US Department

of Transportation Docket Operations 1200 New Jersey Avenue, SE West Building Ground Floor 2895 S
.W.145'h Avenue Room W12-140 Washington,
DC 20590-0001 January 13, 2015 Submitted electronically

to:www

.requlations

.gov GE Aviation Amy Dow Airworthiness and Certifica

tion Manager

.Small Engines GE -Aviati on 1000 Western
Ave.Lynn. MA 01910 General Electric Company T7815945436 Amy

.dow@ge

.com CraigFabian Senior Compliance Manager

,Industry Standards GE -Avi ation 1 Neumann Way Evendale. Ohio USA General Electric Compan

y T5132436837 Cro

i g.fobian@ge

.com RE: GE Aviation Petition for Exemption from 14 CFR § 21.9(cl(1) and§ 21.6(al Dear Madam orSir: Pursuant toTitle 14 Code of Federal Regulations (14 CFRl Part 11, General Electric Company (GEl respectfully petitions for an exemption from 14 CFR § 21.9(cl(1) toallow GE tomanufacture and sell replacement and modification articles for fitment torestricted category UH-60A

1 helicopters previously operated by the US Army

.GE also seeks an exemption from 14 CFR § 21.6(a) toenable the manufacture and sole of new engines for those sameaircraft

. Summary and background The requested relief is compelled by the need to supply replacement articles and engines for the subject aircraft, typecertificated under 14 CFR § 21.25(a)(2). GE military engine models are partof those aircraft typecertificates

. 2 However, since the military engines arenot independently type certificated, they arenot eligible for manufacture under the Federal Aviation Administration (FAA} production certificate (PCI held by GE. As aresult, GE isin the curious position of not being able to supportthe fleet of restricted category aircraft. although

it originally manufactured the engines included
in the restricted categoryaircraft type certificates. We emphasize that the subject aircraft serveasubstantial public interest through their firefighting

, agricultural. and other service roles. Granting this petition furthers that public interest by ensuring the availability
of new replacement partsand engines for continued safe operation during those service missions

. l lncluding S-70A and S-70iwh

ich areUH
-60A and UH-60L derivat

i ves respectively. Engine models allowed onthe UH-60As: twoGeneral Electric T700-GE-700 Original, twoGenera

l Electr

icT700

-GE-701C Alternate, twoGeneral Electric T700-GE-701D Alternate

. 2See. for example, FAA typecertificate data sheet R0012DE for the typecertificate held byBHI H60 Helicopters

.LLC

. There

isno separate

l evel of restricted category eng

ine typecertification for the military engines listed onthe restricted categoryaircraft typecert

i ficates

.U
.S .Department
of Transportation Docket Operations January 13, 2016 It is also worth noting that the US Army

' s UH-60A aircraft sale program. also known as the Black Hawk Exchange and Sales Transaction (BEST) program. has already sold more than one-hundred (100) UH-60A aircraft to the domestic civil market, with plans to sell a total of nearly seven-hundred (700) aircraft over the next few years

.The need for a compliant path to provide new replacement ports and engines

is therefore substantial. Specific sections of 14 CFR from which GE seeks an exemption GE seeks an exemption from §21

.9(c)(1) which provides that: (a} If a person knows. or should know. that a replacement
or modification article is reasonably likely to be installed on a type-certificated product. the person may not produce that article unless
it i s- {1) Produced under
a type certificate

; (2) Produced under anFAA production approval

; (c) Except as provided
in paragraphs (aJ(l) and (aJ(2J of this section,

a person may not sell or represent an article as suitable for
i nstallation on an aircraft type-certificated under Sec

. 21.25(aH2J or 21.27 unless that article-- (1) Was declared surplus by the U.S. Armed Forces, and (2) Was intended for use on that aircraft model by the U.S. Armed Forces. GE also seeks an ex emption from§ 21

.6(a) which states that: (a} Except as specified
in paragraphs
(b} and (c} of this section, no person may manufacture

a new aircraft, aircraft engine, or propeller based ona type certificate unless the person- (1} Is the holder of the type certificate or has a licensing agreement from the holder of the type certificate to manufacture the product; and (2} Meets the requirements
of subpart For G of this part. (b} A person may manufacture one new aircraft based on o type certificate without meeting the requirements
of paragraph
(a) of this section if that person con provide evidence acceptable

to the FAA that the manufacture
of the aircraft by that person began before August s.2004

. (c) The requirements
of this section do not apply to- (1) New aircraft imported under the provisions of §§21.1B3(cJ.
21

.1B4(b). or21

.1BS(c); and (2) New aircraft engines or propellers imported under the provisions of §21

.500

. Extent of relief sought With relief from §21.9 lcll11. GE would comply with §21.9(c) in its entirety since § 2 1.9 (cl(2) provides that: (c) Except as provided
in paragraphs (a}(1) and (a)(2) of this section

.a person may not sell or represent onarticle as suitable for installation on onaircraft type-certif

i cated under Sec. Sec. 21.25(o)(2J or 21.27 unless that orticle- (2} Was intended for use on that aircraft model by the U
.S .Armed Forces

. Page 2U.S

.Department
of Transportation Docket Operations January 13, 2016 With relief from§ 21.6(al. GE would manufacture new engines to meet military requirements under its existing manufacturing quality system. Reason for seeking relief Relief is sought to ensure the availability
of new replacement parts and engines for restricted category aircraft that operate
in substantial part to serve the public interest. Reasons why granting this request
is in the public interest Many of the aircraft at issue fly missions under US State and Federal Government contracts. Operations under those contracts include lifesaving firefighting activities. policing actions. and placement
of power lines in remote locations. Granting this request serves the public interest by ensuring the continued safe operation of these aircraft
in those roles

. Reasons why granting the exemption would not adversely affect safety Granting this exemption serves both public and safety interests. As previously stated, relief is sought to enable the provision of new replacement parts and engines to ensure the operational safety of the restricted category aircraft fleet at issue

. GE is the original manufacturer

of the subject engines, which have accumulated well over ninety (901 million operating hours worldwide

.As manufacturer,
GE closely monitors in-service engines to identify opportunities
for improvement, and to implement improvements

.The current production T700-701D engine configuration incorporates
all operational and safety updates. Granting this exemption affords operators access to the most modern engine technology, replacing the legacy technology included on the aircraft at the time of US Army surplus sale and receipt of the restricted category certificate. Good cause exists for not delaying action on this petition The factors considered
by the FAA (per §11

.871 in expediting
its consideration

of petition for exemption are met. Specifically

,granting this petition will not set a precedent and is not identical to any previous exemption

.Also. although we have filed this petition
in a timely manner

,an exemption

is needed as soon as possible to ensure availability of helicopters required for imminent award of contracts from US Federal and State agencies for the performance

of critical missions that benefit the public interest. We respectfully ask the FAA to grant the requested relief

. Please contact meif you have any questions or require additional information. Very Respectfully, Amy Dow GE Aviation. Airworthiness and Certification Manager, Small Engines Page 3U.S

.Department
of Transportation Docket Operations January13,2016 Cc CraigFabian

,GEAviation Compliance Manager Doug Hensley,GEAviation LegalCounsel Brian Schaap,SeniorProduct Manager,CommercialT700 Engines Page4