# Gulfstream

A GENERAL DYNAMICS CONIPANV

U.S. Department ofTransportation Docket Operations, M-30 West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, D.C. 20590 July27, 2015 A&C-15-104

Subject: Gulfstream Aerospace Corporation- Petition for Exemption from 14 CFR 61.57(a) and (b) for certain Gulfstream Airplane Models Reference: 1) Exemption no. 9887D granted Gulfstream Aerospace Corporation, docket no. FAA-2007-27324 2) Exemption no. 9889C granted Gulfstream Aerospace Corporation, Docket no. FAA-2007-27325
Dear Sir or Madam: Gulfstream Aerospace Corporation ("Gulfstream") hereby petitions in accordance with 14 CFR 11 SubpartA for an exemption from 14 CFR 61.57(a) and (b) forflight currency with regard to operator fleet operations ofthe Gulfstream model G-IV, GIV-X, GV, GV-SP and GVI (G650 and G650ER) airplanes. Relieffrom the rule as requested is intended to provide reliefto all operators ofthe above named Gulfstream model airplanes. The same logicthat underlies exemption 9887D and 9889C applies: while the G-IV/GIV-X, GV/GV-SP and GVI airplanes do have individual type ratings, all are similar in size and have an excellent commonality ofperformance, systems and handling characteristics that are sufficient forthe purposes ofthis petition. The previously granted exemptions 9887D and 9889C therefore provide an ample and valid precedent for consideration. So also do exemptions previously granted the Boeing Company (no. 6843) and Gulfstream, including exemption nos. 9408 and 9408A and the preceding Gulfstream exemption no. 6859. While Gulfstream and other manufacturers such as Boeing have held that pilot proficiency is maintained by standardized operational requirements inherentto their organizations, it is further recognized that operators ofmultiple Gulfstream models also maintain similartraining and experience standards for pilots who are rated among the Gulfstream types within theirfleets. Gulfstream Aerospace Corporation therefore petitions as follows: 14 CFR 11

.81(b)- Sections from which relief is sought: 14 CFR 61.57(a) and (b) 14 CFR 11

.81(c)
- Extent and reason for seeking relief: This exemption is necessaryto facilitate the operation ofGulfstream G-IV, GIV-X, GV, GV-SP and GVI (G650 and G650ER) by pilots who are employed by flight operations departments having any
P 0. Box 2206 • Savannah, GA 31402-2206 USA • Telephone (912) 965-3000 • gulfstream.com

# Gulf 

# stream

A GENERAL DYNAMICS COMPANY

combination ofthese modelswithin theirfleet. Specifically, relief is soughtfrom 14 CFR 61.57(a) with regard to general experience as defined therein, and 61

.57(b) with regard to nighttake-offand landing experience. Compliance with the current requirements ofthese regulations to keep qualified crews current in all fleet models could easily require some 100 or more flights peryearforthe average flight department. Conversely, ifcurrency is recognized by virtue offlight experience in any one ofthe Gulfstream types identified here, the numberofflights required to maintain currency could be reduced to some 35 or so flights peryearforthe same flight department- a reduction ofapproximately two-thirds ofthe present burden. This would result in a reduction ofairtraffic congestion, a savings of resources such as fuel and relieve other operational impactsto the public and airtransportation system. All Gulfstream pilots undergo highly-standardized type training and are experienced in this make and category ofairplane and operate all models ofGulfstream aircraft within theirfleet on a regular basis. Thetypical Gulfstream pilot logs an average ofsome 300 to 600 hours per year in a variety of Gulfstream airplanes and periodically attends FlightSafety International, rotating among the Gulfstream aircraft courses that are applicable to their particularfleet and forwhich they are rated. The Gulfstream model airplanes forwhich this relief is sought are used by businesses, government organizations, the military and foreign entities in the transport ofexecutives, government and military leaders and heads ofstate whose conduct of business has a direct impact on the public. The requested exemption would permit rated pilots ofthese types to provide more productive time and effort to the conduct offlight for the purposes of meeting the service needs oftheir organizations and to the benefit ofsuch operations. This exemption would apply only to Gulfstream pilots who are rated in the models named herein. 14 CFR 11.81(d)- Public interest I benefit Relieffrom the current literal requirements of 14 CFR 61.57(a) and (b) reduce the present requirement of 100 or more flights peryearto approximately 35 flights pertypical flight department. This would result in a significant reduction ofair traffic congestion and other operational impacts to the public and airtransportation system. The businesses, government and military organizations and foreign entities utilizing these airplanes would be better served by the greater availability ofthese pilots to supportthe primary mission intended by the operator'sfleet, hence the public interest is morefavorably supported. The exemption sought is effectively preceded by that granted underexemption no. 98870, to include similar Conditions and Limitations as proscribed therein forthe same models. The same need of exemption for operators exists as does forthe precedent cases as-cited. 14 CFR 11

.81(e)- Information supporting this petition: The exemption sought is in effect identical to that previously granted for similar airplane models in the precedent cases. The relief soughtwill significantly reduce the impact ofoperations to the airtraffic system and public generally. The public will be better served in thatthe operators ofthese aircraft
- including executives, leaders and heads ofstate ofdomestic and foreign businesses, governments, military organizations and foreign states, are more efficiently supported. Resource expenditures now needed to supportthe present requirement could be reduced by approximately two-thirds.

P.O. Box 2206 • Savannah, GA 31402-2206 USA • Telephone (912) 965-3000 • gulfstream.com

# Gulfstream

A GENERAL DYNAMICS COMPANY

The pilots ofthese Gulfstream models are ofthe caliber oftraining and experience to maintain a reliable operational standard at least equivalentto that expected by the current rule. 14 CFR 11.81(g)- Additional information: In accordance with 14 CFR 11.87(a)through (d), Gulfstream seeks the earliest possible consideration ofthis petition and grantofan extension ofthis exemption without summary publication forthe following reasons: (a) Granting this exemption as petitioned will not set a precedent. (b) The relief requested by this petition is in essence identical to that previously granted by previously granted in exemption no. 98870, 9889C and preceding similarexemptions granted Boeing and Gulfstream as identified otherwise herein. (c) A delay in acting on this petition would adversely delaythe benefits ofthis exemption as stated herein. Gulfstream appreciates FAA's consideration ofthis petition for exemption and looksforward to the earliest possible and favorable disposition so thatthe benefits as stated here may be realized by our operators as early as possible. Ifthere are any questions, or if I can be offurther assistance, please do not hesitate to contact Kimberly Lascell at (912) 395-8085 orat Kimberly.Lascell@gulfstream.com. Sincerely,

# ~~cd6 Kimberly Lascell, DirectorAirworthiness & Certification
CC: 

### J. O'Meara, Gulfstream Flight Operations

P.O. Box 2206 • Savannah, GA 31402-2206 USA • Telephone (912) 965--3000 • gulfstream.com