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Gulfstream Aerospace LP ¤ PO Box 1036 ¤ Airport City 70100 ¤ ISRAEL 

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 

December 18, 2013 GALP Ref: FAA/13195/CG 

Mr. Thomas Stafford 

Program Manager, International Branch, ANM-116

Federal Aviation Administration 

Transport Airplane Directorate 

Aircraft Certification 

Subject: Time Limited G280 FAA Exemption No. 10613 – Request for extension. 

Dear Mr. Stafford, 

On August 28, 2012 the Federal Aviation Administration granted exemption 10613 (petition and grant 

attached) for relief from the following parts of 14 CFR: 

 14 CFR §25.901(b)(1)(i) & (b)(2), §25.903(d)(2), 25.939(a), 25.1301(a),(c) & (d), 25.1309(c), 

25.1322 and 25.1549(a) 

Gulfstream Aerospace LP (GALP) originally requested four years in which to accomplish the 

development of an effective solution. FAA limited the exemption to two years as-granted. 

As-granted, the exemption covers a condition on the G280 airplane whereby an extremely remote risk 

of an Inter-Turbine Temperature (ITT) exceedance warning message might occur under certain 

conditions. 

Conditions for this to occur were specified by FAA in original Grant of Exemption: 

- Field elevation greater than 8,000 feet 

- Icing conditions present (less than 10 degrees C / visible moisture) 

- Pilot would have to fail to recognize icing potential and not activate the system prior to 

take-off or initiation of approach procedures 

- Co-pilot would have to overlook the pilot’s failure to activate the Wing Anti-Ice System 

despite defined procedures 

- Crew then recognizes the error and activates the WAI System while at take-off or goaround power 

Type Certification including Flight Into Known Icing was granted under the caveat of this exemption. 

GALP has been working diligently with IAI Engineering and Honeywell to meet the 2 year window 

that was originally granted, including the various target dates as outlined in the granted exemption. 

Every effort has been expended to develop system improvements that would optimize the aircraft 

and engine control system and indication software so as to preclude the possibility of an ITT 
 

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Gulfstream Aerospace LP ¤ PO Box 1036 ¤ Airport City 70100 ¤ ISRAEL 

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 

exceedance indication during certain high-bleed demand conditions within the requirements outlined 

by the exemption. 

GALP hereby requests additional time to effect a full remedy as technical development has proved 

as time-consuming as first envisioned by the original petition. GALP also holds that the original 

standing for no need of publication for comment remains valid as the original technical premise for 

the exemption remains not only valid, but is improved by progress to-date as outline herein. Further, 

the same business case exists and a delay would be costly in terms of public interest and to 

commerce. Substantial progress toward the demonstration of compliance to the affected regulations 

has been made and a path to a full solution is now before us. However, completion of development 

and implementation of a means to show full compliance will require an additional effort and time. 

Therefore GALP hereby requests additional time to be granted so as to effect a full remedy and by 

this request submits a basis for confidence: 

Substantial improvements have been developed and implemented in Honeywell FADEC Software V 

1.5. Additionally, further system improvements are currently in flight testing that will fully address the 

condition for all reasonable scenarios and permit full compliance: 

Two essential changes are planned: 

- FADEC Software Version V 1.5 implementation (TC MOD G25-20061) 

- GADC Software upgrade and introduction of a Crossover Duct Valve (TC MOD G25-10022) 

to remove ‘flow-hogging’ during dual-source (normal) demand conditions 

Milestones for the various design changes intended to provide interim mitigation and finally to reach 

full compliance and resolve the exemption issues, i.e. design approval milestones are as follows: 

- FADEC Software V1.5 – 

o FAA approved Honeywell Service Bulletin AS907-76-9016 is now released (FAR 

33 change); and a corresponding Gulfstream Service Bulletin is planned for 

release in January 2014. GALP intends to complete full fleet implementation no 

later than 30 September, 2014.. Production incorporation began with serial 

number 2034 (November 11, 2013) 

o Improvements: 

 FADEC V1.5 increases ITT limits from 946C to 955C to provide better 

airframe match / decrease ITT exceedance possibilities; also fine-tuned 

debit structure for dual-source in-air activation to alleviate ITT exceedance 

potential in certain conditions 

 Accordingly GALP notes an early and positive improvement to the 

reduction of exposure to possible ITT exceedance that is substantially in 

keeping both with the intent and timeline of the current exemption 

deadlines 

- GADC Software upgrade coupled with installation of a new Wing Anti-Ice Crossover Duct 

Valve to eliminate flow-hogging during dual source (normal) operations – 

o This design is being updated and tested for full optimization and is proving to be a 

solid way forward to solve the issues that remain after the FADEC V1.5 update 

o GADC Software Improvements: 

 Will control the Crossover Valve optimizing Wing Anti-Ice valve 

functionality, and minimizing WAI flow induced exceedance possibilities. . 

Certification and production cut in scheduled for April 2014 
 

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Gulfstream Aerospace LP ¤ PO Box 1036 ¤ Airport City 70100 ¤ ISRAEL 

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 

By this it can be seen that in spite of the significant efforts by all parties the current deadlines 

imposed by the existing exemption cannot be met. However, it is important to highlight that the 

public interest and safety aspects associated with this exemption are improved in comparison to 

those at the time of the granting of the exemption by virtue of the on going implementation of FADEC 

software V1.5 in production and in service which substantially reduces fleet exposure to the original 

event risk. Subsequent full compliance with the requirements set forth by the exemption is 

envisioned as the GADC Software upgrade and introduction of a Crossover Duct Valve is 

implemented following certification of this TC MOD. 

GALP therefore respectfully requests an extension per the above improvements to-date and as now 

forecast in lieu of the original dates required by the exemption as-granted in the “The FAA’s 

Decision” section of the exemption: 

- Item 1 – Validation and substantiation of operational conditions as specified by FAA – 

already satisfied prior to Type Certification and remaining compliant as-such 

- Item 2 – Airworthiness Limitation requirement imposed on the Instructions for Continued 

Airworthiness (ALS of the AMM) 

o Per this requirement the ALS section of the AMM contains the stipulated 

operational restricted deadline of September 30, 2014

o GALP respectfully requests consideration of an extension to December 31, 2015

 This time is needed to support the remaining developmental and/or 

implementation needs relevant to all required features – initially FADEC 

V1.5, and finally the WAI Crossover Duct / Valve and GADC upgrade 

- Item 3 – FAA type-certification approval of amended type design to eliminate noncompliant features 

o Exemption now requires FAA approval of the complete design change needed for 

full compliance by January 10, 2014

 Design change data for FADEC V1.5 is now available (approved by the 

FAA under FAR 33 design change) 

 Design change data for the GADC Software upgrade and Crossover Duct 

Valve changes (TC MOD G25-10022) will be available in April of 2014

o GALP submits that the initial design change – FADEC V1.5, represents a 

substantial improvement for which FAA approval has already been obtained and 

therefore significantly supportive of the existing requirement for the January 10, 

2014 requirement for review of data 

o The design data for the remaining / forecast changes – GADC upgrade and the 

WAI Crossover Duct Valve installation (TC MOD G25-10022) should be available 

for FAA consideration and approval in April of 2014

o Accordingly, GALP requests that the date by which FAA approval of the design 

changes required to eliminate any non-compliant design features be revised to 30 

June, 2014.

- Item 4 – Develop, validate and submit for FAA approval all service information necessary 

to incorporate the design changes required in Item 3 above: 

o FADEC V1.5 –the Gulfstream Service Bulletin to implement this change will be 

submitted to FAA for approval by 31 January, 2014. 

o GADC upgrade and the WAI Crossover Duct Valve installation - – the Service 

Bulletin to implement this change will be provided to the FAA for approval by May 

of 2014 

o Accordingly, GALP requests that the date by which FAA approval of all service 

information necessary to incorporate the design changes required be revised to 30 

June, 2014.
 

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Gulfstream Aerospace LP ¤ PO Box 1036 ¤ Airport City 70100 ¤ ISRAEL 

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 

- Item 5 – Airplanes for which application for airworthiness approvals is made after 

September 30, 2014

o Requires relief due to time required to get existing (in-service) fleet fully modified – 

December 31, 2015 is requested 

- Item 6 – FAA will not issue original airworthiness approvals for GALP Model G280 

Airplanes after September 30, 2014

o No extension appears needed for this date due to planned certification and 

production cut-in of all modifications outlined herein which are expected to be 

approved before this date

As presented herein, our request for extending the deadlines associated with the design change and 

service information approvals is relatively modest compared to extension request for retrofit of the 

G280 fleet which presents significant logistics and scheduling challenges associated with the 

hardware and aircraft availability. GALP remains aggressive in pursuing and implementing these 

improvements, and believes the stepped-process of implementing first the FADEC V1.5 change 

while the GADC upgrade and WAI Crossover Duct Valve design change is being completed provides 

significant mitigation by improving the level of safety relative to the levels at the time of the original 

granting of the exemption. 

GALP also respectfully requests FAA consideration of no need of publication for comment as the 

technical basis and business need / public interest remains the same as during the original 

application with regard to FAR 11.87 requirements. Given progress to-date and the improvements 

that will be implemented during the remaining requested period the conditions addressed by the 

exemption are actually of diminishing concern, so GALP believes a no publication approach remains 

fully valid. 

GALP is confident that this approach will yield a fully compliant product by the dates provided herein 

and will appreciate FAA’s earliest consideration of this request, including no delay for publication. 

Regards, 

Charly Gaber 

GALP Airworthiness & Certification 

Gulfstream Aerospace LP 

e-mail: Charly.Gaber@gulfstream.com 

Telephone: +972-3-935-6627 

Fax: +972-3-935-6750 

cc: J. Gibbs, B. Marom, S. Bendor, D. Lawton, D.Such,J.Gibbs,J.Neville,T.Nir,I.Kalal 

 M. Fagan, File 
Gulfstre am Aerosp ace LP ¤ PO Box 1036 ¤ Airport Cit y 70 100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

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GALP Ref: FAA/12107/CG 

Petition for a Time-Limited Exemption 

Gulfstream Aerospace LP (GALP) originally petitioned FAA for a time-limited Exemption from 14 CFR Parts 

25.901(b) (2) and 25.903(d) (2) on May 17, 2012, as recorded in docket FAA-2012-0553. 

GALP hereby amends that original petition by requesting a time-limited exemption from the originally 

requested rules and from certain additional rules as will follow. 

This amended petition is intended to replace the above referenced original petition. GALP respectfully request 

that the original petition dated May 17, 2012 be removed from this docket and replaced with this submittal

accordingly. 

- 14 CFR §25.901(b)(2) as amended by Amendment 25-46 

- 14 CFR §25.903(d)(2) as amended by Amendment 25-100 

- 14 CFR §25.939(a) as amended by Amendment 25-40 

- 14 CFR §25.1301(c) and (d) effective February 1, 1965 

- 14 CFR §25.1305(c)(1) as amended by Amendment 25-115 

- 14 CFR §25.1322(a) as amended by Amendment 25-38 

- 14 CFR §25.1309(c) and (d) as amended by Amendment 25-41 

This exemption would permit relief from certain engine installation, operational limitation and engine indication 

requirements which apply to the Gulfstream G280 airplane and installed Honeywell AS907-2-1G engines. 

GALP also requests FAA’s early consideration of a grant of exemption without a public comment period 

as a delay would be detrimental to Certification of the Gulfstream G280 airplane and to GALP 

economically. 

Regulations from which relief is sought (at amendments as referenced above): 

Sec. 25.901 

Installation. 

... 

(b) For each powerplant-- ... 

(2) The components of the installation must be constructed, arranged, and installed so as to ensure their 

continued safe operation between normal inspections or overhauls; 

Sec. 25.903 

Engines. 

... 

(d) Turbine engine installations. For turbine engine installations-- ... 
Gulfstre am Aerosp ace LP ¤ PO Box 1036 ¤ Airport Cit y 70 100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

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(2) The powerplant systems associated with engine control devices, systems, and instrumentation, must be 

designed to give reasonable assurance that those engine operating limitations that adversely affect turbine 

rotor structural integrity will not be exceeded in service. 

Sec. 25.939 

Turbine engine operating characteristics. 

(a) Turbine engine operating characteristics must be investigated in flight to determine that no adverse 

characteristics (such as stall, surge, or flameout) are present, to a hazardous degree, during normal and 

emergency operation within the range of operation limitations of the airplane and of the engine. 

Sec. 25.1301 

Function and installation. 

Each item of installed equipment must-- 

... 

(c) Be installed according to limitations specified for that equipment; and 

(d) Function properly when installed. 

Sec. 25.1305 

Powerplant instruments.[The following are required powerplant instruments:]...

(c) For turbine engine-powered airplanes. In addition to the powerplant instruments required by paragraph (a) 

of this section, the following powerplant instruments are required: 

(1) A gas temperature indicator for each engine. 

Sec. 25.1309 

[Equipment, systems, and installations.]

... 

(c) Warning information must be provided to alert the crew to unsafe system operating conditions, and to 

enable them to take appropriate corrective action. Systems, controls, and associated monitoring and warning

means must be designed to minimize crew errors which could create additional hazards. 

(d) Compliance with the requirements of paragraph (b) of this section must be shown by analysis, and where 

necessary, by appropriate ground, flight, or simulator tests. The analysis must consider--]

(1) Possible modes of failure, including malfunctions and damage from external sources. 

(2) The probability of multiple failures and undetected failures. 

(3) The resulting effects on the airplane and occupants, considering the stage of flight and operating conditions, 

and 

(4) The crew warning cues, corrective action required, and the capability of detecting faults. 

Sec. 25.1322 

[Warning, caution, and advisory lights.]

[If warning, caution, or advisory lights are installed in the cockpit, they must, unless otherwise approved by the 

Administrator, be-- 

(a) Red, for warning lights (lights indicating a hazard which may require immediate corrective action); 

Background, Reasons for Exemption and Supportive Information: 

This exemption, if granted, would permit relief from certain engine installation, limitation, operational and 

indication requirements for the Gulfstream G280 where there is extremely remote possibility that an Inter 

Turbine Temperature (ITT) exceedance indication during certain Wing Anti-Ice System (WAI System) 

operations may occur. This exemption would be time-limited to two (2) years to allow improvements presently 

in development to be completed and implemented into the G280 fleet. Improvements now in-work include 

optimized aircraft and engine control system and indication software designed to preclude the possibility of an 

engine ITT exceedance indication during certain high-bleed demand operating conditions. 
Gulfstre am Aerosp ace LP ¤ PO Box 1036 ¤ Airport Cit y 70 100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

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The Gulfstream G280 is nearing the conclusion of a Type Certification effort begun by initial application on 

March 30, 2006 and as extended by FAA agreement through September 30, 2012. Provisional Type 

Certificate number A61NM was granted on March 1, 2012. 

 

An operational review of the Wing Anti-Ice System (WAI System) during recent FAA FSB flight and training

activities has indicated possible compliance issues with the above cited rules. There is an extremely remote 

risk that an ITT exceedance warning message might occur during the initial wing warm-up phase of WAI 

System operation under certain conditions. Engine bleed demands during this phase and the current FADEC 

ITT limits may lead to an indication of engine ITT exceedance to the flight crew. However, the engine is 

actually certified to a higher value (955°C continuous, 970°C maximum for 20 seconds) than the flight deck 

exceedance indication as-generated by the current FADEC version (928°C). The engine may therefore 

continue to safely operate without any adverse affect to the engine or continued safe flight of the aircraft. 

This condition may exist at high power settings, following WAI System activation and until the wing approaches 

WAI System steady-state temperatures and engine bleed flow stabilizes, after which engine ITT is reduced. 

During this warm-up phase it is possible that an ITT exceedance warning indication may occur. However, 

should such an indication occur, it is unlikely that the engine is actually experiencing an exceedance condition 

because the ITT limits as currently set in the FADEC, as stated above, are below the certified engine values by 

as much as 27°C. The planned changes include improved airframe / engine integration functionality by 

optimizing the bleed-demand / engine response and indication functions during WAI System activation, warmup and operation. 

As a precautionary measure, GALP has also assessed the possibility of an actual operational ITT exceedance 

event during foreseeable flight conditions. As stated above, such an actual ITT exceedance occurring during 

foreseeable fleet operations is also not likely. The risk of an actual exceedance occurring during an indication 

error event is therefore mitigated as well. 

For such an actual exceedance all of the following conditions, events and related crew actions would have to 

occur: 

• Field elevation greater than 8,000 feet 

• Icing conditions would have to be present (less than 10°C / visible moisture) 

• Pilot would have to fail to recognize potential for icing conditions and not activate the system prior to 

take-off or initiation of approach procedures 

• Co-pilot would have to overlook the pilot’s failure to activate WAI System despite defined procedures 

• Crew then recognizes the error and activates the WAI System while at take-off or go-around power 

Engines will have ample ITT margins for the two year exemption as-shipped and as monitored and maintained. 

Appropriate ITT margins provide assurance against reaching exceedance values during operation. 

GALP respectfully submits this petition for a time-limited exemption from the provisions of the above-listed 

rules until such time as the current design effort can be finalized and changes may be made to the WAI System 

and engine control systems to optimize the integration design and further preclude the risk of an occurrence of 

the described exceedance warning indication. GALP anticipates that these changes will be available by the 

end of 2013, and will make every effort to ensure that a fleet retrofit will be completed by the end of the third 

quarter of 2014. GALP will provide FAA with details for the intended design changes and modifications to 

achieve full compliance. 

Fleet operational experience demonstrates that the high-usage rate for a Gulfstream Mid-Cabin airplane is 

about 600 hours per year, and that a more typical usage rate is approximately 400 hours per year. Given the 

limited time-frame for the requested exemption and considering the operational window for the airplanes that 

would be delivered within a 2 year time-frame, the risk of an ITT exceedance is reduced due to the engines 

only having a partially deteriorated condition and thereby would have more margin to an ITT limit than a fully 

deteriorated engine as used in the margin analysis. The limited number of airplanes that will be delivered 

within the two-year period of the requested exemption represents a negligible addition to overall fleet risk. 

Reasons for Petition for Exemption: 
Gulfstre am Aerosp ace LP ¤ PO Box 1036 ¤ Airport Cit y 70 100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

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Due to the current configuration of engine FADEC and WAI System control software as reviewed with FAA and 

intended for Type Certification, it has proven impractical to demonstrate full compliance through aircraft or 

other system limitations or by system level changes with the above-listed rules in a timely manner. GALP

therefore respectfully requests that this time-limited exemption be granted without delay to support the timely 

issuance of a Type Certificate for the Gulfstream G280. This would permit the reasonable development of 

mitigating improvements in WAI System control and engine FADEC software within a workable time-frame. 

Type Certification of the Gulfstream G280 to include Flight Into Known Icing (FIKI) is vital to the product. 

Restricting the operational envelope in this manner, or in any form that otherwise restricts airplane 

performance is commercially unviable for GALP and its customers and would be very detrimental to the 

marketability of this aircraft. 

Information Supporting Exemption: 

GALP offers the following justification and substantiation for granting this time limited exemption and as to how 

the current type design provides an acceptable level of safety. It should be pointed out that the potential for an 

ITT exceedance warning indication only exists as an extremely remote possibility. 

GALP, with assistance from the engine manufacturer, has established that tolerance against the risk of the 

described exceedance occurring is related to engine ‘margin’, e.g. a newly-delivered engine has greater ITT

temperature margins than an ‘end of life’ engine. Airplanes delivered within the requested 2 year window will 

have new engines and should accumulate no more than approximately one-eighth of their useful margin-life 

during that time-span at the average-to-highest airplane usage rates. This mitigates any exposure to the 

condition, should AFM procedures not be followed, as these margins help offset the likelihood of a high-bleed 

rate condition driving such an occurrence. 

Current aircraft ITT engine limits are below the certified engine ITT limits by as much as 27 degrees. Even if a 

momentary engine ITT exceedance is seen during the brief period of time while the wing anti ice system 

heats up the wing, the engine is certified to a higher value than the airframe exceedance indication as stated 

above (955°C continuous / 970°C maximum for 20 seconds vs. 928°C in the current FADEC SW), and will 

continue to safely operate without any affect to the engine or continued safe flight of the aircraft. The crew 

can respond to the message, should it occur, with immediate action, as required. Such action would be 

consistent with a message of this type being generated by any other cause and is therefore functionally within 

the reasonable scope of operation. 

GALP’s assessment of the possibility of an actual operational ITT exceedance event during foreseeable flight 

conditions has also shown the likelihood of such an actual ITT exceedance occurring during foreseeable fleet 

operations to be extremely remote. Therefore the risk of an actual exceedance occurring during an indication 

error event is mitigated. 

The limited number of airplanes that will be delivered within the two-year period of the requested exemption 

represents a negligible addition to overall fleet risk. 

Normal operational procedures provide ample means by which the crew may avoid the operational issue of an 

ITT exceedance indication. The condition of this exemption will be also be appropriately stressed during pilot 

type rating and training activities in the Gulfstream G280 so as to ensure crew awareness of the extremely 

remote potential for an exceedance warning. 

GALP will design, certify and incorporate into Gulfstream G280 production line and existing fleet, a series of 

modifications required to demonstrate compliance with the requirements of the above listed rules within the 

time permitted by this exemption, if granted. 

Acceptable Level of Safety is provided – 

The overall potential of an ITT exceedance indication is very limited given the number of foreseeable conditions 

that must be present. Analysis of foreseeable fleet operations, the attending risks of an occurrence / icing 

event and related operational actions, Airplane Flight Manual (AFM) procedures (including prohibition against 

operation in WAI System auto-mode) and reliability of the associated components and systems have shown 

that an acceptable level of safety is assured. 
Gulfstre am Aerosp ace LP ¤ PO Box 1036 ¤ Airport Cit y 70 100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

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In addition to appropriate procedures, clear placarded information will be present in the cockpit to prohibit

operation of the WAI System in auto-mode. When the WAI System is switched off, system probability failures 

that could cause Uncommanded activation of WAI are extremely improbable and are not caused by a single 

failure. 

To further mitigate any risk of an event that might occur from unforeseen rapid engine deterioration in-service, 

it is also proposed that an interim power assurance check be performed at “A check” at 500 hours, or “C check” 

at 12 months, whichever comes first. This is to ensure that appropriate ITT margins are maintained in-service. 

The MMEL will prohibit single bleed source dispatch or other dispatch configuration limitations which are 

fundamental to the exemption being requested. 

Public Interest / Benefit: 

GALP offers the following reasons for why granting the requested time-limited exemption is in the public 

interest, as required by 14 CFR 11.81: 

Denial of this petition for exemption would result in the delay in Type Certification and delivery of the 

Gulfstream G280. While these airplanes are not manufactured in the U.S., a significant portion of the airplane, 

including the wings, engines, avionics, and interiors are manufactured by U.S. suppliers. Denial of this 

exemption would result in the loss of revenue for the U.S. suppliers and have an adverse impact on the U.S. 

balance of trade, both of which are contrary to the public interest. 

Granting this exemption would permit the efficient transport of employees, corporate executives and important 

clientele in an efficient and safe environment. Due to the high demand for these corporate aircraft, it is 

imperative that the petitioner is granted the regulatory relief requested. Failure to achieve this goal will result in 

delivery delays and the potential for significant loss of income, in both domestic and foreign trade for the United 

States and the petitioner. Therefore the stabilizing effect that the manufacture and support of corporate aircraft 

has on the job market and balance of trade for the United States is significant and definitely in the public 

interest. 

Type Certification without FIKI is not a commercially viable option due to the operational needs of the corporate 

aircraft market. Similarly, airplane performance restrictions are not a commercially viable option and would be 

highly punitive to GALP’s ability to compete in the marketplace, at best. 

Adequate time is needed to develop the appropriate mitigations and system features to address this concern. 

This will involve software modifications to the engine FADEC and WAI System control which require a long 

lead-time to assure proper functionality and software compliance. System changes are required to critical 

engine and aircraft control systems which must be carefully done to not introduce additional or unexpected 

hazards to these controls. 

GALP is responding in a timely fashion to this issue which, as stated above, only became known during 

recent FAA FSB activities. This is a crucial time in the development and certification of the Gulfstream G280. 

A delay in granting this exemption would be detrimental to GALP by delaying the Type Certification and 

delivery of the product. 

In Conclusion: 

Respectfully, GALP will appreciate FAA’s early consideration and grant of the requested exemption as 

requested to support final Type Certification efforts and delivery of aircraft to our customers as scheduled. 

GALP believes early consideration without a delay for public comment is warranted due to the conservative

mitigation offered for the interim period of the exemption, that an acceptable level of safety is established and 

because an urgent need exists with regard to timely Type Certification of the Gulfstream G280.