GE Aviation

Amy Dow
Airworthiness and Certification, Senior Technical Leader
GE - Aviation
1000 Western Ave, Lynn, MA 01910
General Electric Company
US Department of Transportation T 781 594 5436
Docket Operations Amy.dow@ge.com

1200 New Jersey Avenue, SE

Craig Fabian
West Building Ground Floor Compliance and Regulatory, Senior Leader
2895 S.W. 145th Avenue GE - Aviation
Room W12-140 1 Neumann Way, Evendale, Ohio USA
Washington, DC 20590-0001 General Electric Company
T 513 377 7388
Craig.fabian@ge.com
May 7, 2021

Submitted electronically to: www.regulations.gov

RE: Scope Expansion to Exemption No. 16697

Dear Madam or Sir:

Pursuant to Title 14 Code of Federal Regulations (14 CFR) Part 11, General Electric Company (GE)
respectfully petitions the Federal Aviation Administration (FAA) for an exemption to enable new GE
T700 engine shipments and new spare parts for restricted category aircraft as described in this request.

The scope of this request differs from FAA exemption number 16697 that was originally issued on May
23, 2016. Specifically, this petition asks for an exemption covering the supply of new T700 engines and
spare parts1 for restricted category aircraft2 that were not declared surplus by the U.S. Armed Forces.

Summary and background

Under FAA exemption 16697, GE was able to address the need to supply replacement articles and
engines to the operating fleet of surplus military restricted category aircraft fitted with GE T700 series
engines. Although that fleet of aircraft are type certificated, the military T700 engines installed in those
aircraft are not, and the engines and their component parts are therefore ineligible for manufacture and
certification under the FAA production certificate held by GE.3 The existing exemption directly addressed
the unintended regulatory position of GE not being able to support the fleet of restricted category aircraft
despite GE originally manufacturing the engines included in the restricted category aircraft type
certificates.

1
The T700 series that GE needs to support include all 700 and 701 engine models.
2
FAA type certificated under Title 14 Code of Federal Regulations (14 CFR) § 21.25 but were not previously
operated/declared surplus by the US Military.
3
The scope of a production certificate is defined in a production limitation record listing the type certificate numbers
and models of products authorized for manufacture (14 CFR § 21.142). The T700 engine is not a type certificated
product.
General Electric Company
U.S. Department of Transportation
Docket Operations
May 7, 2021

In contrast, the restricted category aircraft at issue in this petition are not surplus military and were never
delivered or operated by the US Armed Forces. However, the subject aircraft are used in performing
firefighting, agricultural, and other service roles. As in FAA exemption 16697, granting this petition
furthers the public interest by ensuring the continued availability of new replacement parts and engines
for continued safe operation for all Restricted Category A/C performing those service missions equipped
with T700 engines. This grant of exemption would include new replacement engines and related new
component parts for aircraft manufactured by Sikorsky under the equivalent S-model commercial
identification.4
To facilitate FAA review, elements required by 14 CFR § 11.81 are repeated below in bold underline,
followed by our response in plain text.

Name, mailing address, and contact information

Amy Dow
GE Aviation
1000 Western Ave, Lynn, MA 01910
General Electric Company
T 781 594 5436
Amy.dow@ge.com

Specific sections of 14 CFR from which GE seeks an exemption

GE seeks continued relief from the regulatory requirements in 14 CFR §§ 21.6 and 21.9 to allow
manufacture of new T700 replacement parts and engines that will be installed on FAA type certificated
aircraft in the restricted category.

Extent of relief sought and reason for seeking relief

Relief is sought to ensure the availability of new replacement parts and engines for restricted category
aircraft that operate in substantial part to serve the public interest through firefighting, agricultural, and
other service roles. Specifically, those restricted category aircraft fitted with GE T700 engine models as
described in this petition but not limited to those aircraft declared surplus by the U.S. Military.
GE is unable to add T700 engine models to the scope of its FAA production certificate as the T700 is not
an FAA type certificated engine. Relief from 14 CFR §21.9, expanded to the civil equivalent aircraft
models, will enable GE to more fully support the operating fleet of restricted category aircraft with new
replacement parts manufactured to meet military requirements under its existing production quality
system. Similarly, continued relief from § 21.6 expanded to the civil equivalent aircraft will enable GE to
support the operating Restricted Category fleet with new engines manufactured to meet military
requirements under its existing production quality system as it does now for the surplused military
aircraft in the restricted category fleet.

Reasons why granting this request is in the public interest

4
See, for example, FAA type certificate data sheet (TCDS) H2NE, H3NE, H4NE and H5NE.

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To our knowledge, most if not all of the aircraft at issue fly missions under U.S. State and Federal
Government contracts. Operations under those contracts include lifesaving firefighting activities, policing
actions, and placement of power lines in remote locations, among other service roles. Granting this
request serves the public interest by ensuring the continued safe operation of all these aircraft in those
critical roles.

Reasons why granting the exemption extension would not adversely affect safety
Granting this exemption serves both public and safety interests. As previously stated, relief is sought to
enable the continued provisioning of new replacement parts and new engines manufactured to meet
military requirements under the GE production quality system used for original engine manufacture. This
exemption is needed to compliantly ensure the operational safety of the restricted category aircraft fleet
at issue.
GE is the original manufacturer of the subject engines, which have accumulated well over one hundred
(100) million operating hours worldwide. As the manufacturer, GE closely monitors in-service engines to
identify opportunities for improvement, and to implement improvements. Granting this exemption
expansion affords all operators continued access to the most modern standards and engine technology.

Good cause exists for not delaying action on this petition

As provided in 14 CFR § 11.87, GE respectfully presents that granting this petition will not set a precedent
as the relief requested is nearly identical to the exemption granted previously. GE believes that the ablitly
to directly support all restricted category operators with new engines and replacement parts required for
aircraft performing critical missions greatly benefits public interests. This petition is being filed in a timely
manner.

Appendix A
Additional Supporting information supplied in response to FAA questions surrounding examination of
GE’s Petition to Expand the Scope of Exemption No. 16697 are contained in the attached Appendix A.

Please contact me if you have any questions or require additional information.

Very Respectfully,

Amy Dow
GE Aviation, Airworthiness and Certification, Senior Technical Leader

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Appendix A
Additional Supporting information supplied in response to FAA questions
surrounding expanding the scope of GE’s Exemption No. 16697:
With the quantity of affected aircraft, as stated in your petition, what justification does GE have
for not applying for a Type Certificate/Production Certificate under title 14 CFR, part 21?
The T700 model engines have significant commonality with the FAA type certificated CT7 models.
However, for the restricted category aircraft, where the T700 engines are included in the FAA type
certificate for the complete aircraft (by individual aircraft/tail number) GE does not see the benefit
of Type Certifying previously produced and qualified military engine models solely for use in the
restricted category fleet. GE believes that significant unexpected complexity would be introduced to
this unique fleet. Firstly, despite the qualification and significant time in operation of the T700
engines in the military, GE's experience is still that such certification efforts would take several
years. An FAA exemption would still be needed to support the current operating fleet as the
certification activity is worked through the FAA engine certification office. Also, compliance to the
FAA airworthiness standards would likely drive differences into the T700 engine design from its
current military design/limitations (for operation on the same aircraft) and require a unique engine
identification as is typical between our military and commercial engines. This would not be
practical for the surplus military fleet. Lastly, despite the large current offering of CT7 type
certificated engine models (see FAA TCDS number E8NE) any consideration for utilizing an existing
engine configuration would drive additional unanticipated certification efforts at the aircraft level.

How was the manufacturing of these engines and components previously handled prior to the
issuance of the current exemption?
Prior to the initial exemption, there was no demand for parts or engines. We assume that what little
supply was required for line maintenance of the very limited fleet of aircraft was provided through
parts and engines surplused by the US Military or through Sikorsky. Many more surplus Military
Aircraft are now in operation and demand is expected to grow. We anticipate those additional
operators will require direct GE support for new parts and engines.

Please provide the FAA with the equivalent quality system, procedures and processes used
under the current exemption.
GE manufactures both military and commercial engines and component parts under one
production quality system. That production quality system is approved by the FAA (14 CFR §§
21.137 and 21.138) as part of the FAA production certificate held by GE (PC #108). That single
production quality system is used to manufacture and certify the T700 engines subject to the
initial, and any subsequent, FAA exemption.

Evidence of all GE Engine Models & Articles manufactured by GE for UH-60 Variant Aircraft,
and identify for which aircraft they were produced /installed, since the Exemption was
Granted (May 2016).
We understand this question to be asking about those engines and articles manufactured by GE
outside of the current exemption as a supplier to Sikorsky for their new helicopter production. This

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estimated number of engines is thirteen T700-701D engines sent to Sikorsky since 2016 in support
of their production certificate.

What specific rationale does GE have to add new engine variants to their petition? What
aircraft are these engines intended for installation?
At the time the initial exemption was granted, the operating fleet of restricted category type
certificated aircraft applications was more limited. As the scope of that fleet has grown, we
realized the exemption required broadening to extend support to additional aircraft applications.
Our addition of the T700-701A model was intended to cover all UH-60/S-70 variant aircraft engine
model configurations that power the T700 Restricted Category fleet. It is possible that a S-70A or C
model could have the original T700-GE-701A model engines installed, and GE thought it best to
include all allowable engine models to enable comprehensive support.

What specific rationale does GE have to broaden the scope to include aircraft not declared
surplus by the U.S. Armed Forces? What aircraft does GE envision the additional engines and
articles to be installed on?
GE feels it would be detrimental to the Restricted Category fleet and operators if we were not able
to provide unilateral support to any/all of the different variants of the UH-60/S-70/HH-60/EH-60
models that could be operating under a restricted category TC powered by GE engines. We
understand that Sikorsky is manufacturing new restricted category model aircraft with T700
powerplants. Although the additional restricted category type certificated aircraft at issue are
manufactured under the FAA production certificate held by Sikorsky, we realize that Sikorsky
expects GE to directly support that operating fleet with regard to the T700 engines. GE has already
entered into a near final agreement on a comprehensive support service program with one such
operator. As a result, GE is seeking a compliant path to provide new replacement parts and new
T700 engines for those aircraft.

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