AIR-15-195-E

April 30, 2015

 Exemption No. 11076A

 Regulatory Docket No. FAA-2013-0982

Mr. Richard Edinger

VP Certification and Flight Safety

Hartzell Propeller Inc.

One Propeller Place

Piqua, OH 45356-2634

Dear Mr. Edinger:

This letter is to inform you that the Federal Aviation Administration (FAA) has granted your 

petition to extend and amend Exemption No. 11076. This letter explains the basis for our 

decision and describes its effect.

On November 7, 2013, you petitioned the FAA on behalf of Hartzell Propeller Inc. (Hartzell) 

for an exemption from § 45.13(a)(4) of Title 14 of the Code of Federal Regulations (14 CFR). 

On October 6, 2014, we responded by issuing Exemption No. 11076, which relieved Hartzell 

of the requirement to include a type certificate (TC) number identification mark on certain

propeller blades. The exemption applied only to Hartzell-produced propeller blades approved 

for installation on multiple type designs. 

On November 26, 2014, you petitioned the FAA again, this time requesting an extension and 

amendment to Exemption No. 11076. The amendment you requested would eliminate entirely

the requirement to mark a TC number on any Hartzell propeller blades, and would extend or 

eliminate the exemption’s October 31, 2016, expiration date. We grant your petition, for the 

reasons described below.

The Basis for Our Decision

Section 45.13(a) requires, among other things, a manufacturer to mark each propeller blade 

with the TC number for which the blade is approved. In your petition, however, you state that 
2

Hartzell manufactures at least twelve propeller blade models, many of which are compatible 

with numerous FAA-certificated propeller type designs. For example, one model, the “Yshank” series, is compatible with seventeen TCs.

In Exemption No. 11076, we found that marking any blade approved for more than one TC 

with the term “multiple,” rather than a list of all compatible TC numbers, would provide an 

equivalent level of safety to compliance with § 45.13(a)(4). We agreed with the petitioner 

that an exemption would be in the public interest, because marking propeller blades with 

numerous TC numbers could cause confusion among the public. One potential source of 

confusion is that, as a blade became approved for additional TCs, Hartzell would be required 

to change its markings, creating a situation in which various propeller blades of the same 

model would be marked differently depending on their date of manufacture. 

As you state in your November 26, 2014, petition, however, the terms of Exemption 

No. 11076 did not wholly mitigate the potential for confusion among the public. By limiting 

the exemption to blade models already approved for multiple TCs, we failed to account for 

situations in which a blade model is first approved for only one TC, but is subsequently

approved for additional designs. In such a situation, Hartzell would, over time, produce the 

same blade with two different marking configurations—first with a single TC number, then 

with the word “multiple.” You also state that some historical blades may have been 

manufactured with no TC marking at all. As a result, you suggest that the original terms of 

Exemption No. 11076 could cause three distinct variations of propeller blade markings 

compatible with a single propeller system—some blades with no TC number, some with a 

single TC number, and others marked as “multiple.” The FAA agrees this situation could 

cause confusion among the public.

In your petition, you also request that the FAA amend Exemption No. 11076 to extend or 

eliminate the two-year expiration date. Although the FAA generally grants exemptions for 

only two years, we agree that the specific factual circumstances presented here warrant an 

extended exemption, for a period of five years. In particular, the circumstances justifying this 

exemption are extremely unlikely to change in the foreseeable future. Hartzell will continue 

to produce propeller blades using blade designs that are, individually, approved for numerous

propeller system TCs. Moreover, Hartzell’s progressive type certification strategy for new

and existing blades would, absent this exemption, require continuous adjustments to each 

blade’s TC markings, potentially confusing the public. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register, because the requested amendment to the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to Hartzell. You also 
3

indicate in your petition that there has been no change in facts relative to the public interest 

and safety findings that were the basis for original exemption.

The FAA has reviewed your petition and supporting information, and we find that a grant of 

exemption would provide an equivalent level of safety to the regulations for which relief is 

required and would be in the public interest. The FAA finds that Hartzell’s continued 

compliance with the marking requirements of §§ 45.11(c)(2) and 45.13(a)(1)-(3)&(5)-(8), as 

applicable, will provide an installer with sufficient information to ensure that he or she has the 

correct article for installation. Hartzell may also choose to mark individual blades with all 

applicable TC numbers.

Our Decision

The FAA has determined that an amended grant of exemption is in the public interest and has 

no adverse effect on safety. Therefore, pursuant to the authority contained in 49 U.S.C. 

§§ 106(f), 40113 and 44701, delegated to me by the Administrator, Hartzell Propeller Inc. is 

granted an exemption from 14 CFR § 45.13(a)(4) to the extent necessary to permit Hartzell to

forgo marking a type certificate number on Hartzell-manufactured propeller blades. Hartzell’s 

original exemption term is also extended for a period of five years.

This exemption terminates on April 30, 2020, unless sooner superseded or rescinded.

Sincerely,

//s//

John Barbagallo

Deputy Director, Flight Standards Service
4

Project No.: AIR-15-195-E

Project Officer: Robert Cook

ARM-201:SKLong:04/03/15:Doc#42652

ARM-1/200/201:Program Office AIR-100

[Insert Stylewriter Score Here]

[INSERT ENVELOPE ADDRESS HERE]