Merck & Co., Inc. - Exemption/Rulemaking

See attached file(s). The General Aviation Manufacturers Association (GAMA) welcomes to the opportunity to review and provide comment in support of the petition for exemption filed by Merck & Co., Inc. seeking an alternative means of compliance for 14 CFR 91.211(b)(1)(ii) to permit operations above FL 410 without one pilot wearing an oxygen mask. Granting this exemption to Merck, & Co., Inc. to operate certain Gulfstream Aerospace models is supported by GAMA's membership which includes all manufacturers of business jets. Enabling a model-specific alternative means of compliance that is based on advances made in aircraft design, aircraft safety features, and the specified conditions and limitations – as discussed in the petition – will ensure that safety is maintained. Sincerely, Jens C. Hennig Vice President, Operations