BEFORE THE

FEDERAL AVIA nON ADMINISTRA nON

WASHINGTON, DC

)

)

) Docket No. FAA-2000-8533

)

for an exemption from Sections 61.77(a) and )

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

~~~~ )

---------------

Petition of

ISRAEL AEROSPACE INDUSTRIES LTD

PETITION TO RENEW AND EXTEND EXEMPTION

Communications with regard to this document should be addressed to:

Rory Kelleher

Sidley Austin LLP

787 Seventh Avenue

New York, NY 10019

212-839-7385 (direct phone)

212-839-5599 (direct fax)

rkelleher@sidley.com

Counsel for Israel Aerospace Industries Ltd

May 17,2011

NYl 7676833v.l
BEFORE THE

FEDERAL AVIA TION ADMINISTRATION

WASHINGTON, DC

May 17,2011

)

)

) Docket No. FAA-2000-8533

)

for an exemption from Sections 61.77(a) and )

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

~cl~m )

---------------

Petition of

ISRAEL AEROSPACE INDUSTRIES LTD

PETITION TO RENEW AND EXTEND EXEMPTION

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

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

hereby requests renewal and extension of FAA Exemption No. 7406F (issued March 19,2009) 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:

(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 IAJ's Part 145 repair stations.

NY\ 7676833v.\
Israel Aerospace Industries Ltd

Petition to Renew and Extend Exemption

Page 2

The existing exemption was valid until March 31, 2011. IAI is requesting that the

exemption be renewed and 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 7406F. The same justifications for the issuance of the exemption continue to

be applicable. IAI hereby incorporates by reference all relevant information 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 renewal and 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. 7406F 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. This petition seeks to renew and extend the exemption for

reasons identical to those that supported the original grant

and subsequent extensions of the exemption and therefore

will set no new precedent;

2. The relief requested by this petition is identical to the

exemption previously granted by the FAA;

NYI 7676833v.l 2
Israel Aerospace Industries Ltd

Petition to Renew and Extend Exemption

Page 3

3. Grant of the exemption would maintain at least and

equivalent level of safety;

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

IAI because IAI has immediate need for operation of

aircraft pursuant to the exemption; and

5. The public interest would be served by promptly renewing

and extending the exemption, as requested.

NYI 7676833v.1 3
Israel Aerospace Industries Ltd

Petition to Renew and Extend Exemption

Page 4

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

and extend Exemption No. 7406F, as described herein, for a two year period from the prior

March 31, 2011 expiration date.

Res~t1lL

Rory Kelleher

Sidley Austin LLP

787 Seventh Avenue

New York, NY 10019

212-839-7385 (direct phone)

212-839-5599 (direct fax)

rkelleher@sidley.com

Counsel for Israel Aerospace Industries Ltd

cc: John Byerly, U.S. Department of State

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

NYl 7676833v.l 4