Pursuant to 14 C.F.R. 11.61 (b) and 11.81, Patrick Roth hereby petitions for an exemption permitting 

it to apply US Nationality and Registration marks at least 2 inches high on his Great Lakes Model 

2T-1A aircraft “N” Number N7GL.

(a) Contact information:

Patrick Roth

72 Lovely St

Unionville, Ct. 06085

860-673-5284

psrother@yahoo.com

(b) The specific sections of 14 C.FR. from which an exemption is sought:

14 C.F.R. Part 45.29(b): "Height. Except as provided in paragraph (h) of this part, the nationality

and registration marks must be of equal height and on-"

14 C.F.R. Part 45.29(b)(1): "Fixed-wing aircraft, must be at least 12 inches high, except that"

14 C.F.R. Part 45.22(b): "A small U.S.-registered aircraft built at least 30 years ago or a U.S.

registered aircraft for which an experimental certificate has been issued under §21.191 (d) or

21.191 (g) for operation as an exhibition aircraft or as an amateur-built aircraft and which has the

same external configuration as an aircraft built at least 30 years ago may be operated without

displaying marks in accordance with §45.21 and §45.23 through 45.33 if:"

14 C.F.R. Part 45.22(b)(1): "It displays in accordance with §45.21(c) marks at least 2 inches

high on each side of the fuselage or vertical tail surface consisting of the Roman capital letter

"N" followed by:"

(c) The extent of relief sought, and the reason for the relief sought:

Patrick Roth, owner of Great Lakes Model 2T-1A aircraft in accordance with FAA Type Certificate 

A18EA, “N” Number N7GL. This small, single engine aircraft was previously manufactured by the 

Great Lakes Aircraft Company from 1972 until approximately 1980 when production ceased. A small 

production run of 3 aircraft was run in 1984 to 1985. The Great Lakes aircraft manufactured by all 

these companies are identical in configuration and appearance to those built more than 30 years 

ago which are permitted to display nationally and registration marks at least 2 inches high in 

accordance with 14 C.F.R Part 45.22(b). During a one year pre-production sales campaign by 

WACO Classic, potential buyers of the new Great Lakes have objected to the requirement for 12 

inch registration numbers due to the small size of the aircraft and the detrimental effect large

numbers on the sides for the fuselage have on the intrinsic value of the aircraft's design. Not

having a purely practical purpose, such as transportation, aesthetics is a very important factor

for prospective buyers when considering the purchase of one of these airplanes. Patrick Roth hereby 

petitions the FAA for an exemption from 14 C.F.R. Part 45.29(b)(1) requiring nationality and 

registration marks to be at least 12 inches high and from 14 C.F.R. 45.22(b) requiring the aircraft to 

have been built at least 30 years ago allowing Patrick Roth to comply with 14 C.F.R. Part 45.22(b)(1) 

when applied to all new Great Lakes Model 2T-1 A aircraft.

(d) The reasons why granting this request is in the public interest:

This exemption will allow my Great Lakes Model 2T-1A aircraft to fit in with the look of the older 

Great lakes produced with the smaller letters. Aesthetics is a very important factor for an aircraft of 

this design and the 12” numbers just overwhelm the lines of this classic design.
(e) The reasons why granting the exemption would not adversely affect safety, or how the

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

the exemption is sought:

Granting the exemption from 14 C.F.R Part 45.29(b)(1) and allowing Patrick Roth to comply

with 14 C.F.R. Part 45.22(b)(1) in the marking of N7GL Great Lakes aircraft in the same manner

as that of identical aircraft currently operating safely in the national airspace system would

provide a level of safety at least equal to that provided by the rule from which exemption is

sought.

(f) A summary to be published in the Federal Register stating the rule from which an exemption

is sought and a brief description of the nature of the exemption sought:

14 C.F.R. Part 45.29(b): "Height. Except as provided in paragraph (h) of this part, the nationality

and registration marks must be of equal height and on-"

14 C.F.R. Part 45.29(b)(1): "Fixed-wing aircraft, must be at least 12 inches high, except that:"

14 C.F.R. Part 45.22(b): "A small U.S.-registered aircraft built at least 30 years ago or a U.S. 

registered aircraft for which an experimental certificate has been issued under §21.191(d) or

21. 191(g) for operation as an exhibition aircraft or as an amateur-built aircraft and which has the

same external configuration as an aircraft built at least 30 years ago may be operated without

displaying marks in accordance with §45.21 and §45.23 through 45.33 if:"

14 C.F.R. Part 45.22(b)(1): "It displays in accordance with §45.21(c) marks at least 2 inches

high on each side of the fuselage or vertical tail surface consisting of the Roman capita/letter

"N" followed by:"

Patrick Roth respectfully requests that it be granted an exemption from the requirements of 14 

C.F.R. Part 45.29(b) (1) and 14 C.F.R. Part 45.22(b) and be allowed to mark N7GL Great Lakes 

Model 2T-1A aircraft in accordance with 14 C.F.R. Part 45.22(b)(1).

(g) Whether and why the privileges of this exemption are needed to be exercised outside of the

United States:

Patrick Roth has no need to exercise the privileges of this exemption outside the United States.