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 Regula tions (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 tra ining. Gulfstream Aerospace LP (hereinafter GALP) is a limited partnership company established and wholly owned by Gulfstream Aerospace Corporation to manage Type Certification of Gulfstr eam Aerospace airplane models manufactured in Israel by Israel Aerospace Industries. GALP has ap plied for a Provisional Type Certificate for the Gulfstream model G280 airplane and is in need of re lief from 14 CFR Part 21.195(a) to allow for the application and issuance of an experimental certifi cate as stated above.

Existing Regulations

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

Section 21.195(a) –

“ (a) A manufacturer of aircraft manufactured withi n 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 P rovisional Type Certificate. The issuance of an Experimental Airworthiness Certificate for the purp ose of market surveys, sales demonstrations, and customer crew training is needed to facilitate flig ht 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 a irplane models manufactured by Israel Aerospace Industries in Israel. As such, GALP is also the ap plicant 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 fo r 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 outfittin g. As a part of this final phase design developmen t there is a need for market survey, sales demonstrat ion 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 publ ic interest as it would permit the efficient transport of employees, corporate executives and ot her 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 req uested. Failure to achieve this goal willGulfstre 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 potent ial for significant loss of income, in both domestic and foreign trade for the United States an d the petitioner. Therefore the stabilizing effect that manufacturer and support of corporate a ircraft has on the job market and balance of trade for the United States is significant and d efinitely in the public interest.

Granting this exemption will allow Gulfstream and G ALP 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 hav e 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 pr oductive effort for crew training, sales development and training of new flight crews in pre paration for delivery of completed airplanes.

The level of safety intended by the rule will be up held. 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 ai rplanes. GALP / Gulfstream would manage all aspects of the G280 program under a Expe rimental Airworthiness Certificate for the purpose of Market Survey, Sales Demonstration, and Crew Training in the same manner as for Gulfstream Large Cabin airplane models. Fli ght 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 significan t negative impact for several reasons:

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

effort.

• Reduction in employment of production workers at G ulfstream Aerospace and its suppliers around the U.S. and the world due to dela yed completions and related developmental efforts.

• Several major corporations and other entities arou nd the U.S. and the world anticipating the delivery of the G280 aircraft to m eet their business and critical mission needs would need to find alternative transp ortation.

• The balance of trade between the US and other nati ons would be negatively impacted due to delayed deliveries and lost sales.

• Taxation at the local, state, and federal levels w ould 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 sough t.

As an integral element of Gulfstream Aerospace Corp oration, 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 exis ting IAI-built Gulfstream models G100, G150 and G200 and has played a direct role in the d evelopment of the G280. GAC crews are highly experienced in all of these models, incl uding 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 G 280 program under an experimental

certificate in the same manner as for Gulfstream La rge 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 app ropriate maintenance and oversight of airworthiness. This arrangement would be closely c oordinated as required with overseeing FAA offices including ACO, FSDO and MIDO at each lo cation 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 ar e 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 und er an Experimental Airworthiness

Certificate

GALP requests FAA consideration of expeditious hand ling and foregoing of public comment period under the provisions of 14 CFR 11.87

The need for this exemption is urgent to preclude l ost time for accomplishing the goals defined herein. GALP does not believe the requeste d 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 Certificat ion.



### Summary

Gulfstream Aerospace LP (GALP) respectfully request s an exemption from 14 CFR Part 21.195(a) as this rule relates to eligibility of U.S. Manufac turers for a U.S. Experimental Airworthiness Certificate issuance for the purpose of market surv eys, sales demonstrations, and customer crew training for the G280 airplane. This exemption wil l allow GALP to perform certain U.S. domestic functions that are vital to the finished product co mmensurate with U.S. Type Certification. GALP further requests FAA consideration of the critical timing of this petition, and accordingly, relief fr om the public comment period to assure timely continua tion of U.S. domestic operational needs.