UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERALAVIATIONADMINISTRATION 

WASHINGTON, DC 20591 

In the matter of the petition of 

GULFSTREAM AEROSPACE Regulatory Docket No. FAA-2015-4420

CORPORATION

for an exemption from § 61.57(a) 

and (b) of Title 14, Code of 

Federal Regulations 

DENIAL OF EXEMPTION

By letter received July 27, 2015, Ms. Kimberly Lascell, Director, Airworthiness and 

Certification, Gulfstream Aerospace Corporation, P.O. Box 2206, Savannah, GA 31402-

2206, petitioned the Federal Aviation Administration (FAA) on behalf of Gulfstream 

Aerospace Corporation (Gulfstream) for an exemption from § 61.57(a) and (b) of Title 14, 

Code of Federal Regulations (14 CFR). This exemption, if granted, would allow all 

operators of Gulfstream models G-IV, GIV-X, GV, GV-SP and GVI (G650 and G650ER) 

airplanes to meet the recent takeoff and landing experience requirements of § 61.57(a) and 

(b). 

The petitioner requests relief from the following regulation:

Section § 61.57(a) prescribes, in pertinent part, that no person may act as a pilot in 

command of an aircraft carrying passengers or of an aircraft certificated for more than one 

pilot flight crewmember unless that person has made at least three takeoffs and three 

landings within the preceding 90 days, and— 

(i) The person acted as the sole manipulator of the flight controls; and 

(ii) The required takeoffs and landings were performed in an aircraft of the same category, 
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class, and type (if a type rating is required). 

Section § 61.57(b) prescribes, in pertinent part, that no person may act as pilot in command 

of an aircraft carrying passengers during the period beginning 1 hour after sunset and 

ending 1 hour before sunrise, unless within the preceding 90 days that person has made at 

least three takeoffs and three landings to a full stop during the period beginning 1 hour after 

sunset and ending 1 hour before sunrise, and— 

(i) That person acted as sole manipulator of the flight controls; and 

(ii) The required takeoffs and landings were performed in an aircraft of the same category, 

class, and type (if a type rating is required).

The petitioner supports its request with the following information:

The petitioner states that its petition is intended to provide relief to all operators of 

Gulfstream G-IV/GIV-X, GV/GV-SP and GVI airplanes that these airplanes have individual 

type ratings. The petitioner also states that these airplanes all are similar in size and have an 

excellent commonality of performance, systems and handling characteristics. 

The petitioner also supports its petition by citing previous issued exemptions to Gulfstream 

(Exemption Nos. 9887D and 9889C) and Boeing Commercial Airplane Group (Boeing) 

(Exemption No. 6843). The petitioner contends that while Gulfstream and other 

manufacturers, such as Boeing, have held that pilot proficiency is maintained by 

standardized operational requirements inherent to their organizations, it is further recognized 

that operators of multiple Gulfstream models also maintain similar training and experience 

standards for pilots who are rated among the Gulfstream types within their fleets. 

The petitioner states that compliance with § 61.57(a) and (b) to keep crews current in all 

fleet models could easily require some 100 or more flights per year for the average flight 

department. By allowing flight experience in any one of the Gulfstream types listed in the 

petition, the number of flights required to maintain currency could be reduced to some 35 or 

so flights per year, which is a reduction of approximately two-thirds of the present burden. 

The petitioner maintains that this would result in a reduction of air traffic congestion, a 

savings of resources such as fuel and relieve other operational impacts to the public and air 

transportation system. 

The petitioner states that Gulfstream pilots undergo highly-standardized type training and 

are experienced in this make and category of airplane and operate all models of Gulfstream 

aircraft within their fleet on a regular basis. The typical Gulfstream pilot logs an average of 

300 to 600 hours per year in a variety of Gulfstream airplanes and periodically attends 

FlightSafety International, rotating among the Gulfstream aircraft courses that are applicable 

to their particular fleet and for which they are rated. 

According to the petitioner, Gulfstream's aircraft are operated by businesses, government 
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organizations, military services, and foreign countries. The petitioner argues that its’ aircraft 

transport corporate executives, military leaders, and heads of State who conduct business 

that directly supports the public. As such, an exemption would allow Gulfstream pilots to be 

more efficient and devote more time and effort to conducting flights to expedite aircraft into 

service. 

A summary of the petition was published in the Federal Register on October 19, 2015. No 

comments were received. 

The FAA’s analysis is as follows: 

The petitioner believes that the same logic that supported the grants of exemption Nos. 

9887D and 9889C applies to this petition. The petitioner also cites a similar exemption (No. 

6843) issued to Boeing. However, the conditions and limitations of all three of those 

exemptions make it applicable only to production and engineering test pilots. Additionally, 

on August 5, 1998, and in supplemental information dated October 5, 1998, the petitioner 

stated that its pilots log an average of 500 to 600 flight hours per year. In those exemptions, 

the FAA recognized the skills needed to be a production and engineering test pilot and the 

continual experience Gulfstream pilot receive each year. This was a critical component in 

determining an equal level of safety. Gulfstream cannot ensure that a typical corporate pilot 

of the listed Gulfstream models would have the skill, knowledge and proficiency of a 

production and engineering test pilots. Gulfstream states that these pilots may have much 

less annual experience than their production and engineering test pilots. 

The petitioner states that the Gulfstream G-IV/GIV-X, GV/GV-SP and GVI airplanes have 

individual type ratings. However, the GIV-X, GV, and GV-SP all hold the same pilot type 

rating (G-V). The Flight Standardization Board (FSB) Report for the GIV-X, GV and GVSP airplanes, revision 9, paragraph 8.1 states “Currency is considered to be common for the 

GIV-X, G-V and GV-SP. Separate tracking of currency for the GIV-X, G-V and GV-SP is 

not necessary or applicable. Currency will be maintained, or re-established, in accordance 

with 14 CFR section 61.57, 61.58, 135.247 and/or 135.351.” Consequently, an exemption to 

allow all operators of Gulfstream models GIV-X, GV, and GV-SP airplanes to meet the 

recent takeoff and landing experience requirements of § 61.57(a) and (b) is not required. 

The Gulfstream G-IV holds separate pilot type ratings (G-IV). The G-IV FSB report 

(revision 1 dated June 19, 2015) paragraph 2.2 states “In that this is a new pilot type rating, 

the FSB did not evaluate, and does not allow for any training credits, checking credits, 

currency credits, landing currency credits, or proving test credits (except that which is 

permitted by 14 CFR § 135.145) between the G-IV and any other similar type aircraft from 

Gulfstream.” Consequently, no data exists demonstrating the transfer of take-offs and 

landings proficiency between the G-IV and the other aircraft in the petition. 

The Gulfstream GVI also holds a separate type rating (GVI). Due to many similar or 

identical systems to related GV-SP and the GIV-X, the FSB was asked to evaluate a “full” 

GVI (G650) initial training course which is designed for a pilot with no previous Gulfstream 

experience and a “shortened” GVI (G650) initial training course. Although a shortened 
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initial type rating course was approved for those pilots meeting certain experience 

requirements in a GIV-X and GV-SP, the shortened course still required take-offs and 

landings in the GVI to be in the aircraft, or a level C or D simulator. Additionally, 

paragraph 8 of the FSB report states “The FSB has found no additional “Recent Experience” 

requirements for the GVI, other than those already specified in 14 CFR parts 61, 125 and 

135.” 

Equal Level of Safety: 

In issuing the Gulfstream exemptions (Nos. 9887D and 9889C) and the Boeing exemption 

(No. 6843), the FAA took into consideration not only the skills needed to be a production 

and engineering test pilot, but also the continual experience levels of these pilots. The 

petitioner requested an exemption to allow all operators of Gulfstream models G-IV, GIV-X, 

GV, GV-SP and GVI airplanes to meet the recent takeoff and landing experience 

requirements of § 61.57(a) and (b). Most pilots that would be covered by this exemption, if 

granted, are not production and engineering test pilots. Additionally, the petitioner cannot 

ensure that these pilots will be able to maintain the continual experience levels of Gulfstream 

or Boeing production and engineering test pilots. Consequently, the petition has not shown 

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

The FAA’s Decision: 

In consideration of the foregoing, I find that a grant of exemption would not provide an 

equivalent level of safety and is not in the public interest. Therefore, pursuant to the 

authority contained in 49 U.S.C. 40113, and 44701, delegated to me by the Administrator 

the petition of Gulfstream Aerospace Corporation for an exemption from 14 CFR § 61.57(a) 

and (b) is denied. 

Issued in Washington, D.C., on April 26, 2016. . 

/s/ 

John S. Duncan 

Director, Flight Standards Service