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Gulf stream A ero space LP ¤ c/o IA I D ept. 4199 ¤ B en Guri o n I nt' l A i rpo rt 7 0100 ¤ IS R A E L 

T el: + 972-3-935-6 624 ¤ Fa x: + 972 - 3-935- 6750

May 14, 2015 GALP Ref: FAA/15205/CG

 

Subject: PETITION FOR EXEMPTION FROM REQUIREMENTS OF 14 CFR §45.13(A)(1) 

FOR THE GULFSTREAM G280

In accordance with 14 CFR §11.81, Gulfstream Aerospace LP (GALP) here by petitions 

for exemption from 14 CFR §45.13(a)(1) as amended by Amendment 45-28. This 

exemption would permit relief from the requirement to list the aircraft builder’s name on 

the aircraft identification plate which applies to the Gulfstream G280 model.

The following are excerpts from the regulation which have relevance to this petition:

14 CFR §21.182(a)

(a) Except as provided in paragraph (b) of this section, each applicant for 

an airworthiness certificate under this subpart must show that his 

aircraft is identified as prescribed in §45.11.

14 CFR §45.11(a)

(a) Aircraft and aircraft engines. Aircraft covered under Sec. 21.182 of this 

chapter must be identified, and each person who manufactures an 

aircraft engine under a type or production certificate shall identify that 

engine, by means of a fireproof plate that has the information specified 

in Sec. 45.13 of this part marked on it by etching, stamping, engraving, 

or other approved method of fireproof marking. The identification plate 

for aircraft must be secured in such a manner that it will not likely be 

defaced or removed during normal service, or lost or destroyed in an 

accident. Except as provided in paragraphs (c), (d), and (e) of this 

section, the aircraft identification plate must be secured to the aircraft 

fuselage exterior so that it is legible to a person on the ground, and 

must be either adjacent to and aft of the rear-most entrance door or on 

the fuselage surface near the tail surfaces. For aircraft engines, the 

identification plate must be affixed to the engine at an accessible 

location in such a manner that it will not likely be defaced or removed 

during normal service, or lost or destroyed in an accident.

14 CFR §45.13(a)

(a) The identification required by §45.11 (a) through (c) must include the 

following information:

(1) Builder's name.

(2) Model designation.

(3) Builder's serial number.

(4) Type certificate number, if any.

(5) Production certificate number, if any.

.............
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Gulf stream A ero space LP ¤ c/o IA I D ept. 4199 ¤ B en Guri o n I nt' l A i rpo rt 7 0100 ¤ IS R A E L 

T el: + 972-3-935-6 624 ¤ Fa x: + 972 - 3-935- 6750

Gulfstream Aerospace LP (GALP), the type certificate holder of the Gulfstream G280 

aircraft, has licensed Israel Aerospace Industries (IAI) to manufacture the Gulfstream 

G280 under a licensing agreement. The assembly of the aircraft by IAI is performed 

under the production certificate issued to IAI by the Civil Aviation Authority of Israel 

(CAAI). Under such an arrangement, per section 6.e of AC 45-2D, “Identification and 

Registration Marking”, IAI, the licensee, should and currently does appear on the aircraft 

identification plate as the builder. 

The basic or “green” aircraft is assembled by IAI and then exported to the United States 

to the Gulfstream Completions Center located at Love Field in Dallas Texas where the 

aircraft is outfitted, painted and STCs are installed per the specifications of the final 

customer. 

The FAA itself has recognized over the last several decades that the aircraft 

manufacturing industry has evolved significantly from what was once primarily a U.S. 

centric industry to what is now become a continually expanding global environment. This 

is clearly illustrated in the case of the G280, for which major aircraft components and 

sub-assemblies are manufacture in North America, Europe, and Asia. 

Due to certain long standing geopolitical issues, the appearance of “IAI LTD” as the 

builder on the aircraft identification plate can have a significant negative impact on 

Gulfstream’s ability to market and sell aircraft in certain regions / markets around the 

world. We therefore are requesting relief from 14 CFR §45.13(a)(1) such that if granted 

the aircraft identification plate will not include a field for the aircraft builder.

The intended purpose of mentioning the builder on the aircraft identification plate is 

essentially to provide operators and authorities a “point of contact” for any issues that 

might occur in service. The business relationship established between Gulfstream 

Aerospace Corporation (GAC), with headquarters in Savannah Georgia, and IAI is such 

that GAC performs all marketing, sales, publications (AFM, AMM, etc.) and product 

support functions. From the perspective of the operator and the authorities, Gulfstream / 

GALP (not IAI) is in fact the contact for all issues related to the aircraft - GALP as the 

type certificate holder and Gulfstream in the marketing, sales and product support roles. 

So allowing this exemption certainly does not represent any lost benefit to the public and 

in fact it could be argued that there is a benefit in that the aircraft identification plate 

would unambiguously identify Gulfstream as the point of contact for all matters 

associated with the aircraft. We do not see this issue as representing an issue of any 

significant interest to the public however it does represent a significant benefit to 

Gulfstream and IAI in terms of market access and sales.

Accordingly, GALP respectfully requests a waiver on the public notification period as such 

a delay in granting the exemption will negatively affect ongoing sales negotiations and as 

stated above, this exemption does not represent an issue of interest to the public. The 

proposed change clearly has no impact whatsoever on aircraft safety or operations and

therefore waiver of public notification period is appropriate.
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Gulf stream A ero space LP ¤ c/o IA I D ept. 4199 ¤ B en Guri o n I nt' l A i rpo rt 7 0100 ¤ IS R A E L 

T el: + 972-3-935-6 624 ¤ Fa x: + 972 - 3-935- 6750

Finally, it is our intention that the privileges of this exemption also be exercised outside of 

the United States. The stated goal for this exemption is to expand access for this aircraft 

to global markets and to achieve this goal it is necessary that operation under this 

exemption be extended outside of the United States. In support of this request, per the 

guidance provided in 14 CFR §11.83, GALP has verified that adoption of this requested 

exemption has no affect on compliance with the relevant International Civil Aviation

Organization (ICAO) standards or requirements contained in Annex 7, titled “Aircraft 

Nationality and Registration Marks”, to the Convention on International Civil Aviation. In 

fact, ICAO does not require the aircraft identification plate to list the builder of the aircraft.

Gulfstream appreciates the FAA’s consideration of this petition. Please contact me 

directly concerning this important matter using the contact information provided below.

Regards,

Charly Gaber

Airworthiness & Certification Manager

Gulfstream Aerospace LP

P.O. Box 1036

Airport City, Israel 7019900

e-mail: charly.gaber@gulfstream.com

Telephone: +972-3-935-6627

Fax: +972-3-935-6750