofthe United States as defined by 49 USC §401 02(a)(15)(c). In support of this petition, Piper states that it is incorporated underthe laws ofthe 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 ofthe 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 0-0749 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 ofthis letter and supporting documentation that an extension to FAA-2010-0749 be granted. Ifyou require any further information in support ofthis 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



### ByFDMS/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 musthave an established place ofbusiness in the United States, mustbe substantially engaged in the manufacturing or selling ofaircraft and mustbe a citizen ofthe United States as defmed by49 USC §40102(a)(15)(C). In support ofthis petition, Piper states that it is incorporated under the laws ofthe State of Delaware, it has an established place ofbusiness in the State ofFlorida where it is headquartered and it is substantiaiiy engaged in the manufacturing ofaircraft. As a result ofits May 2009 acquisitionbyPiper Holdings Cooperatief, a Dutch company, Piper no longer meets one ofthe United States citizenship criteria under 49 USC §40102(a)(15)(C) (that relating to citizenship ofshareholders). Itis for this reason that Piper submits this petition. Webelieve that good cause exists for the FAA to grant this petitionbecause the requested exemption would not set a precedent and delay in acting on this petition would be detrimental to Piper. Issuance ofa 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 timelymanner. Itwould also benefit the FAA byreducing the number 

### ofapplications for registration processed and certificates issued bythe FAA. Piperunderstands 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'sAircraftRegistration Cert{ficate. I am attaching a summary ofourresponses to the required items in the format set forth in 14 CPR §11.81 for your convenience. Ifyou require any further information in support ofthis petition,

• 2926 PIPERDRIVE • VERO BEACH FLORIDA 32960 • TEL772.567.4361 •

# 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 ofresponses to the enumerated information that mustbe included in a petition for an exemption as set forth in 14 CFR 

### §11.81 : 

### (a) Yourname and mailing address and, ifyou wish, other contactinformation such as a fax number, telephonenumber, or e-mail address; PiperAircraft, 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 CFRfrom which you seek an exemption; Title 14 Code ofFederal Regulations Section 47.65 (14 CFR §47.65).


### (c) The extent ofreliefyou seek, andthe reason you seekthe relief; Piper seeks relieffrom the citizenship requirements set forth in 14 CFR §47.65 because as a result ofits May 2009 acquisition byPiperHoldings Cooperatief, a Dutch company, Piper no longermeets the United States citizenship requirement of 14 CFR §47.65. Specifically, 14 CFR §47.65 requires meeting the citizenship criteria under49 USC .§401 02(a)(15)(C). As a result of the aforementioned acquisition, Piperdoes not meettherequirements relatingto citizenship of**~h,...,.~k."l,..lo.,..,.,** .,11Gll VllUiUCI-1..:). 

### (d) The reasons why grantingyour request would bein the public interest; thatis, how it would benefit the public as a whole; Granting this request would permit issuance ofa Dealer's Aircraft Registration Certificate to Piper. This would be inthe public interestbecause it would enable the flight test and demonstration ofPiper's US-manufactured aircraft in a more timely manner than ifother forms ofrecistration were sought for individual aircraft. Itwould also benefit the FAAbvreducing the

....... ......... ., ....... number ofapplications for registrationprocessed and certificates issued by the FAA. 

### (e) The reasons why grantingthe exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety atleast equal to that provided by the rule from which you seek the exemption;

• 2926 PIPERDRIVE • VERO BEACH FLORIDA 32960 • TEL 772.567.4361 •

### •

# .~ 

# ... 1per Granting this request would not adversely affect safety. To the contrarythis exemption would enhance safetybyfacilitating flight test and demonstration ofthese aircraft under FAA registration. (f) A summary we can publish in the FederalRegister, stating: (1) The rule from which you seekthe exemption; and (2) A briefdescription ofthe nature ofthe 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. Piperis incorporated ul).der the laws ofthe State ofDelaware, has an established place ofbusiness in the State ofFlorida where it is headquartered and it is substantially engaged in the manufacturing of aircraft. However, as a result ofits May2009 acquisition byPiper Holdings Cooperatief, a Dutch company, Piperno longer meets one ofthe United States citizenship criteria under49 USC §40102(a)(15)(C) (that relating to citizenship ofshareholders). Granting ofthis exemption would permit issuance ofa Dealer's Aircraft Registration Certificate and would enhance safety and facilitate flight test and demonstration ofthese aircraft under FAAregistration. It would also benefit the FAAbyreducing the number ofapplications for registration processed and certificates issued bythe FAA. (g) Any additional information,views or arguments available to supportyour request; and See the attached petition letter. (h) Ifyou wantto exercise the privileges ofyour exemption outside the United States, the reason why you need to do so. Piper does not seek to exercise the privileges ofthe requested exemption outside the United States.

• 2926 PIPERDRIVE • VERO BEACHFLORIDA 32960 • TEL 772.567.4361 •US Deportment ofTransportation 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



### ExemptionNo. 10115 800 Independence Ave

.. SW. Washington. D.C. 20591



### Regulatory Docket No. FAA-2010-0749

This lette! is to.info.rm yo1:1 t4at 'Ye**]lay~** 

### _ _granted yourrequest.for**~X~Illption_.** 

### It**tran~mits** 

### our__ decision, explains its basis, and gives youthe conditions and limitations ofthe exemption. The Basis for OurDecision By letter dated July 22, 2010, youpetitioned the Federal Aviation Administration (FAA) on behalfofPiper Aircraft, Inc. (Piper) for an exemption from§ 47.65 ofTitle 14, Code of Federal Regulations (14 CPR) to the extent necessary to allowPiper to obtain a Dealer's Aircraft Registration Certificate without meeting the U.S. citizenship requirements. The FAAhas determined that good cause exists for not publishing a summary ofthe petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting onthis petition would be detrimental to Piper. The FAAhas issued a grant ofexemption in circumstances similar in all material respects to those presented in yourpetition. In Grant ofExemptionNo. 5259 (copy enclosed), the FAA found that issuance ofa Dealer's Aircraft Registration Certificate would facilitate the petitioner's operation by eliminating the requirement to obtain a certificate ofregistration for each aircraft and thus enable it to test and demonstrate aircraft in a more timely manner. It 

### would also benefit the FAAby reducing the number ofapplications 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 ofthe State ofDelaware, has an established place ofbusiness in the State ofFlorida where it is headquartered, and is substantially engaged inmanufacturing ofaircraft. fu addition, Piper states that as a result ofits May 2009 acquisition by Piper Holdings Cooperatief, a Dutch company, PiperAircraft, fuc., the holder ofa 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 that

### 2

• they do not differ materially from those presented by the petitioner in the enclosed grant of exemption; • the reasons stated bythe FAA for granting the enclosed exemption also apply to the situation you present; and • a grant ofexemption is in the public interest. OurDecision 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 Piperto 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 exemptionpertains to citizenship requirements only. Piper must adhere to all otherrequirements 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 ofa 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 EnclosureAttachment 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 ofthe

### -~··L date ofthts 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 ofTransportation 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. Ifyou have already requested an extension for this exemption or no longer need this exemption, please ignore this notice. · Vice President and General Counsel PiperAircraft Inc. 2926 PiperDrive Vero Beach, FL 32960