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

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 November 10 , 2011 GALP Re f: 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 Regula tions (14 CFR) to allow a non-United States Manufacturer the ability to obtain a Provisional Ce rtificate of Airworthiness. Gulfstream Aerospace LP (hereinafter GALP) is a limited partnership comp any established and wholly owned by Gulfstream Aerospace Corporation to manage Type Certification of Gulfstream Aerospace airplane models manufactured in Israel by Israel Aerospace Industri es. 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 rel ief from the following regulation:

Section 21.213(a) –

“Eligibility.

(a) A manufacturer who is a United States citizen m ay 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 P rovisional Type Certificate. An accompanying

Provisional Certificate of Airworthiness is needed to facilitate flight demonstration and training eff orts
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 a irplane models manufactured by Israel Aerospace Industries in Israel. As such, GALP is also the ap plicant 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 fo r 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 outfittin g. As a part of this final phase design developmen t there is a need for market survey and customer demo nstration flights. These flights can only be accomplished with the issuance of Class II Provisio nal Airworthiness Certificate as part of the Provisional Type Certificate issuance.

Public Interest / Benefit:

Granting this Petition for Exemption is in the publ ic interest as it would permit the efficient transport of employees, corporate executives and ot her 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 req uested. Failure to achieve this goal will result in product development delays and the potent ial for significant loss of income, in bothGulfstream Aerospace LP ¤ PO Box 1 03 6 ¤ Airpo rt Ci t y 70100 ¤ ISRAEL

Tel: +972-3- 935-6624 ¤ Fax: +972-3-935-675 0 domestic and foreign trade for the United States an d the petitioner. Therefore the stabilizing effect that manufacturer and support of corporate a ircraft has on the job market and balance of trade for the United States is significant and d efinitely in the public interest.

Granting this exemption will allow Gulfstream and G ALP 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 ai rplanes awaiting Type Certification before being eligible to fly to the U.S. for modifi cation 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 up held. 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 operatio nal units.

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

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

effort.

• Reduction in employment of production workers at G ulfstream Aerospace and its suppliers around the U.S. and the world due to dela yed completions and related developmental efforts.

• Several major corporations and other entities aro und the U.S. and the world anticipating the delivery of the G280 aircraft to m eet their business and critical mission needs would need to find alternative transp ortation.

• The balance of trade between the US and other nati ons would be negatively impacted due to delayed deliveries and lost sales.

• Taxation at the local, state, and federal levels w ould 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 Ce rtificate / Provisional Certificate of Airworthiness approach and concluded there is no ad verse affect on safety based on the exemption being sought.

As an integral element of Gulfstream Aerospace Corp oration, GALP has the direct benefit of GAC’s experience as a U.S. manufacturer of Large Ca bin 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 fligh t test crews who have participated in the product development and flight testing of the new G 280 model.

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

of Airworthiness in the same manner as for Gulfstre am 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 andGulfstream Aerospace LP ¤ PO Box 1 03 6 ¤ Airpo rt Ci t y 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 amendme nt 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 airworthin ess. 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 st ation, as required.

Further, as evidenced by GAC’s exemptions 9887 and 9889, GAC maintains a highlyexperienced and well-trained force of pilots who ar e 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 und er the Provisional Certificate of Airworthiness requirements and limitations.

GALP requests FAA consideration of expeditious hand ling and foregoing of public comment period under the provisions of 14 CFR 11.87

The need for this exemption is urgent to preclude l ost time for accomplishing the goals defined herein. GALP does not believe the requeste d relief to be controversial. GALP / GAC are integral entities in the design and manufac turing 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 Airworthine ss closely parallel those FAA realized when providing the current 14 CFR 21.213(b) by amen dment 21-12.

A delay of action on this petition would jeopardize the timely maturity of the G280 commensurate with eventual grant of Type Certificat ion.



### Summary

Gulfstream Aerospace LP (GALP) respectfully request s an exemption from 14 CFR Part 21.213(a) as this rule relates to eligibility of U.S. Manufac turers for a U.S. Provisional Certificate of Airworthiness for the G280 airplane. This exemptio n would be of similar logic to that applied by FAA in the final rule under 14 CFR 21.213(b) provided u nder amendment 21-12 by virtue of GALP’s purposes and means of managing the operational aspe cts of a Provisional Certificate of Airworthiness on the G280. This exemption will all ow GALP to perform certain U.S. domestic modification and operational functions that are vit al to the finished product commensurate with U.S. Type Certification. GALP further requests FAA cons ideration 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.935662 7