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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

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### 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 bedefaced 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

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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,

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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