Hogan Lovells US LLP Columbia Square 555 Thirteenth Street, NW Washington, DC 20004 T +1 202 637 6934 F +1 202 637 5910 December 17, 2018 U.S. Department of Transportation Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590 Subject: Cirrus Design Corporation d/b/a Cirrus Aircraft Petition for Exemption to 14 CFR §§ 47.65 and 47.69(b) Dear Sir or Madam: Pursuant to 14 C.F.R. Part 11, Cirrus Design Corporation d/b/a Cirrus Aircraft (“Cirrus”), hereby applies for a Grant of Exemption from 14 C.F.R. §§ 47.65 and 47.69(b). If granted, the requested relief would allow Cirrus to obtain a Dealer’s Aircraft Registration Certificate, AC Form 8050-6, without meeting the United States citizenship requirements, and permit Cirrus to conduct limited flights outside of the United States under its Dealer Certificate for demonstration, sales and marketing purposes. The requested exemptions in this petition are not new or novel to the FAA. The FAA has issued grants of exemption from 14 C.F.R. §§ 47.65 and 47.69(b) in circumstances similar in all material respects to those presented in this petition, and therefore the requested relief would not set a precedent. Moreover, any delay in acting on this petition would be detrimental to Cirrus. Accordingly, Cirrus submits that good cause exists for not publishing a summary of the petition in the Federal Register. If you have any questions as you review these documents please do not hesitate to contact me at 202-637-8644 or
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