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August 13, 2015 4412/C E RT/001 

U.S . Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

Subject: PETITION FOR EXEMPTION FROM REQUIREMENTS OF 14 CFR 

~45.13(A)(1) FOR THE GULFSTREAM G280 

In accordance with 14 CFR §11.81, Israel Aerospace Industries (IAI) 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. 

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 inentioning 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 
~~~1 ~ 1 

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, IAI 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. 

Finally, it is IAI and Gulfstream 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, IAI 

has verified that adoption of this requested exemption has no effect 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. 

IAI appreciates the FAA's consideration of this petition. Please contact me directly 

concerning this important matter using the contact information provided below. 

Regards, 

~'. 

Tali Nir 

Airworthiness & Certification 

Israel Aerospace Industries Ltd 

Ben Gurion International Airport 7010000, Israel 

e-mail: tmazor iai.co.il 

Telephone: +972-3-9359826 

Fax: +972-3-9356686 

CC: C. Gaber, GALP; D. Lawton, GALP; S. Karako, IAI; Y. Berkovitz, IAI; D. Alimi, IAI; 

I. Kalal, IAI; M. Kollet, IAI