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Draft Submittal to

November 26, 2014

SUBMITTED ELECTRONICALLY TO: Federal Docket Management System, www.regulations.gov

U.S. Department of Transportation Docket Operations West Building, Room W12-140 1200 New Jersey Avenue, SE Washington, D.C. 20590-0001

Subject: Hartzell Propeller Inc. Request to Amend the Grant of Exemption from 14 CFR Part 45.13(a)(4), Regulator Docket FAA-2013-0982, Exemption No. 11076

Dear Ladies and Gentlemen:

Pursuant to 14 CFR § 11.101 Hartzell Propeller Inc. (Hartzell) hereby petitions to amend the FAA’s October 6, 2014 grant of exemption from 14 CFR Part 45.13(a)(4) for propeller.

By letter dated November 7, 2013, and supplemental information dated August 14, 2014, Mr. Richard Edinger, VP Certification and Flight Safety, Ha rtzell Propeller Inc. (Hartzell), One Propeller Place, Piqua, OH 45356-2634, petitioned the Federal Aviati on Administration (FAA) on behalf of Hartzell for an exemption from § 45.13(a)(4) of Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted, would relieve Hartzell from the requirement to include a propeller type certificate (TC) number identification mark on the propeller blades it manufactures.

On October 6, 2014 the exemption was granted with the following conditions and limitations:

Conditions and Limitations 1. All of the information specified in § 45.13(a) must continue to be placed on propeller blades for which only one type certificate (TC) is applicable. 2. For propeller blades for which more than one TC is applicable, the term “multiple” may be marked on the blade in lieu of the applicable TC numbers. This exemption terminates on October 31, 2016, unless sooner superseded or rescinded.

We believe the “Conditions and Limitations” contained in the “Grant of Exemption” letter will increase confusion by adding more variation in the markings found on a blade and will have a negative impact on flight safety. We propose that the exemption conditions and limitations be amended to exclude marking the TC number on our blades based on the discussion below and that the exemption expiration date be eliminated or extended.

We reviewed our initial petition for exemption and be lieve that conditions and limitations associated with granting the exemption may have been the result of our not providing the information required by §11.81 in a manner that could be assessed by the FAA. Therefore, we will re-establish the basis for our petition for exemption and provide additional information to support an amendment to exclude the conditions and limitation from the exemption following the paragraph format provided in §11.81. Hartzell Propeller Inc. One Propeller Place Piqua, OH 45356-2634 USA

Tel: +1-937-778-4200

Fax: +1-937-778-4271 www.hartzellprop.comU.S. Department of Transportation November 26, 2014 Page 2

Summary of the Hartzell Petition for Exemption with additional information

§11.81 (a) Your name and mailing add ress and, if you wish, other contact information such as a fax number, telephone number, or e-mail address: Richard Edinger Hartzell Propeller Inc. One Propeller Place Piqua, OH 45356-2634 USA

Tel: 937-778-4200

Fax: 937-778-4271

Cell: 937-214-6544

§11.81 (b) The specific section or sections of 14 CFR from which you seek an exemption: Hartzell is requesting an exemption from regulation 14 CFR Part 45.13(a)(4) to mark the propeller blade with the type certificate number. The propeller and propeller hub will be marked in accordance with part 45. The specific requirement is underlined below along with the related requirements.

Section 45.11(c) amendment 45-27 requires: (c) Propellers and propeller blades and hubs. Each person who produces a propeller, propeller blade, or propeller hub under a type certificate or production certificate must mark each product or part using an approved fireproof method. The marking

must-- (1) Be placed on a non-critical surface; (2) Contain the information specified in Sec. 45.13; (3) Not likely be defaced or removed during normal service; and (4) Not likely be lost or destroyed in an accident.

Section 45.13(a) amendment 45-28 requires: (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. (6) For aircraft engines, the established rating.

§11.81 (c) The extent of relief you seek, and the reason you seek the relief: Hartzell requests relief from the requirement of §45.13(a)(4) to mark a propeller type certificate (TC) number on the propeller blades it manufactures. We request that our blades be marked with the following information: (1) Builder's name (2) Model designation (3) Builder's serial number and (4) Production certificate number

Reference: On October 6, 2014 the exemption was granted with the following conditions and

limitations:U.S. Department of Transportation November 26, 2014 Page 3

Conditions and Limitations

1. All of the information specified in § 45.13(a) must continue to be placed on propeller blades for which only one type certificate (TC) is applicable. 2. For propeller blades for which more than one TC is applicable, the term “multiple” may be marked on the blade in lieu of the applicable TC numbers. This exemption terminates on October 31, 2016, unless sooner superseded or rescinded

We are requesting relief from the terms and conditions in the exemption for the following

reasons.

Through the normal course of business, we are constantly designing new blade designs for new or existing TC’s. Every new blade model is initially certificated for just one propeller TC. Therefore, following the “Conditions and Limitations” in the “Grant of Exemption” letter, the initial shipments of that blade model will be required to show that specific TC marking. However, it is typical for us to subsequently add that blade model to more than one propeller TC. Once it is applicable to two or more propeller TC’s, we will then be required to change the marking to say “multiple”. Conceivably, all of the following variations can exist on different blades in the same propeller. 1) No TC marking (valid for historically produced blades) 2) One TC marking (valid for a blade design associated with one propeller TC at the time of shipment) 3) “Multiple” (valid for a blade design associated with more than one propeller TC at time of shipment) Confusion is certain to occur when these variations are observed on the same blade design and when blades with various TC markings are installed in a propeller with yet a different TC

number.

We believe the presence of a TC number on the blade may cause the customer to divert attention away from a determination of installation eligibility, and cause instead, a focus on determining whether a blade’s specific TC marking makes it eligible, or ineligible, for installation to a specific hub model. A propeller blade and hub combination is vibrationally approved for use on a specific engine and airplane combination to assure that the propeller is structurally acceptable as well as meeting the airplane performance and operational capabilities. Hartzell does not want to give the public the mistaken impression that blades and hubs with the same TC number make up a propeller that is acceptable for use on airplane installations where no approval exists. The TC number might imply to an end-user that he only needs to match-up a blade and a hub having the same TC number in order to gain approval for that propeller to be used on an airplane. This could distract the end-user from verifying the propeller blade and hub combination is approved for the specific airplane

installation.

There is a real-world example of this lack of verification as it relates to engine compatibility. FAA SAIB NE-08-19, titled “Propeller Installati ons on Experimental Aircraft”, warns the public to verify propeller-engine compatibility. The same compatibility verification is required for all aircraft installations.

We also request that your office reconsider the impact of an exemption that expires just two years away; on October 31, 2016. It is not clear why there is a need to re-examine the exemption every two years. We propose that the exemption either not have an expirationU.S. Department of Transportation November 26, 2014 Page 4

date, or at least have one that is substantially longer than two years. A longer timeframe

would

allow time to permit a future rule change to eliminate this exemption by permitting part marking that the administrator finds appropriate. For example, prior to the conversion of the Civil Air Regulations (CARs) to the CFRs in the early 1960’s part marking discretion was provided by CAR 1.5 Identification, which stated:

“Each product manufactured under the terms of a type or production certificate shall display permanently such data as may be required to show its identity. The data shall include such of the following items as the Administrator finds appropriate: (1) Manufacturer's name, (2) model designation, (3) manufacturer's serial number (if article is numbered serially), otherwise the date of manufacture, except that articles subject to deterioration as a result of aging (parachutes, parachute flares, etc.), shall bear the date of manufacture in addition to the serial number, if any, (4) type certificate number, (5) production certificate number, (6) capacity or rating.”

The cost to Hartzell to mark a blade in accordance with the exemption conditions and limitations prior to shipment is minimal. However, we believe that there will be delays and associated costs during overhaul or other maintenance caused by confusion when the blade and propeller TC numbers do not match. The public will need to be educated through service documents that blade and propeller TC numbers are not required to match and that the standard methods to verify approved propeller blade and hub combination need to be applied.

The exemption granted did give relief to the concern that some blades may be installed on so many propellers there may not be sufficient space on the bottom of the blade to stamp all valid TC numbers. The table below shows a count of the TC numbers that could potentially be added to a specific blade design series model. The largest being the “Y-shank” blade design series that is capable of being installed into 17 unique type-certificated propellers.

Blade Series No. TC's

A shan k 1 D,E 4

M shan k 3

P shan k 2

R shan k 1

T shan k 2

U shan k 1

V shan k 8

X shan k 10

Y shan k 17

Z shan k 4

§11.81 (d) The reasons why granting your request wo uld be in the public interest; that is, how it would benefit the public as a whole:

Amending the exemption would be in the public interest because it would: 1) Prevent public confusion 2) Prevent increased costs resulting from that confusionU.S. Department of Transportation November 26, 2014 Page 5 3) Prevent potential safety problems associated with distracting the end-user from verifying the propeller blade and hub combination is approved for the specific airplane installation.

The confusion, cost and safety concerns regarding blade TC markings are detailed in paragraph §11.81 (c).

§11.81 (e) The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek the exemption:

Marking the TC number on our blades provides no safety value and may reduce safety therefore excluding the TC number from the blade provides the same or higher level of safety. Blade markings that could distract the end-user from verifying the propeller blade and hub combination is approved for the specific airplane installation reduces safety. The confusion and safety concerns regarding blade TC markings are detailed in paragraph §11.81 (c).

§11.81 (f) A summary we can publish in the Federal Register, stating: (1) The rule from which you seek the exemption; and (2) A brief description of the nature of the exemption you seek;

Petitioner: Hartzell Propeller Inc.

Section of 14 CFR Affected: 14 CFR part: 45.13(a)(4)

Description of Relief Sought: The petitioner is requesting relief from having type certificate number markings on the blades of propellers.

§11.81 (g) Any additional information, views or arguments available to support your request;

and

None

§11.81 (h) If you want to exercise the privileges of your exemption outsid e the United States, the reason why you need to do so. Hartzell propellers are validated and are operated in many foreign countries. To be useful to foreign owners and operators, Hartzell requests that the FAA allow the use of the petitioned exemption outside of the United States.

Regards,

Richard L Edinger V.P. Certification and Flight Safety Hartzell Propeller, Inc.