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 

1

GALP Ref: FAA/12014/CG 

Petition for partial Exemption 

Gulfstream Aerospace LP 

Gulfstream Model G280 

Gulfstream Aerospace LP hereby petitions for relief from 14 CFR Part 21.195(a) as amended by 

Amendment 21-92 of Title 14, Code of Federal Regulations (14 CFR) to allow a non-United States 

Manufacturer the ability to obtain an experimental certificate for aircraft to be used for market 

surveys, sales demonstrations and customer crew training. Gulfstream Aerospace LP (hereinafter 

GALP) is a limited partnership company established and wholly owned by Gulfstream Aerospace 

Corporation to manage Type Certification of Gulfstream Aerospace airplane models manufactured in 

Israel by Israel Aerospace Industries. GALP has applied for a Provisional Type Certificate for the 

Gulfstream model G280 airplane and is in need of relief from 14 CFR Part 21.195(a) to allow for the 

application and issuance of an experimental certificate as stated above.

Existing Regulations 

Gulfstream Aerospace LP (GALP) requests partial relief from the following regulation: 

Section 21.195(a) – 

“ (a) A manufacturer of aircraft manufactured within the United States may apply for an experimental 

certificate for an aircraft that is to be used for market surveys, sales demonstrations or customer 

crew training.” 

Background 

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

application on March 30, 2006. GALP is seeking a Provisional Type Certificate. The issuance of an 

Experimental Airworthiness Certificate for the purpose of market surveys, sales demonstrations, and 

customer crew training is needed to facilitate flight demonstration and training efforts in the U.S. 

Reasons for Petition 

GALP is a Texas limited partnership, whose partners are both wholly owned Gulfstream Aerospace 

Corporation subsidiaries. GALP maintains an office in Israel to assist in the management of Type 

Certification activities for Gulfstream Aerospace airplane models manufactured by Israel Aerospace 

Industries in Israel. As such, GALP is also the applicant for Type Certification of the G280. While 

outfitted and sold exclusively in the United States by GALP, the G280 is not manufactured in the 

United States and does not meet the requirements for issuance of an experimental certificate under 

14 CFR 21.195(a). 

The model G280, like predecessor GALP models, will be manufactured in Israel and delivered to 

Gulfstream in the United States for final outfitting. As a part of this final phase design development 

there is a need for market survey, sales demonstration and customer crew training flights. These 

flights can only be accomplished with the issuance of an experimental certificate under 21.195(a). 

Public Interest / Benefit: 

Granting this Petition for Exemption is in the public interest as it would permit the efficient 

transport of employees, corporate executives and other 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 
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 

2

result in product development 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 manufacturer 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. 

Granting this exemption will allow Gulfstream and GALP to continue final product 

development, including interior outfitting, flight demonstration / product familiarization, inpace with our Type Certification effort. 

Without the exemption, Gulfstream and GALP will have production airplanes awaiting Type 

Certification before being able to be demonstrated to customers and other potential buyers. 

This would deprive the company of many months of productive effort for crew training, sales 

development and training of new flight crews in preparation for delivery of completed 

airplanes. 

The level of safety intended by the rule will be upheld. As an integral element of Gulfstream 

Aerospace Corporation, GALP has the direct benefit of the experience Gulfstream brings as 

a U.S. manufacturer of Large Cabin jet transport airplanes. GALP / Gulfstream would 

manage all aspects of the G280 program under a Experimental Airworthiness Certificate for 

the purpose of Market Survey, Sales Demonstration, and Crew Training in the same manner 

as for Gulfstream Large Cabin airplane models. Flight operations and maintenance 

activities would be governed by the same standards applicable to our existing Large and 

Mid-Size cabin airplane production, maintenance and operational units. 

Not granting this exemption would have a significant negative impact for several reasons: 

• An extended resource demand on the FAA / public resources to support a delayed 

effort. 

• Reduction in employment of production workers at Gulfstream Aerospace and its 

suppliers around the U.S. and the world due to delayed completions and related 

developmental efforts. 

• Several major corporations and other entities around the U.S. and the world 

anticipating the delivery of the G280 aircraft to meet their business and critical 

mission needs would need to find alternative transportation. 

• The balance of trade between the US and other nations would be negatively impacted 

due to delayed deliveries and lost sales. 

• Taxation at the local, state, and federal levels would be adversely impacted from loss 

of wage taxes and sales taxes. 

Level of Safety equal to that provided by 14 CFR 21.195(a) 

GALP has carefully examined the requested approach and concluded there is no adverse 

affect on safety based on the exemption being sought. 

As an integral element of Gulfstream Aerospace Corporation, GALP has the direct benefit of 

the experience of Gulfstream as a U.S. manufacturer of Large Cabin jet transport airplanes. 

Gulfstream has an organic familiarity with the existing IAI-built Gulfstream models G100, 

G150 and G200 and has played a direct role in the development of the G280. GAC crews 

are highly experienced in all of these models, including flight test crews who have 

participated in the product development and flight testing of the new G280 model. 
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 

3

GALP / Gulfstream would manage all aspects of the G280 program under an experimental 

certificate in the same manner as for Gulfstream Large Cabin airplane models. 

Flight operations and maintenance activities would be governed by the same standards 

applicable to our existing Large and Mid-Size cabin airplane production, maintenance and 

operational units. 

 

Gulfstream would apply the maintenance instructions and personnel training requirements in 

the same manner as for existing types to ensure appropriate maintenance and oversight of 

airworthiness. This arrangement would be closely coordinated as required with overseeing 

FAA offices including ACO, FSDO and MIDO at each location where maintenance and 

operations will be based. 

Further, as evidenced by exemptions 9887 and 9889, Gulfstream maintains a highlyexperienced and well-trained force of pilots who are well qualified to operate the G280 within 

a well-regimented company system. Pilot-in-command duties would be limited to those who 

are appropriately qualified to operate the G280 under an Experimental Airworthiness 

Certificate 

GALP requests FAA consideration of expeditious handling and foregoing of public 

comment period under the provisions of 14 CFR 11.87

The need for this exemption is urgent to preclude lost time for accomplishing the goals 

defined herein. GALP does not believe the requested relief to be controversial. GALP / 

Gulfstream are integral entities in the design and manufacturing of the G280; granting this 

exemption at an early date would assure the normal fulfillment of that role in a timely 

manner. 

GALP also believes an exemption as requested would be consistent with the FAA’s previous 

grants of exemption to this rule. 

A delay of action on this petition would jeopardize the timely maturity of the G280 

commensurate with eventual grant of Type Certification. 

Summary

Gulfstream Aerospace LP (GALP) respectfully requests an exemption from 14 CFR Part 21.195(a) 

as this rule relates to eligibility of U.S. Manufacturers for a U.S. Experimental Airworthiness 

Certificate issuance for the purpose of market surveys, sales demonstrations, and customer crew 

training for the G280 airplane. This exemption will allow GALP to perform certain U.S. domestic 

functions that are vital to the finished product commensurate with U.S. Type Certification. GALP 

further requests FAA consideration of the critical timing of this petition, and accordingly, relief from 

the public comment period to assure timely continuation of U.S. domestic operational needs.