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- 6750 May 1 4 , 201 5 GALP Ref: FAA/15206 / CG

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

FOR THE GULFSTREAM G150

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 G150 model.

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

14 CFR § 2 1. 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

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1 4 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 firep roof 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 li kely 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 leg ible 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 nam e. (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 70100 ¤ IS R A E L

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- 6750 Gulfstream Aerospace LP (GALP)

, the type certificate holder of the Gulfstream G150 aircraft, has licensed Israel Aerospace Industries (IAI) to manufacture the Gulfstream
G150 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 arra ngement, 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 sev eral decades t hat t he 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 G150 , for which major aircraft components and

sub

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

Due to certain long standing geopolitical issues

, t he appearance of “ IAI LTD ” as the builder on the aircraft identification plate can have a significan t 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 o n 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 e stablished between Gulfstream Aerospace Corporation (GAC), with headquarters in Savannah Georgia, and IAI i s 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 G ulfstream in the marketing, sales and product support role s

. So a llowing 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. W e do n ot see this issue as representing an issue of any significant interest to the public however i t does represent a significant benefit to
Gulfstream and IAI in terms of market access and sales.

A ccordingly

, GALP respectfully requests a waiver on the public notification p eriod as such a delay in granting the exemption will negatively affect ongoing sales n egotiations and as stated above, this exemption does not represent an issue of interest to the public

. The

prop osed change clearly has no impact whatsoever on aircraft safety or operation s and
therefore w aiver of public notification period is appropriate.3 of 3

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 70100 ¤ IS R A E L

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- 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 market s and to achieve this goal it is necessary that operati on 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 verif ied that adoption of this reque sted 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 Conven tion on International Civil Aviation

. In fact, ICAO does not re quire the aircraft identification plate to list the builder of the aircraft

.

G ulfstream appreciates the FAA’s consideration of this petition . Please contact me directly concerning this impor tant 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

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