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 

Craig Fabian 

Senior Compliance Manager, Industry Standards 

GE -Aviation 

1 Neumann Way Evendale. Ohio USA 

General Electric Company 

T 513 243 6837 

Croig.fobian@ge.com 

RE: GE Aviation Petition for Exemption from 14 CFR § 21.9(cl(1) and§ 21.6(al 

Dear Madam or Sir: 

Pursuant to Title 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) to allow GE to manufacture and sell 

replacement and modification articles for fitment to restricted category UH-60A1 helicopters previously operated by the US Army. GE also seeks an exemption from 14 CFR § 21.6(a) to enable the manufacture and sole of new engines for those same aircraft. 

Summary and background 

The requested relief is compelled by the need to supply replacement articles and engines for the subject aircraft, type certificated under 14 CFR § 21.25(a)(2). GE military engine models are part of those aircraft 

type certificates.2 However, since the military engines are not independently type certificated, they are not eligible for manufacture under the Federal Aviation Administration (FAA} production certificate (PCI held by GE. As a result, GE is in the curious position of not being able to support the fleet of restricted category aircraft. although it originally manufactured the engines included in the restricted category aircraft type certificates. 

We emphasize that the subject aircraft serve a substantial public interest through their firefighting, agricultural. and other service roles. Granting this petition furthers that public interest by ensuring the availability of new replacement parts and engines for continued safe operation during those service missions. 

l lncluding S-70A and S-70i which are UH-60A and UH-60L derivatives respectively. Engine models allowed on the UH-60As: 

two General Electric T700-GE-700 Original, two General Electric T700-GE-701C Alternate, two General Electric 

T700-GE-701D Alternate. 

2 See. for example, FAA type certificate data sheet R0012DE for the type certificate held by BHI H60 Helicopters. LLC. 

There is no separate level of restricted category engine type certification for the military engines listed on the 

restricted category aircraft type certificates. 
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 is-

{1) Produced under a type certificate; 

(2) Produced under an FAA 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 installation 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 exemption 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 on a 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). or 21.1BS(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 §21.9 (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 on article as suitable for installation on on aircraft type-certificated 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. 

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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 me if you have any questions or require additional information. 

Very Respectfully, 

Amy Dow 

GE Aviation. Airworthiness and Certification Manager, Small Engines 

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