Petition of 

BEFORE THE 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

) 

) 

- ·~ ; 

ISRAEL AEROSPACE INDUSTRIES L TO ) Docket No. F AA-2000-8533 

) 

for an exemption from Sections 61.77(a) and ) 

63.23(a) of Title 14, Code of Federal ) 

Regulations ) ------------------------------

PETITION TO EXTEND EXEMPTION 

Communications with regard to this document should be addressed to: 

March 13, 2015 

ACTIVE 206515637v.2 

Rory Kelleher 

Sidley Austin LLP 

78 7 Seventh A venue 

New York, NY 10019 

212-839-7385 (direct phone) 

212-839-5599 (direct fax) 

rkelleher@sidley.com 

eounsel for Israel Aerospace Industries Ltd 
Petition of 

BEFORE THE 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

March 13,2015 

) 

) 

ISRAEL AEROSPACE INDUSTRIES L TO ) Docket No. FAA-2000-8533 

for an exemption from Sections 61 .77(a) and 

63.23(a) ofTitle 14, Code of Federal 

Regulations 

) 

) 

) 

) 

PETITION TO EXTEND EXEMPTION 

Pursuant to 49 U.S.C. § § 44701(£) and 40113, and Part 11 of Title 14 of the Code of 

Federal Regulations ("C.F.R."), Israel Aerospace Industries Ltd ("IAI" or the "Company"), 

hereby requests extension of FAA Exemption No. 10283A (issued May 2, 2013) to continue to 

permit the issuance of special purpose authorizations otherwise issued under 14 C.F.R. §§ 61.77 

and 63.23(a) to IAI-assigned pilots, flight engineers and flight navigators for the operation of 

U.S.-registered aircraft, as follows: 

ACTlYE 206515637v.2 

(a) Ferry/delivery flights of U.S.-registered aircraft being 

delivered by IAI from Israel to the United States for its 

U.S. and international customers; 

(b) Ferry/delivery flights of U.S.-registered aircraft being 

delivered by IAI from Israel to other countries for its U.S. 

and international customers; 

(c) Test and acceptance flights of U.S.-registered aircraft being 

delivered by IAI for its U.S. and international customers; 

and 

(d) Ferry, delivery and acceptance flights for its customers 

from IAI's Part 145 repair stations. 
Israel Aerospace Industries Ltd 

Petition to Extend Exemption 

Page 2 

The existing exemption is valid until June 30, 2015. IAI is requesting that the exemption 

be extended for a two year period to allow for the issuance of special purpose pilot authorizations 

to IAI-assigned pilots, flight engineers and flight navigators pursuant to 14 C.F.R. §§ 61.77 and 

63.23(a), consistent with the conditions and limitations set forth in Exemption 1 0283A. The 

same justifications for the issuance of the exemption continue to be applicable. IAI hereby 

incorporates by reference all relevant infonnation previously submitted in the instant docket. 

In light of the unique and continuing security concerns facing the country of Israel, and 

the other facts and circumstances set forth in this docket, IAI submits that extension of the 

exemption (under the same conditions and limitations) is in the public interest, and will provide 

at least an equal, if not greater, level of safety. IAI submits that the conditions and reasons 

regarding public interest and safety upon which Exemption No. 1 0283A was granted remain 

unchanged, and the requested extension will not adversely affect safety in any way. 

Pursuant to 14 C.F.R. § 11.87, IAI respectfully requests a waiver from the requirement in 

Section 11.85 that a summary of the petition for exemption be published in the Federal Register 

and that comments be considered before the FAA takes action on this petition to extend the 

exemption. IAI submits that good cause exists for waiving the advance notice and publication 

requirements, for the following reasons: 

1. 

2. 

3. 

ACTIVE 2065 l5637v.2 

This petition seeks to extend the exemption for reasons 

identical to those that supported the original grant of the 

exemption and therefore will set no new precedent; 

The relief requested by this petition is identical to the 

exemption previously granted by the FAA; 

Grant of the exemption would maintain at least and 

equivalent level of safety; 

2 
Israel Aerospace Industries Ltd 

Petition to Extend Exemption 

Page 3 

ACTIVE 2065!5637v.2 

4. Any delay in acting on this petition would be detrimental to 

IAI because TAl has immediate need for operation of 

aircraft pursuant to the exemption; and 

5. The public interest would be served by promptly extending 

the exemption, as requested. 

3 
Israel Aerospace Industries Ltd 

Petition to Extend Exemption 

Page 4 

WHEREFORE, for the foregoing reasons, IAI respectfully requests that the FAA extend 

Exemption No. 10283A, as described herein, for a two year period prior to the June 30, 2015 

expiration date. 

Roty Kelleher 

Sidley Austin LLP 

787 Seventh A venue 

New York, NY 10019 

212-839-7385 (direct phone) 

212-839-5599 (direct fax) 

rkelleher@sidlev. com 

Counsel for Israel Aerospace Industries Ltd 

cc: Thomas S. Engle, Deputy Assistant Secretary for Transportation Affairs, 

U.S. Department of State 

John M. Krepp, Manager, FAA New York International Field Office 

ACTIVE 206515637v.2 4