Gulfstream Aerospace LP ¤ PO Box 1 03 6 ¤ Airpo rt Ci ty 70100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

November 10 , 2011 GALP Ref: FAA/11217/CG 

 Petition for partial Exemption

Gulfstream Aerospace LP 

Gulfstream Model G280 

Gulfstream Aerospace LP hereby petitions for relief from 14 CFR Part 21.213(a) as amended by 

Amendment 21-79 of Title 14, Code of Federal Regulations (14 CFR) to allow a non-United States 

Manufacturer the ability to obtain a Provisional Certificate of Airworthiness. Gulfstream Aerospace 

LP (hereinafter GALP) is a limited partnership company established and wholly owned by Gulfstream 

Aerospace Corporation to manage Type Certification of Gulfstream Aerospace airplane models 

manufactured in Israel by Israel Aerospace Industries. GALP will apply for a Provisional Type 

Certificate for the Gulfstream model G280 airplane and is in need of relief from 14 CFR Part 

21.213(a) to allow for the application and issuance of a Class II Provision Airworthiness 

Certificate.

Existing Regulations 

Gulfstream Aerospace LP (GALP) requests partial relief from the following regulation: 

Section 21.213(a) – 

“Eligibility. 

(a) A manufacturer who is a United States citizen may apply for a Class I or Class II provisional 

airworthiness certificate for aircraft manufactured by him within the U.S.” 

Background 

The Gulfstream model G280 is nearing the conclusion of a Type Certification effort begun by initial 

application on March 30, 2006. GALP is seeking a Provisional Type Certificate. An accompanying 

Provisional Certificate of Airworthiness is needed to facilitate flight demonstration and training efforts 

in the U.S. 

Reasons for Petition 

GALP is a Texas limited partnership, whose partners are both wholly owned Gulfstream Aerospace 

Corporation subsidiaries. GALP maintains an office in Israel to assist in the management of Type 

Certification activities for Gulfstream Aerospace airplane models manufactured by Israel Aerospace 

Industries in Israel. As such, GALP is also the applicant for Type Certification of the G280. While 

outfitted and sold exclusively in the United States by GALP, the G280 is not manufactured in the 

United States and does not meet the requirements for issuance of a provisional airworthiness 

certificate under 14 CFR 21.213(a). 

The model G280, like predecessor GALP models, will be manufactured in Israel and delivered to 

Gulfstream in the United States for final outfitting. As a part of this final phase design development 

there is a need for market survey and customer demonstration flights. These flights can only be 

accomplished with the issuance of Class II Provisional Airworthiness Certificate as part of the 

Provisional Type Certificate issuance. 

Public Interest / Benefit: 

Granting this Petition for Exemption is in the public interest as it would permit the efficient 

transport of employees, corporate executives and other important clientele in an efficient and 

safe environment. Due to the high demand for these corporate aircraft, it is imperative that 

the petitioner is granted the regulatory relief requested. Failure to achieve this goal will 

result in product development delays and the potential for significant loss of income, in both 
Gulfstream Aerospace LP ¤ PO Box 1 03 6 ¤ Airpo rt Ci ty 70100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

domestic and foreign trade for the United States and the petitioner. Therefore the stabilizing 

effect that manufacturer and support of corporate aircraft has on the job market and balance 

of trade for the United States is significant and definitely in the public interest. 

Granting this exemption will allow Gulfstream and GALP to continue final product 

development, including interior outfitting, flight demonstration / product familiarization, inpace with our Type Certification effort. 

Without the exemption, GALP will have production airplanes awaiting Type Certification 

before being eligible to fly to the U.S. for modification development work and to operate here 

as stated above. This would deprive the company of many months of productive effort. 

The level of safety intended by the rule will be upheld. As an integral element of Gulfstream 

Aerospace Corporation, GALP has the direct benefit of GAC’s experience as a U.S. 

manufacturer of Large Cabin jet transport airplanes. GALP / GAC would manage all aspects 

of the G280 program under a Provisional Certificate of Airworthiness in the same manner as 

for Gulfstream Large Cabin airplane models. Flight operations and maintenance activities 

would be governed by the same standards applicable to our existing Large and Mid-Size 

cabin airplane production, maintenance and operational units. 

Not granting this exemption would have a significant negative impact for several reasons: 

• An extended resource demand on the FAA / public resources to support a delayed 

effort. 

• Reduction in employment of production workers at Gulfstream Aerospace and its 

suppliers around the U.S. and the world due to delayed completions and related 

developmental efforts. 

• Several major corporations and other entities around the U.S. and the world 

anticipating the delivery of the G280 aircraft to meet their business and critical 

mission needs would need to find alternative transportation. 

• The balance of trade between the US and other nations would be negatively impacted 

due to delayed deliveries and lost sales. 

• Taxation at the local, state, and federal levels would be adversely impacted from loss 

of wage taxes and sales taxes. 

Level of Safety equal to that provided by 14 CFR 21.213(a) 

GALP has carefully examined the Provisional Type Certificate / Provisional Certificate of 

Airworthiness approach and concluded there is no adverse affect on safety based on the 

exemption being sought. 

As an integral element of Gulfstream Aerospace Corporation, GALP has the direct benefit of 

GAC’s experience as a U.S. manufacturer of Large Cabin jet transport airplanes. GAC has 

an organic familiarity with the existing IAI-built Gulfstream models G100, G150 and G200 

and has played a direct role in the development of the G280. GAC crews are highly 

experienced in all of these models, including flight test crews who have participated in the 

product development and flight testing of the new G280 model. 

GALP / GAC would manage all aspects of the G280 program under a Provisional Certificate 

of Airworthiness in the same manner as for Gulfstream Large Cabin airplane models. 

Flight operations and maintenance activities would be governed by the same standards 

applicable to our existing Large and Mid-Size cabin airplane production, maintenance and 
Gulfstream Aerospace LP ¤ PO Box 1 03 6 ¤ Airpo rt Ci ty 70100 ¤ ISRAEL 

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 

operational units. Accordingly, GALP’s management of these activities is functionally similar 

to that of the case considered and accepted by FAA in providing the current 14 CFR 

21.213(b) provisions for Air Carriers under amendment 21-12. 

Gulfstream Repair Stations in the U.S. would apply the maintenance instructions and 

personnel training requirements in the same manner as for existing types to ensure 

appropriate maintenance and oversight of airworthiness. This arrangement would be closely 

coordinated as required with overseeing FAA offices including ACO, FSDO and MIDO at 

each location where maintenance and operations will be based. The G280 would be added 

to the operational specifications of each repair station, as required. 

Further, as evidenced by GAC’s exemptions 9887 and 9889, GAC maintains a highlyexperienced and well-trained force of pilots who are well qualified to operate the G280 within 

a well-regimented company system. Pilot-in-command duties would be limited to those who 

are appropriately qualified to operate the G280 under the Provisional Certificate of 

Airworthiness requirements and limitations. 

GALP requests FAA consideration of expeditious handling and foregoing of public 

comment period under the provisions of 14 CFR 11.87

The need for this exemption is urgent to preclude lost time for accomplishing the goals 

defined herein. GALP does not believe the requested relief to be controversial. GALP / 

GAC are integral entities in the design and manufacturing of the G280; granting this 

exemption at an early date would assure the normal fulfillment of that role in a timely 

manner. 

GALP also believes an exemption as requested would be consistent with the FAA’s own 

rationale in amendment 21-12 of this rule. GALP’s reasons for this petition, the underlying 

demonstrated safety of the product and GALP’s means of managing the operation of the 

G280 under a Provisional Certificate of Airworthiness closely parallel those FAA realized 

when providing the current 14 CFR 21.213(b) by amendment 21-12. 

A delay of action on this petition would jeopardize the timely maturity of the G280 

commensurate with eventual grant of Type Certification. 

Summary

Gulfstream Aerospace LP (GALP) respectfully requests an exemption from 14 CFR Part 21.213(a) 

as this rule relates to eligibility of U.S. Manufacturers for a U.S. Provisional Certificate of 

Airworthiness for the G280 airplane. This exemption would be of similar logic to that applied by FAA 

in the final rule under 14 CFR 21.213(b) provided under amendment 21-12 by virtue of GALP’s 

purposes and means of managing the operational aspects of a Provisional Certificate of 

Airworthiness on the G280. This exemption will allow GALP to perform certain U.S. domestic 

modification and operational functions that are vital to the finished product commensurate with U.S. 

Type Certification. GALP further requests FAA consideration of the critical timing of this petition, and 

accordingly, relief from the public comment period to assure timely continuation of U.S. domestic 

operational needs. 

For further information please contact : 

Baruch Marom, baruch.marom@gulfstream.com,Tel.972 3 9356629 

Charly Gaber,charly.gaber@gulfstream.com,Tel.9356627