+---+----+------------------+------------------------------------------+
|   | ** | **FAA proposed   | **ICCAIA comment:**                      |
|   | Pa | text**           |                                          |
|   | ge |                  |                                          |
|   | &  |                  |                                          |
|   | Pa |                  |                                          |
|   | ra |                  |                                          |
|   | ** |                  |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | Operations       | The proposed regulation is limiting      |
|   | \. |                  | passenger seating arrangement to not     |
|   | 3  | §2. General: The | exceed 60 only under operations, but not |
|   | 87 | passenger        | to under Equipment and Design. Please    |
|   | 43 | seating          | clarify why the limitation is not        |
|   |    | arrangement may  | specified under "Equipment and Design".  |
|   | Op | not exceed 60.   |                                          |
|   | er |                  |                                          |
|   | at | Equipment and    |                                          |
|   | io | Design           |                                          |
|   | ns |                  |                                          |
|   |    | §3. General:     |                                          |
|   | §  | Unless otherwise |                                          |
|   | 2. | noted,           |                                          |
|   | G  | compliance is    |                                          |
|   | en | required with    |                                          |
|   | er | the applicable   |                                          |
|   | al | certification    |                                          |
|   |    | basis for the    |                                          |
|   | \  | airplane.        |                                          |
|   | (a |                  |                                          |
|   | \) |                  |                                          |
|   |    |                  |                                          |
|   | E  |                  |                                          |
|   | qu |                  |                                          |
|   | ip |                  |                                          |
|   | me |                  |                                          |
|   | nt |                  |                                          |
|   | a  |                  |                                          |
|   | nd |                  |                                          |
|   | De |                  |                                          |
|   | si |                  |                                          |
|   | gn |                  |                                          |
|   |    |                  |                                          |
|   | §  |                  |                                          |
|   | 3. |                  |                                          |
|   | G  |                  |                                          |
|   | en |                  |                                          |
|   | er |                  |                                          |
|   | al |                  |                                          |
+---+----+------------------+------------------------------------------+
| 1 |    |                  | It is recommended that maximum passenger |
| - |    |                  | seating for private use airplanes be     |
| 1 |    |                  | determined by evacuation analysis for    |
|   |    |                  | each individual interior. This analysis  |
|   |    |                  | would allow taking into consideration    |
|   |    |                  | the exit door configuration for the      |
|   |    |                  | applicable airplane model. This rule     |
|   |    |                  | does not allow for twin-aisle aircraft   |
|   |    |                  | that are operated as private aircraft    |
|   |    |                  | with greater than 60 passengers.         |
+---+----+------------------+------------------------------------------+
| 2 | p  | Airplanes        | The proposal that airplanes with a       |
|   | .3 | outfitted with   | passenger capacity of 10 or more and     |
|   | 87 | interior doors   | that are outfitted with interior doors   |
|   | 43 | under paragraph  | be staffed by at least one flight        |
|   |    | 10 of this SFAR  | attendant is not acceptable.             |
|   | Op | must be staffed  |                                          |
|   | er | with at least    | As discussed in the NPRM, FAR 91.533     |
|   | at | one flight       | specifies the number of flight           |
|   | io | attendant who    | attendants required for airplanes based  |
|   | ns | meets the        | on the number of passengers on board the |
|   | §2 | requirements of  | airplane. The proposed rule changes the  |
|   | .G | 14 CFR 91.533(b) | requirement for flight attendants in two |
|   | en | of this chapter  | ways for all airplanes that are equipped |
|   | er | if the airplane  | with interior doors per paragraph 10 of  |
|   | al | has a capacity   | the proposed SFAR:                       |
|   |    | of 10--50        |                                          |
|   | \  | passengers,      | (1) The flight attendant requirements    |
|   | (b | inclusive, and   |     are to be based on capacity of the   |
|   | \) | at least two     |     airplane as opposed to the number of |
|   |    | flight           |     passengers on board the airplane;    |
|   |    | attendants who   |     and                                  |
|   |    | meet the         |                                          |
|   |    | requirements of  | (2) A flight attendant will be required  |
|   |    | 14 CFR 91.533(b) |     if the capacity of the airplane is   |
|   |    | of this chapter  |     greater than 9 as opposed to         |
|   |    | if the capacity  |     requiring a flight attendant if      |
|   |    | exceeds 50       |     there are more than 19 passengers on |
|   |    | passengers.      |     board                                |
|   |    |                  |                                          |
|   |    |                  | The proposed rule is considered to be    |
|   |    |                  | unacceptable for the following reasons:  |
|   |    |                  |                                          |
|   |    |                  | \(1\) Basing the flight attendant        |
|   |    |                  | requirements on capacity as opposed to   |
|   |    |                  | the number of passengers on board is not |
|   |    |                  | consistent with other sections of CFR    |
|   |    |                  | Title 14 and could require, depending on |
|   |    |                  | the capacity of the airplane, that the   |
|   |    |                  | airplane be staffed with one or two      |
|   |    |                  | flight attendants for flights with fewer |
|   |    |                  | than 10 passengers on board, including   |
|   |    |                  | positioning & maintenance flights        |
|   |    |                  |                                          |
|   |    |                  | \(2\) Applying the requirement for       |
|   |    |                  | flight attendants to all aircraft        |
|   |    |                  | equipped with interior doors regardless  |
|   |    |                  | of aircraft size or configuration        |
|   |    |                  | disregards important differences between |
|   |    |                  | larger aircraft that were originally     |
|   |    |                  | developed for use as commercial          |
|   |    |                  | airliners and smaller business jets:     |
|   |    |                  |                                          |
|   |    |                  | > \(i\) The layout of smaller business   |
|   |    |                  | > jets make installation of a flight     |
|   |    |                  | > attendant station extremely            |
|   |    |                  | > challenging, particularly for those    |
|   |    |                  | > airplanes that have FAR 25.562         |
|   |    |                  | > included in the certification basis,   |
|   |    |                  | > given the need for proximity to a      |
|   |    |                  | > floor level exit and for the seat to   |
|   |    |                  | > be facing the cabin                    |
|   |    |                  | >                                        |
|   |    |                  | > \(ii\) The layout of smaller business  |
|   |    |                  | > jets typically allow the flight crew   |
|   |    |                  | > to visually check the condition of     |
|   |    |                  | > interior doors from the flight deck    |
|   |    |                  | > given the fact that such airplanes are |
|   |    |                  | > not equipped with flight deck doors,   |
|   |    |                  | > the cabin is in close proximity to the |
|   |    |                  | > flight deck and in most cases the door |
|   |    |                  | > must be installed transverse to the    |
|   |    |                  | > longitudinal axis of the airplane      |
|   |    |                  | > given the limited width of the cabin   |
|   |    |                  | >                                        |
|   |    |                  | > \(iii\) Although the intent of the     |
|   |    |                  | > proposed rule, as stated in the NPRM,  |
|   |    |                  | > is to address oversight of the cabin   |
|   |    |                  | > where the aircraft type is one that is |
|   |    |                  | > "typically used in air carrier         |
|   |    |                  | > operations", the proposed rule does    |
|   |    |                  | > not provide relief for smaller         |
|   |    |                  | > business jets outfitted with interior  |
|   |    |                  | > doors                                  |
|   |    |                  |                                          |
|   |    |                  | \(3\) It is put forward that the ability |
|   |    |                  | of flight crew to oversee the cabin of a |
|   |    |                  | large private use aircraft is affected   |
|   |    |                  | by the installation of bulkheads,        |
|   |    |                  | partitions and offset aisles &           |
|   |    |                  | passageways along the length of the      |
|   |    |                  | cabin as opposed to interior doors and   |
|   |    |                  | that the proposed rule should reflect    |
|   |    |                  | such (e.g. the ability of flight crew to |
|   |    |                  | oversee the cabin would be affected as   |
|   |    |                  | much by curtains as for interior doors). |
+---+----+------------------+------------------------------------------+
| 2 |    |                  | Without a demonstrated need or defined   |
| - |    |                  | benefit substantiated by facts gathered  |
| 1 |    |                  | as a result of research, the current     |
|   |    |                  | operational requirement set forth in FAR |
|   |    |                  | 91.533 continues to provide an           |
|   |    |                  | acceptable level of safety. One flight   |
|   |    |                  | attendant required for capacity of 20-50 |
|   |    |                  | passengers in lieu of 10-50. Therefore,  |
|   |    |                  | the following change is proposed to      |
|   |    |                  | §2(b): "One flight attendant required    |
|   |    |                  | for capacity of 20-50 passengers in lieu |
|   |    |                  | of 10-50".                               |
+---+----+------------------+------------------------------------------+
| 3 | p  | Prior to each    | The proposed text is acceptable provided |
|   | .3 | flight, the      | that the intent is for the briefing is   |
|   | 87 | operator must    | restricted to those features of the      |
|   | 43 | ensure that each | airplane for which particular emphasis   |
|   |    | passenger is     | is required to ensure an acceptable      |
|   | Op | briefed and      | level of safety (ideally the SFAR would  |
|   | er | instructed       | identify those features that are         |
|   | at | appropriately on | required to be addressed by the          |
|   | io | functions to be  | passenger briefing).                     |
|   | ns | performed by the |                                          |
|   | §2 | passenger and    | For instance, while passengers should be |
|   | .G | the applicable   | briefed on the frangible features of     |
|   | en | features of the  | interior doors and the need for such     |
|   | er | airplane.        | doors to be secured open during taxi,    |
|   | al |                  | takeoff & landing, it would not be       |
|   |    |                  | necessary to include a mention of the    |
|   | \  |                  | following features even though their     |
|   | (c |                  | installation is addressed by the         |
|   | \) |                  | proposed SFAR:                           |
|   |    |                  |                                          |
|   |    |                  | \(1\) Firm handholds                     |
|   |    |                  |                                          |
|   |    |                  | \(2\) Side facing seats/divans           |
|   |    |                  |                                          |
|   |    |                  | \(3\) Flight attendant direct view       |
|   |    |                  |                                          |
|   |    |                  | \(4\) Passenger information signs and    |
|   |    |                  | placards                                 |
|   |    |                  |                                          |
|   |    |                  | \(5\) Emergency signage and lighting     |
|   |    |                  |                                          |
|   |    |                  | \(6\) Interior materials heat release &  |
|   |    |                  | smoke density                            |
|   |    |                  |                                          |
|   |    |                  | \(7\) Fire detection                     |
|   |    |                  |                                          |
|   |    |                  | \(8\) Cook tops                          |
|   |    |                  |                                          |
|   |    |                  | The concern is that the phrase           |
|   |    |                  | "applicable features of the airplane"    |
|   |    |                  | could be taken to mean all features      |
|   |    |                  | addressed by the SFAR that apply to an   |
|   |    |                  | airplane as opposed to only those        |
|   |    |                  | features for which there is a function   |
|   |    |                  | to be performed by the passenger.        |
+---+----+------------------+------------------------------------------+
| 4 | p  | The airplane may | The proposal that airplanes be limited   |
|   | .3 | not be offered   | to private use operations only is not    |
|   | 87 | for common       | acceptable.                              |
|   | 43 | carriage or      |                                          |
|   |    | operated for     | The limitation of airplanes to private   |
|   | Op | hire. The        | use operations has a significant impact  |
|   | er | Airplane Flight  | to the manufacturers, owners & operators |
|   | at | Manual required  | of smaller business jets in particular   |
|   | io | by § 25.1581     | since such airplanes are frequently used |
|   | ns | must be revised  | for on-demand commercial operations.     |
|   | §2 | to prohibit any  |                                          |
|   | .G | operations       | NOTE                                     |
|   | en | involving the    |                                          |
|   | er | carriage of      | Limiting aircraft to private use         |
|   | al | persons or       | operations only will have significant    |
|   |    | property for     | financial implications for operators of  |
|   | \  | compensation or  | smaller business jets for the following  |
|   | (d | hire.            | reasons:                                 |
|   | \) |                  |                                          |
|   |    |                  | • It would not be possible to offset     |
|   |    |                  | ownership costs by offering the airplane |
|   |    |                  | for hire when it is not otherwise        |
|   |    |                  | required                                 |
|   |    |                  |                                          |
|   |    |                  | • Depending upon the state where the     |
|   |    |                  | airplane is based, there could be tax    |
|   |    |                  | implications for the owner or operator   |
|   |    |                  |                                          |
|   |    |                  | • The residual value will be reduced due |
|   |    |                  | to the fact that it would have           |
|   |    |                  | limitations that are not applicable to   |
|   |    |                  | other types that do not include the SFAR |
|   |    |                  | in the certification basis               |
|   |    |                  |                                          |
|   |    |                  | The same is likely not true for          |
|   |    |                  | commercial airliners for which charter   |
|   |    |                  | operations would be cost prohibitive and |
|   |    |                  | there are security & airfield            |
|   |    |                  | performance issues that would make       |
|   |    |                  | commercial operations less attractive.   |
|   |    |                  | It is also noteworthy that the level of  |
|   |    |                  | customization possible for smaller       |
|   |    |                  | business jets is not comparable to that  |
|   |    |                  | of commercial airliners given            |
|   |    |                  | constraints such as aircraft size and    |
|   |    |                  | weight & balance limitations.            |
|   |    |                  |                                          |
|   |    |                  | Furthermore, many of the issues          |
|   |    |                  | addressed by the proposed SFAR are       |
|   |    |                  | subject to design requirements that      |
|   |    |                  | provide an acceptable, if not            |
|   |    |                  | equivalent, level of safety. If there    |
|   |    |                  | are specific aspects of an interior      |
|   |    |                  | configuration that are not acceptable    |
|   |    |                  | for commercial operations of any kind,   |
|   |    |                  | including on-demand operations, then the |
|   |    |                  | private use only limitation should be    |
|   |    |                  | associated with those provisions of the  |
|   |    |                  | proposed SFAR only instead of being      |
|   |    |                  | applicable to any aircraft for which     |
|   |    |                  | perhaps only one design feature is       |
|   |    |                  | certified in accordance with the         |
|   |    |                  | provisions of the proposed SFAR.         |
|   |    |                  | Consideration should also be given to    |
|   |    |                  | permitting on-demand operations since    |
|   |    |                  | the expectations & needs of clients are  |
|   |    |                  | comparable to those of the owners of     |
|   |    |                  | private use aircraft, particularly       |
|   |    |                  | aircraft that are operated by a          |
|   |    |                  | corporation's flight department under    |
|   |    |                  | FAR Part 91.                             |
|   |    |                  |                                          |
|   |    |                  | Given the costs associated with          |
|   |    |                  | operating large transport category       |
|   |    |                  | aircraft, it is clear that on-demand air |
|   |    |                  | carriers cannot be competitive with      |
|   |    |                  | scheduled airlines on pricing and that   |
|   |    |                  | they must differentiate themselves with  |
|   |    |                  | superior service and flexibility.        |
|   |    |                  | Therefore, it is apparent that charter   |
|   |    |                  | operations conducted under FAR Part 135  |
|   |    |                  | will continue as a relatively small      |
|   |    |                  | segment of the air transportation system |
|   |    |                  | and that the "flying public" would not   |
|   |    |                  | be endangered by allowing, for example,  |
|   |    |                  | aircraft with interior doors to be       |
|   |    |                  | operated by air carriers for on-demand   |
|   |    |                  | operations.                              |
|   |    |                  |                                          |
|   |    |                  | NOTE                                     |
|   |    |                  |                                          |
|   |    |                  | In the past, exemptions from FAR         |
|   |    |                  | 25.813(e) have been granted that limit   |
|   |    |                  | affected airplanes to private use only   |
|   |    |                  | operations. Notwithstanding the          |
|   |    |                  | precedent set by these exemptions, there |
|   |    |                  | are some aircraft that do not include    |
|   |    |                  | FAR 25.813(e) in their certification     |
|   |    |                  | basis. Examples of these aircraft are    |
|   |    |                  | being operated by air carriers under FAR |
|   |    |                  | Part 135 without any adverse effect on   |
|   |    |                  | the safety of the "flying public".       |
+---+----+------------------+------------------------------------------+
| 4 |    |                  | Part 91 should be amended to include the |
| - |    |                  | prohibition. The AFM is not the          |
| 1 |    |                  | appropriate document to specify          |
|   |    |                  | operational limitations.                 |
+---+----+------------------+------------------------------------------+
| 5 | p  | A placard        | The proposal that a placard be installed |
|   | .3 | stating that     | in the cockpit that states the           |
|   | 87 | ''Operations     | limitation associated with private use   |
|   | 43 | involving the    | operations is not acceptable. The        |
|   |    | carriage of      | content of such a placard is not         |
|   | Op | persons or       | directly related to the safe operation   |
|   | er | property for     | of the airplane and the information must |
|   | at | compensation or  | already be provided to the flight crew   |
|   | io | hire are         | in an AFM supplement in accordance with  |
|   | ns | prohibited,''    | subparagraph 2(d) of the proposed rule.  |
|   | §2 | must be located  | It is submitted that the installation of |
|   | .G | in conspicuous   | placards not directly related to the     |
|   | en | view of the      | safe operation of the airplane reduces   |
|   | er | pilot-in         | the effectiveness of those that are      |
|   | al | command. The     | required for the following reasons:      |
|   |    | operators may    |                                          |
|   | \  | receive          | \(1\) As more placards are added the     |
|   | (e | remuneration to  | effort associated with locating and      |
|   | \) | the extent       | reading the information on a specific    |
|   |    | consistent with  | placard may increase                     |
|   |    | parts 125 and    |                                          |
|   |    | 91, subpart F of | \(2\) The importance given to individual |
|   |    | this chapter.    | placards is apt to decrease as more      |
|   |    |                  | placards are added (i.e. each placard    |
|   |    |                  | becomes one of many as opposed to an     |
|   |    |                  | exception in an otherwise sterile        |
|   |    |                  | cockpit)                                 |
|   |    |                  |                                          |
|   |    |                  | \(3\) There are innumerable placards     |
|   |    |                  | that can be added to duplicate           |
|   |    |                  | limitations or other "vital" information |
|   |    |                  | contained in the AFM - it is difficult   |
|   |    |                  | to rate the importance of each but it is |
|   |    |                  | likely that a limitation on the kinds of |
|   |    |                  | operations permitted would rank          |
|   |    |                  | relatively low compared, for example, to |
|   |    |                  | the number of passengers for which the   |
|   |    |                  | airplane is approved                     |
|   |    |                  |                                          |
|   |    |                  | NOTE                                     |
|   |    |                  |                                          |
|   |    |                  | Although not a significant issue for the |
|   |    |                  | business aviation community, it is not   |
|   |    |                  | clear why operations involving the       |
|   |    |                  | carriage of property for compensation or |
|   |    |                  | hire must be prohibited given the fact   |
|   |    |                  | that the proposed SFAR primarily         |
|   |    |                  | addresses issues that affect occupant    |
|   |    |                  | safety as opposed to aircraft structure  |
|   |    |                  | or systems.                              |
+---+----+------------------+------------------------------------------+
| 6 | p  | For seating      | §2(f) should state for ***"passenger     |
|   | .3 | arrangements of  | configurations of 45 and greater***" in  |
|   | 87 | 45 to 60         | order to accommodate greater passenger   |
|   | 43 | passengers,      | counts on privately owned twin aisle     |
|   |    | analysis must be | aircraft. Boeing already recommends this |
|   | Op | submitted that   | be done for passenger configurations of  |
|   | er | demonstrates     | 45 and greater.                          |
|   | at | that the         |                                          |
|   | io | airplane can be  |                                          |
|   | ns | evacuated in     |                                          |
|   | §2 | less than 90     |                                          |
|   | .G | seconds under    |                                          |
|   | en | the conditions   |                                          |
|   | er | specified in     |                                          |
|   | al | §25.803 and      |                                          |
|   |    | Appendix J to    |                                          |
|   | \  | part 25.         |                                          |
|   | (f |                  |                                          |
|   | \) |                  |                                          |
+---+----+------------------+------------------------------------------+
| 7 | p  | Firm Handhold    | The proposed rule does not consider the  |
|   | .3 |                  | following factors:                       |
|   | 87 | In lieu of the   |                                          |
|   | 43 | requirements of  | \(1\) Seats installed in business jets   |
|   |    | § 25.785(j),     | typically feature backrests that recline |
|   | E  | there must be a  | fully - since the backrest cannot be     |
|   | qu | means provided   | used as a firm handhold when it is       |
|   | ip | to enable        | reclined, a separate means would have to |
|   | me | persons to       | be provided for persons to steady        |
|   | nt | steady           | themselves wherever seats with this      |
|   | a  | themselves in    | feature border an aisle                  |
|   | nd | moderately rough |                                          |
|   | De | air while        | \(2\) The meaning of "bordered by seats" |
|   | si | occupying aisles | could be construed to mean any path      |
|   | gn | that are along   | between any two seats regardless of      |
|   |    | the cabin        | whether or not they are arranged in      |
|   | §. | sidewall or      | rows - for some cabin configurations it  |
|   | 4. | bordered by      | may not be possible to provide a means   |
|   | Oc | seats (seat      | for persons to steady themselves for all |
|   | cu | backs providing  | such locations                           |
|   | pa | a 25-pound       |                                          |
|   | nt | minimum          | \(3\) The proposed requirements do not   |
|   | Pr | breakaway force  | address the potential for injury to      |
|   | ot | are an           | occupants moving about the cabin away    |
|   | ec | acceptable means | from aisles that are along the cabin     |
|   | ti | of compliance)   | sidewall or bordered by seats - the      |
|   | on |                  | possibility of injury could be reduced   |
|   |    |                  | by requiring:                            |
|   | \  |                  |                                          |
|   | (a |                  | > \(i\) That interior components which   |
|   | \) |                  | > persons moving about the cabin may use |
|   |    |                  | > to steady themselves in lieu of a seat |
|   |    |                  | > back or handrail meet a minimum        |
|   |    |                  | > standard similar to the abuse loads    |
|   |    |                  | > typically applied to interior          |
|   |    |                  | > furnishings such as tables or the      |
|   |    |                  | > 25-pound minimum breakaway force       |
|   |    |                  | > applicable to seat backs               |
|   |    |                  | >                                        |
|   |    |                  | > \(ii\) That compliance findings        |
|   |    |                  | > against the requirements of FAR        |
|   |    |                  | > 25.785(k) take into consideration the  |
|   |    |                  | > lack of a means for persons to steady  |
|   |    |                  | > themselves in moderately rough air     |
+---+----+------------------+------------------------------------------+
| 7 |    |                  | > The proposed rule does not address the |
| - |    |                  | > area of concern, in regard to the firm |
| 1 |    |                  | > handhold. In general, cabin sidewall   |
|   |    |                  | > or cabin bordered by seats are not the |
|   |    |                  | > areas of concern, because the sidewall |
|   |    |                  | > and the seat provide handgrips that    |
|   |    |                  | > the passenger can grab to steady       |
|   |    |                  | > themselves. The proposed rule should   |
|   |    |                  | > more specifically address the open     |
|   |    |                  | > areas, which are typical of the        |
|   |    |                  | > private configurations -- and address  |
|   |    |                  | > the cases that are not anymore covered |
|   |    |                  | > by the guidance specified in the       |
|   |    |                  | > AC25-17 (above 65in).                  |
+---+----+------------------+------------------------------------------+
| 8 | p  | Injury criteria  | In the context of the comments for 2(d)  |
|   | .3 | for multiple     | above, it is considered essential that   |
|   | 87 | occupancy        | airplanes outfitted with side facing     |
|   | 43 | side-facing      | seats not be limited to private use      |
|   |    | seats            | operations only - this position is based |
|   | E  |                  | on the following:                        |
|   | qu | The following    |                                          |
|   | ip | requirements are | \(1\) The injury criteria and test       |
|   | me | only applicable  | requirements proposed in the NPRM        |
|   | nt | to airplanes     | provide for a level of safety that far   |
|   | a  | that have §      | exceeds that of side facing seats        |
|   | nd |                  | installed on airplanes that do not       |
|   | De | 25.562 in their  | include FAR 25.562 in their              |
|   | si | certification    | certification basis                      |
|   | gn | basis.           |                                          |
|   |    |                  | \(2\) Exemptions that have been          |
|   | §. |                  | previously granted do not prohibit       |
|   | 4. |                  | commercial operation of aircraft with    |
|   | Oc |                  | side facing seats installed If           |
|   | cu |                  | necessary, it would be acceptable for    |
|   | pa |                  | the installation of side facing seats to |
|   | nt |                  | be approved for airplanes involved in    |
|   | Pr |                  | private use operations or on-demand      |
|   | ot |                  | operations only so that there is no      |
|   | ec |                  | possibility of side facing seats being   |
|   | ti |                  | installed on airplanes that are intended |
|   | on |                  | for operation by FAR Part 121 airlines.  |
|   |    |                  |                                          |
|   | \  |                  |                                          |
|   | (b |                  |                                          |
|   | \) |                  |                                          |
+---+----+------------------+------------------------------------------+
| 8 | p  |                  | Use the recommendation set forth by      |
| - | .3 |                  | GAMA. The FAA does not provide any       |
| 1 | 87 |                  | justification for its positions that     |
|   | 43 |                  | "side-facing seats are considered a      |
|   |    |                  | novel design" and "adequate and          |
|   | E  |                  | appropriate safety standards" do not     |
|   | qu |                  | exist. It seems that the FAA is          |
|   | ip |                  | attempting to re-insert passenger injury |
|   | me |                  | criteria where there were none           |
|   | nt |                  | previously. It is also noted that        |
|   | a  |                  | without this guidance, side facing seat  |
|   | nd |                  | installations certified to Amendment     |
|   | De |                  | 25-64 will still be meeting upgraded     |
|   | si |                  | standards that increase airplane         |
|   | gn |                  | occupant protection during emergency     |
|   |    |                  | landing conditions. The body-to-body     |
|   | §. |                  | contact requirement is overly            |
|   | 4. |                  | constrictive and not substantiated by a  |
|   | Oc |                  | demonstrated need. It is not in keeping  |
|   | cu |                  | with the procedures for developing       |
|   | pa |                  | guidance material to impose a            |
|   | nt |                  | requirement without demonstrating the    |
|   | Pr |                  | need and the benefit as substantiated by |
|   | ot |                  | facts gathered as a result of research.  |
|   | ec |                  |                                          |
|   | ti |                  | NOTE: The FAA can justify the necessity  |
|   | on |                  | of special conditions/exemptions, in     |
|   |    |                  | lieu of a regulatory change, only if     |
|   | \  |                  | side-facing divans were indeed novel at  |
|   | (b |                  | Amendment 25-64. The 707 history shows   |
|   | \) |                  | that, side-facing divans were not novel  |
|   | a  |                  | at Amendment 25-64. .                    |
|   | nd |                  |                                          |
|   | (  |                  |                                          |
|   | c) |                  |                                          |
+---+----+------------------+------------------------------------------+
| 9 | p  | Body-to-Body     | The proposed text should include the     |
|   | .3 | Contact          | following clarification:                 |
|   | 87 |                  |                                          |
|   | 43 | Contact between  | *"Any contact between adjacent ATDs is   |
|   |    | the head,        | acceptable during rebound".*             |
|   | E  | pelvis, or       |                                          |
|   | qu | shoulder area of |                                          |
|   | ip | one seated       |                                          |
|   | me | anthropomorphic  |                                          |
|   | nt | test dummy (ATD) |                                          |
|   | a  | on the adjacent  |                                          |
|   | nd | seated ATD's is  |                                          |
|   | De | not acceptable   |                                          |
|   | si | during the test  |                                          |
|   | gn | conducted in     |                                          |
|   |    | accordance with  |                                          |
|   | §. | § 25.562(b)(1)   |                                          |
|   | 4. | and (b)(2).      |                                          |
|   | Oc | Incidental       |                                          |
|   | cu | contact of the   |                                          |
|   | pa | legs, feet, arms |                                          |
|   | nt | and hands that   |                                          |
|   | Pr | will not result  |                                          |
|   | ot | in               |                                          |
|   | ec | incapacitation   |                                          |
|   | ti | of the occupants |                                          |
|   | on | is acceptable.   |                                          |
|   |    |                  |                                          |
|   | (b |                  |                                          |
|   | )( |                  |                                          |
|   | 2) |                  |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | Body-to          | The proposal that contact surfaces be    |
| 0 | .3 | -Wall/Furnishing | covered with at least 2 inches of energy |
|   | 87 | Contact          | absorbing protective foam is not         |
|   | 43 |                  | satisfactory for the following reasons:  |
|   |    | If the sofa is   |                                          |
|   | E  | installed aft of | \(1\) Since the performance criteria for |
|   | qu | a structure,     | the energy absorbing protective foam is  |
|   | ip | such as an       | not specified, it may be possible to     |
|   | me | interior wall or | achieve a satisfactory result (i.e.      |
|   | nt | furnishing that  | equivalent level of protection for the   |
|   | a  | may be contacted | occupant) with less than 2 inches of     |
|   | nd | by the pelvis,   | foam, depending upon the product used    |
|   | De | upper arm,       |                                          |
|   | si | chest, or head   | \(2\) The location or orientation of the |
|   | gn | of an occupant   | contact surface relative to the side     |
|   |    | seated next to   | facing seat may be such that any         |
|   | §. | the structure,   | predicted or actual contact with the     |
|   | 4. | then a           | surface is not injurious to the occupant |
|   | Oc | conservative     |                                          |
|   | cu | representation   | It is suggested that the requirement to  |
|   | pa | of the structure | pad the contact surface of adjacent      |
|   | nt | and its          | structure be eliminated altogether from  |
|   | Pr | stiffness must   | the requirement or that the addition of  |
|   | ot | be included in   | 2 inches of energy absorbing protective  |
|   | ec | the tests. The   | foam be accepted as a means of           |
|   | ti | contact surface  | compliance in lieu of some of the injury |
|   | on | of this          | criteria such as HIC.                    |
|   |    | structure must   |                                          |
|   | (b | be covered with  |                                          |
|   | )( | at least 2       |                                          |
|   | 3) | inches of energy |                                          |
|   |    | absorbing        |                                          |
|   |    | protective foam. |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | All side-facing  | The proposed text should be changed to   |
| 1 | .3 | seats require    | read as follows:                         |
|   | 87 | end closures.    |                                          |
|   | 43 |                  | "*All side-facing seats require end      |
|   |    |                  | closures or other means to prevent the   |
|   | E  |                  | occupant from translating off of the     |
|   | qu |                  | seat."*                                  |
|   | ip |                  |                                          |
|   | me |                  | The suggested text takes into            |
|   | nt |                  | consideration the fact that end closures |
|   | a  |                  | are not the only means for ensuring that |
|   | nd |                  | the occupant does not translate off of   |
|   | De |                  | the side-facing seat.                    |
|   | si |                  |                                          |
|   | gn |                  |                                          |
|   |    |                  |                                          |
|   | §. |                  |                                          |
|   | 4. |                  |                                          |
|   | Oc |                  |                                          |
|   | cu |                  |                                          |
|   | pa |                  |                                          |
|   | nt |                  |                                          |
|   | Pr |                  |                                          |
|   | ot |                  |                                          |
|   | ec |                  |                                          |
|   | ti |                  |                                          |
|   | on |                  |                                          |
|   |    |                  |                                          |
|   | \  |                  |                                          |
|   | (c |                  |                                          |
|   | \) |                  |                                          |
|   | G  |                  |                                          |
|   | en |                  |                                          |
|   | er |                  |                                          |
|   | al |                  |                                          |
|   | Gu |                  |                                          |
|   | id |                  |                                          |
|   | el |                  |                                          |
|   | in |                  |                                          |
|   | es |                  |                                          |
|   | (  |                  |                                          |
|   | 1) |                  |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | For the          | The proposed text should be changed to   |
| 2 | .3 | longitudinal     | read as follows:                         |
|   | 87 | tests, conducted |                                          |
|   | 43 | in accordance    | *"One test will be required with ATDs in |
|   |    | with the         | all positions, with undeformed floor, 10 |
|   | E  | conditions       | degrees yaw and with all lateral         |
|   | qu | specified in §   | supports (armrests/walls). For           |
|   | ip | 25.562(b)(2), a  | configurations with a wall or bulkhead   |
|   | me | minimum number   | immediately forward of the forward seat  |
|   | nt | of tests will be | position of the sofa, a Side Impact      |
|   | a  | required as      | Dummy (SID) (or other suitable) ATD must |
|   | nd | follows:         | be used in the forward seat position and |
|   | De |                  | Hybrid II ATD(s) or equivalent must be   |
|   | si | \(i\) One test   | used for all other seat locations. For   |
|   | gn | will be required | configurations without a wall or         |
|   |    | with one SID ATD | bulkhead immediately forward of the      |
|   | §. | in the forward   | forward seat, Hybrid II ATDs or          |
|   | 4. | most position    | equivalent must be used in all seat      |
|   | Oc | and Hybrid II    | locations".*                             |
|   | cu | ATD(s) in all    |                                          |
|   | pa | other positions, | The use of a SID ATD in any seating      |
|   | nt | with undeformed  | position where there is no contact       |
|   | Pr | floor, 10        | between the ATD and surrounding          |
|   | ot | degrees yaw, and | structure is not considered necessary    |
|   | ec | with all lateral | and the proposed text is not consistent  |
|   | ti | supports         | with exemptions that have been granted   |
|   | on | (                | in the past. Where there is no contact,  |
|   |    | armrests/walls). | an occupant movement envelope (OME) must |
|   | \  |                  | be determined by test and used to        |
|   | (c |                  | substantiate the installation of         |
|   | \) |                  | adjacent furnishings.                    |
|   | G  |                  |                                          |
|   | en |                  | The use of Hybrid II ATDs, or            |
|   | er |                  | equivalent, for the required             |
|   | al |                  | longitudinal tests is considered to be   |
|   | Gu |                  | an acceptable means for determination of |
|   | id |                  | the OME for the side-facing seat.        |
|   | el |                  |                                          |
|   | in |                  | Furthermore, the final rule should not   |
|   | es |                  | define the type of ATD to be used in     |
|   | (  |                  | absolute terms. The qualification "or    |
|   | 3) |                  | equivalent" should be included in the    |
|   |    |                  | final rule wherever the type (ie minimum |
|   |    |                  | performance standard) of ATD must be     |
|   |    |                  | specified.                               |
+---+----+------------------+------------------------------------------+
| 1 | p  | \(ii\) One test  | The proposed text should be changed to   |
| 3 | .3 | will be required | read as follows:                         |
|   | 87 | with one SID ATD |                                          |
|   | 43 | in the center    | One test will be required with Hybrid II |
|   |    | seat and Hybrid  | ATDs, or equivalent, in all positions,   |
|   | E  | II (or modified  | with deformed floor, 10 degrees yaw and  |
|   | qu | Hybrid III)      | with all lateral supports                |
|   | ip | ATD(s) in all    | (armrests/walls). This could be          |
|   | me | other positions, | considered the structural test as well." |
|   | nt | with deformed    |                                          |
|   | a  | floor, 10        | The use of a SID ATD in the center       |
|   | nd | degrees yaw, and | seating position is not considered       |
|   | De | with all lateral | necessary since contact between the      |
|   | si | supports         | occupants is not permitted and there     |
|   | gn | (                | would be no contact with surrounding     |
|   |    | armrests/walls). | structure. Furthermore, it is noted that |
|   | §. | This could be    | exemptions that have been granted in the |
|   | 4. | considered the   | past did not require the use of a SID    |
|   | Oc | structural test  | ATD in the center seating position.      |
|   | cu | as well.         |                                          |
|   | pa |                  |                                          |
|   | nt |                  |                                          |
|   | Pr |                  |                                          |
|   | ot |                  |                                          |
|   | ec |                  |                                          |
|   | ti |                  |                                          |
|   | on |                  |                                          |
|   |    |                  |                                          |
|   | \  |                  |                                          |
|   | (c |                  |                                          |
|   | \) |                  |                                          |
|   | G  |                  |                                          |
|   | en |                  |                                          |
|   | er |                  |                                          |
|   | al |                  |                                          |
|   | Gu |                  |                                          |
|   | id |                  |                                          |
|   | el |                  |                                          |
|   | in |                  |                                          |
|   | es |                  |                                          |
|   | (  |                  |                                          |
|   | 3) |                  |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | For the vertical | The proposed text should be changed to   |
| 4 | .3 | test, conducted  | read as follows:                         |
|   | 87 | in accordance    |                                          |
|   | 44 | with the         | "**For the vertical test, conducted in   |
|   |    | conditions       | accordance with the conditions specified |
|   | E  | specified in §   | in § 25.562(b)(1), Hybrid II ATDs or     |
|   | qu | 25.562(b)(1),    | equivalent will be used in all seat      |
|   | ip | Hybrid II ATD's  | positions**".                            |
|   | me | will be used in  |                                          |
|   | nt | all seat         |                                          |
|   | a  | positions.       |                                          |
|   | nd |                  |                                          |
|   | De |                  |                                          |
|   | si |                  |                                          |
|   | gn |                  |                                          |
|   |    |                  |                                          |
|   | §. |                  |                                          |
|   | 4. |                  |                                          |
|   | Oc |                  |                                          |
|   | cu |                  |                                          |
|   | pa |                  |                                          |
|   | nt |                  |                                          |
|   | Pr |                  |                                          |
|   | ot |                  |                                          |
|   | ec |                  |                                          |
|   | ti |                  |                                          |
|   | on |                  |                                          |
|   |    |                  |                                          |
|   | \  |                  |                                          |
|   | (c |                  |                                          |
|   | \) |                  |                                          |
|   | G  |                  |                                          |
|   | en |                  |                                          |
|   | er |                  |                                          |
|   | al |                  |                                          |
|   | Gu |                  |                                          |
|   | id |                  |                                          |
|   | el |                  |                                          |
|   | in |                  |                                          |
|   | es |                  |                                          |
|   | (  |                  |                                          |
|   | 4) |                  |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | In lieu of the   | It is proposed to include "*as           |
| 5 | .3 | requirements of  | practical*" and to remove *"for which    |
|   | 87 | § 25.785(h)(2),  | the flight attendant is responsible"*,   |
|   | 44 | to the extent    | as follow: "\[...\] seats must be        |
|   |    | practical        | located to face the cabin area ***[as    |
|   | §  | without          | practical]{.underline}*** ~~for which    |
|   | 5. | compromising     | the flight attendant is responsible."~~  |
|   | Di | proximity to a   |                                          |
|   | re | required floor   | The reason is that the definition of the |
|   | ct | level emergency  | area where the flight attendant is       |
|   | Vi | exit, flight     | responsible could be a subjective issue  |
|   | ew | attendant seats  | in certain configuration.                |
|   |    | must be located  |                                          |
|   |    | to face the      |                                          |
|   |    | cabin area for   |                                          |
|   |    | which the flight |                                          |
|   |    | attendant is     |                                          |
|   |    | responsible.     |                                          |
+---+----+------------------+------------------------------------------+
| 1 |    |                  | It is noted that for smaller business    |
| 5 |    |                  | jets, particularly those that include    |
| - |    |                  | FAR 25.562 in their certification basis, |
| 1 |    |                  | it is not practical to equip the         |
|   |    |                  | airplane with a flight attendant station |
|   |    |                  | for the following reasons:               |
|   |    |                  |                                          |
|   |    |                  | \(1\) It is not possible for flight      |
|   |    |                  | attendant to be seated adjacent to the   |
|   |    |                  | floor level emergency exit since there   |
|   |    |                  | is typically insufficient room at this   |
|   |    |                  | location due to the following:           |
|   |    |                  |                                          |
|   |    |                  | \(i\) Limited width of the airplane      |
|   |    |                  | (smaller business jets have a small      |
|   |    |                  | cross-section relative to commercial     |
|   |    |                  | airliners)                               |
|   |    |                  |                                          |
|   |    |                  | \(ii\) Main passenger door (typically    |
|   |    |                  | the only floor level exit) incorporates  |
|   |    |                  | steps or stairs which reduces the space  |
|   |    |                  | available when the door is closed        |
|   |    |                  |                                          |
|   |    |                  | \(2\) The entry area is furnished with   |
|   |    |                  | monuments such as galleys, closets,      |
|   |    |                  | lavatory partitions, etc and there is no |
|   |    |                  | free space available for an aft facing   |
|   |    |                  | seat                                     |
|   |    |                  |                                          |
|   |    |                  | \(3\) Having the flight attendant occupy |
|   |    |                  | a "reserved" seat in the passenger       |
|   |    |                  | compartment would not be acceptable to   |
|   |    |                  | many customers given the need for        |
|   |    |                  | privacy of the passengers                |
|   |    |                  |                                          |
|   |    |                  | Therefore, if the requirement for        |
|   |    |                  | smaller business jets with interior      |
|   |    |                  | doors to be staffed by a flight          |
|   |    |                  | attendant is not eliminated altogether   |
|   |    |                  | (refer to comments for subparagraph 2(b) |
|   |    |                  | above), then the relief provided by the  |
|   |    |                  | NPRM for direct view would be considered |
|   |    |                  | inadequate. If such were the case,       |
|   |    |                  | manufacturers of small business jets     |
|   |    |                  | would have to press for elimination of   |
|   |    |                  | any view of the cabin so that the flight |
|   |    |                  | attendant could occupy a jump seat or    |
|   |    |                  | (belted) lavatory seat.                  |
+---+----+------------------+------------------------------------------+
| 1 |    |                  | If a cabin attendant is required,        |
| 5 |    |                  | according to the comment made to         |
| - |    |                  | "operation" §2 (b), the proposed SFAR    |
| 2 |    |                  | should be in line with exemption already |
|   |    |                  | granted for FAR 25.785(h)(2), and take   |
|   |    |                  | the wording of the exemption granted, as |
|   |    |                  | follow: "***A majority of flight         |
|   |    |                  | attendant seats must be oriented to face |
|   |    |                  | the passenger cabin"***.                 |
|   |    |                  |                                          |
|   |    |                  | Furthermore, the restricted nature of    |
|   |    |                  | the operation of a private use airplane  |
|   |    |                  | mitigates much of the need for direct    |
|   |    |                  | view. That is, the operator controls and |
|   |    |                  | restricts the population of passengers   |
|   |    |                  | to be carried, unlike an air carrier.    |
|   |    |                  | Therefore, the risk of passengers        |
|   |    |                  | engaging in hazardous activity is        |
|   |    |                  | reduced, and the need for direct view is |
|   |    |                  | limited to cases where a passenger might |
|   |    |                  | need assistance. The FAA considered in   |
|   |    |                  | previous exemption granted that the      |
|   |    |                  | objective of the rule is met by          |
|   |    |                  | requiring that a majority of flight      |
|   |    |                  | attendant seats face the cabin.          |
+---+----+------------------+------------------------------------------+
| 1 | p  | The number of    | It must be clarified under which         |
| 6 | .3 | passenger seats  | circumstances a special percentage of    |
|   | 87 | located between  | occupant seats must be reduced and this  |
|   | 44 | 2 adjacent pairs | reduction should start at the            |
|   |    | of emergency     | regulations of FAR 25 and not below.     |
|   | §  | exits (commonly  |                                          |
|   | 7  | referred to as a | There is no substantiation why for a     |
|   | .( | "dead-end"       | dead end zone 40 % is adequate. It might |
|   | b) | zone), may not   | be based on the FAA experience over the  |
|   |    | exceed the       | amount of private airplanes certified    |
|   |    | following:       | and exemption granted. Nevertheless this |
|   |    |                  | passenger reduction correlates somehow   |
|   |    | 1° For zones     | to the reduced safety standard and the   |
|   |    | between 2 pairs  | reason for that adequacy should be       |
|   |    | of exits, 50 %   | explained.                               |
|   |    | of the combined  |                                          |
|   |    | rated capacity   |                                          |
|   |    | of the two pairs |                                          |
|   |    | of emergency     |                                          |
|   |    | exits.           |                                          |
|   |    |                  |                                          |
|   |    | 2° for zones     |                                          |
|   |    | between one pair |                                          |
|   |    | of exits and a   |                                          |
|   |    | bulkhead, 40 %   |                                          |
|   |    | of the rated     |                                          |
|   |    | capacity of the  |                                          |
|   |    | pair of          |                                          |
|   |    | emergency exits. |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | Distance between | The example is applying the percentage   |
| 7 | .3 | exits            | to the maximum allowable after           |
|   | 87 |                  | modification when exits are deactivated. |
|   | 44 | The total number |                                          |
|   |    | of passenger     | Our interpretation based on the proposed |
|   | §  | seats in the     | regulation                               |
|   | 7  | airplane may not |                                          |
|   | .( | exceed 33        | The total number of passenger seats in   |
|   | c) | percent of the   | the airplane may not exceed 33 percent   |
|   | a  | maximum seating  | of the maximum seating capacity for the  |
|   | nd | capacity for the | airplane model using the exit ratings    |
|   | e  | airplane model   | listed in Sec. 25.807(g) for the         |
|   | xa | using the exit   | original certified exits                 |
|   | mp | ratings listed   |                                          |
|   | le | in Sec.          | It is 55x4x33% = 72,6 (73 passengers)    |
|   | p  | 25.807(g) for    |                                          |
|   | .3 | the original     | The maximum allowable after modification |
|   | 87 | certified exits  | when exits are deactivated               |
|   | 37 | or the maximum   |                                          |
|   |    | allowable after  | It is 55x3 = 165                         |
|   |    | modification     |                                          |
|   |    | when exits are   | Whichever is less.                       |
|   |    | deactivated,     |                                          |
|   |    | whichever is     | 73 passengers, but limited to 60 as the  |
|   |    | less.            | proposed regulation                      |
|   |    |                  |                                          |
|   |    | "For example, on | The example has been assumed that the    |
|   |    | an airplane with | total seating capacity reduced to        |
|   |    | 4 pairs of Type  | one-third of the remaining doors after   |
|   |    | C exits, the     | exits deactivated and the proposed       |
|   |    | t                | regulation could be interpreted as       |
|   |    | ype-certificated | presented above, being so clarification  |
|   |    | passenger        | is needed.                               |
|   |    | seating capacity |                                          |
|   |    | will normally be |                                          |
|   |    | 220. Assuming    |                                          |
|   |    | the number 3     |                                          |
|   |    | exits are        |                                          |
|   |    | deactivated,     |                                          |
|   |    | leaving three    |                                          |
|   |    | active pairs of  |                                          |
|   |    | Type C exits,    |                                          |
|   |    | the theoretical  |                                          |
|   |    | maximum          |                                          |
|   |    | currently        |                                          |
|   |    | allowed by Sec.  |                                          |
|   |    | 25.807 would be  |                                          |
|   |    | 165. This        |                                          |
|   |    | proposal,        |                                          |
|   |    | however, would   |                                          |
|   |    | limit the        |                                          |
|   |    | maximum capacity |                                          |
|   |    | to 55."          |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | A distance of    | It is not obvious why a distance of more |
| 8 | .3 | more than 60     | than 60ft is allowed only one time on    |
|   | 87 | feet between     | each side of the fuselage. In case of a  |
|   | 44 | adjacent         | five uniform distributed pair of exits   |
|   |    | passenger        | (1,2,3,4,5), it should be possible to    |
|   | §  | emergency exits  | deactivate Door 2 and 4 so far all other |
|   | 7  | on the same side | aspects are fulfilled. The situation     |
|   | .( | of the same deck | between 1 and 3 would be the same as     |
|   | d) | of the fuselage, | between 3 and 5 and the safety level for |
|   |    | as measured      | the occupants would be the same in each  |
|   |    | parallel to the  | cabin area.                              |
|   |    | airplane's       |                                          |
|   |    | longitudinal     |                                          |
|   |    | axis between the |                                          |
|   |    | nearest exit     |                                          |
|   |    | edges, is        |                                          |
|   |    | allowed only one |                                          |
|   |    | time on each     |                                          |
|   |    | side of the      |                                          |
|   |    | fuselage.        |                                          |
+---+----+------------------+------------------------------------------+
| 1 |    |                  | The case where only one exit from the    |
| 8 |    |                  | pair of exit is deactivated should be    |
| - |    |                  | added.                                   |
| 1 |    |                  |                                          |
+---+----+------------------+------------------------------------------+
| 1 | p  | In lieu of the   | Draft AC 25-17A proposes to include      |
| 9 | .3 | requirements of  | guidance that specifically addresses     |
|   | 87 | § 25.811(d)(1)   | this issue.                              |
|   | 44 | and (2) a single |                                          |
|   |    | sign at each     | NOTE                                     |
|   | §  | exit may be      |                                          |
|   | 8. | installed        | AC 25-17 already addresses the case of a |
|   | E  | provided:        | combined locator and bulkhead exit sign  |
|   | me |                  | (i.e. single sign that meets the         |
|   | rg | (a) The sign can | requirements of FAR 25.811(d)(1) and     |
|   | en |     be read from | (3)).                                    |
|   | cy |     the aisle    |                                          |
|   | Ex |     while        | The disadvantages of including this      |
|   | it |     directly     | design requirement in the proposed SFAR  |
|   | S  |     facing the   | are as follows:                          |
|   | ig |     exit, and    |                                          |
|   | ns |                  | \(1\) A compliance finding against the   |
|   |    | (b) The sign can | requirements of the SFAR implies that    |
|   |    |     be read from | the design does not comply with the      |
|   |    |     the aisle    | requirements of FAR 25.811(d) - there is |
|   |    |     adjacent to  | a possibility that this could complicate |
|   |    |     the          | foreign validation of associated         |
|   |    |     passenger    | approvals                                |
|   |    |     seat         |                                          |
|   |    |     furthest     | \(2\) There is no degradation of the     |
|   |    |     from the     | overall level of safety therefore the    |
|   |    |     exit without | use of a single exit sign to perform     |
|   |    |     an           | both the locator and marker functions    |
|   |    |     intervening  | should not be limited to aircraft with   |
|   |    |     exit         | executive interiors and certainly not    |
|   |    |                  | only airplanes that are limited to       |
|   |    |                  | private use operations only              |
|   |    |                  |                                          |
|   |    |                  | It is recommended that this item be      |
|   |    |                  | eliminated from the proposed SFAR and    |
|   |    |                  | that the associated advisory material be |
|   |    |                  | updated to reflect this interpretation   |
|   |    |                  | of FAR 25.811(d).                        |
+---+----+------------------+------------------------------------------+
| 1 |    |                  | Section 25.811(d) requires three types   |
| 9 |    |                  | of emergency exit signs: locator signs   |
| - |    |                  | (Sec. 25.811(d)(1)), which are in the    |
| 1 |    |                  | aisle at the approximate longitudinal    |
|   |    |                  | station at the exit to direct a          |
|   |    |                  | passenger to the exit; marking signs     |
|   |    |                  | (Sec. 25.811(d)(2)), which are next to   |
|   |    |                  | the exit to identify it when a passenger |
|   |    |                  | has reached that point; and indicator    |
|   |    |                  | signs (Sec. 25.811(d)(3)), which are     |
|   |    |                  | located on a bulkhead or divider to      |
|   |    |                  | indicate exits are beyond that           |
|   |    |                  | bulkhead.\                               |
|   |    |                  | \                                        |
|   |    |                  | Many interior configurations present a   |
|   |    |                  | bulkhead or a monument obscuring the     |
|   |    |                  | view of emergency exits, thus requiring  |
|   |    |                  | a bulkhead sign according to Sec.        |
|   |    |                  | 25.811(d)(3).                            |
|   |    |                  |                                          |
|   |    |                  | AC 25-17, paragraph no. 384, allows that |
|   |    |                  | a single sign may satisfy both           |
|   |    |                  | requirements RBHA/FAR 25.811(d)(1) and   |
|   |    |                  | 25.811(d)(3), as quoted in the           |
|   |    |                  | following: " . . . However, certain      |
|   |    |                  | cabin arrangements might permit a single |
|   |    |                  | sign to serve the functions of both      |
|   |    |                  | paragraph (d)(1) and (3). If such an     |
|   |    |                  | arrangement were presented, the sign     |
|   |    |                  | should meet the contrast and brightness  |
|   |    |                  | requirements of Sec. 25.812(b)(1)(i) and |
|   |    |                  | should be in close proximity to the      |
|   |    |                  | exits concerned. Compliance with both    |
|   |    |                  | Sec. 25.811(d)(1) and (3) is required    |
|   |    |                  | regardless of the number of signs        |
|   |    |                  | employed." (AC 25-17 A, paragraph 384,   |
|   |    |                  | page 339)                                |
|   |    |                  |                                          |
|   |    |                  | " ... Should be in close proximity to    |
|   |    |                  | the exits concerned ..." is a subjective |
|   |    |                  | statement. For private use passenger     |
|   |    |                  | operation (but also applicable to other  |
|   |    |                  | transport category airplanes presenting  |
|   |    |                  | a single aisle configuration and simple  |
|   |    |                  | cabin layout) a more objective criteria  |
|   |    |                  | could be proposed as follows:            |
|   |    |                  |                                          |
|   |    |                  | "*. . . However, certain cabin           |
|   |    |                  | arrangements might permit a single sign  |
|   |    |                  | to serve the functions of both paragraph |
|   |    |                  | (d)(1) and (3) in situations where the   |
|   |    |                  | bulkheads and/or monuments do not        |
|   |    |                  | obscure the visibility of the exit       |
|   |    |                  | locator sign. If such an arrangement     |
|   |    |                  | were presented, the sign should meet the |
|   |    |                  | contrast and brightness requirements of  |
|   |    |                  | Sec. 25.812(b)(1)(i).*"                  |
|   |    |                  |                                          |
|   |    |                  | Adequacy of the single sign and its      |
|   |    |                  | location would be demonstrated during    |
|   |    |                  | the cabin compliance inspection of the   |
|   |    |                  | interior arrangement.                    |
+---+----+------------------+------------------------------------------+
| 2 |    | In lieu of the   | Reference paragraph 2(a) of this SFAR    |
| 0 |    | requirements of  | for flight attendant requirements.       |
|   |    | § 25.813(e),     |                                          |
|   |    | interior doors   | Correct the indication reference         |
|   |    | may be installed | paragraph - it is 2 (b)                  |
|   |    | between          |                                          |
|   |    | passenger        |                                          |
|   |    | compartments     |                                          |
|   |    | provided the     |                                          |
|   |    | following        |                                          |
|   |    | requirements are |                                          |
|   |    | met.             |                                          |
|   |    |                  |                                          |
|   |    | Note: Reference  |                                          |
|   |    | paragraph 2(a)   |                                          |
|   |    | of this SFAR for |                                          |
|   |    | flight attendant |                                          |
|   |    |                  |                                          |
|   |    | requirements.    |                                          |
+---+----+------------------+------------------------------------------+
| 2 |    |                  | There are a few issues with the proposed |
| 0 |    |                  | rule:                                    |
| - |    |                  |                                          |
| 1 |    |                  | \(1\) The proposed SFAR does not         |
|   |    |                  | addresses the changes to FAR 25.813(e)   |
|   |    |                  | that were introduced by Amdt 25-116      |
|   |    |                  | (i.e. the fact that the regulation now   |
|   |    |                  | prohibits any door between a passenger   |
|   |    |                  | seat and a required emergency exit)      |
|   |    |                  |                                          |
|   |    |                  | NOTE                                     |
|   |    |                  |                                          |
|   |    |                  | The installation of a door between the   |
|   |    |                  | entry area and the passenger compartment |
|   |    |                  | is a design feature that is common to    |
|   |    |                  | most smaller business jets, including    |
|   |    |                  | those that are operated by air carriers  |
|   |    |                  | under FAR Part 135.                      |
|   |    |                  |                                          |
|   |    |                  | The ability to offer such doors is       |
|   |    |                  | considered to be essential for all       |
|   |    |                  | business jets, regardless of whether or  |
|   |    |                  | not aircraft will be for private use     |
|   |    |                  | operations or on-demand operations.      |
|   |    |                  |                                          |
|   |    |                  | \(2\) The proposed rule does not specify |
|   |    |                  | what additional requirements, if any,    |
|   |    |                  | would be applicable if the applicant     |
|   |    |                  | seeks the installation of interior doors |
|   |    |                  | on aircraft that have no operating       |
|   |    |                  | limitations (i.e. that can be operated   |
|   |    |                  | for hire or common carriage)             |
|   |    |                  |                                          |
|   |    |                  | NOTE                                     |
|   |    |                  |                                          |
|   |    |                  | The FAA has recently issued a finding of |
|   |    |                  | equivalent safety (reference memo        |
|   |    |                  | PS05-0272-C-1) to permit doors on        |
|   |    |                  | mini-suites installed on Boeing 777      |
|   |    |                  | aircraft that are intended for scheduled |
|   |    |                  | airline operations. Given the criteria   |
|   |    |                  | that are proposed in the NPRM, which are |
|   |    |                  | intended to ensure that the doors are    |
|   |    |                  | secured open for takeoff & landing, it   |
|   |    |                  | not clear why installation of a          |
|   |    |                  | frangible door between passenger         |
|   |    |                  | compartments is not permitted for        |
|   |    |                  | aircraft that are used for on-demand     |
|   |    |                  | operations as well as private use        |
|   |    |                  | operations.                              |
|   |    |                  |                                          |
|   |    |                  | In order to address the changes          |
|   |    |                  | introduced by Amdt 25-116, it may be     |
|   |    |                  | necessary for the final rule to          |
|   |    |                  | differentiate between doors installed    |
|   |    |                  | between passenger compartments and those |
|   |    |                  | that are installed between passenger     |
|   |    |                  | seats and emergency exits.               |
+---+----+------------------+------------------------------------------+
| 2 | p  | Compliance is    | The proposal that aisle width may not be |
| 1 | .3 | required with §  | reduced to less than 9 inches between    |
|   | 87 | 25.815, except   | passenger seats during flight is not     |
|   | 44 | that aisle width | acceptable. Unlike commercial aircraft,  |
|   |    | may be reduced   | the seats on aircraft with executive     |
|   | §  | to no less than  | interiors can be moved during flight     |
|   | 1  | 9 inches between | (leg rests extended, seatback reclined,  |
|   | 1. | passenger seats  | seat swiveled and/or tracked on its      |
|   | W  | during flight,   | base, etc). While the NPRM addresses     |
|   | id |                  | these differences, there are a few       |
|   | th | provided that    | issues with the proposed rule:           |
|   | of | instructions are |                                          |
|   | A  | provided at each | \(1\) The requirement to maintain at     |
|   | is | passenger seat   | least a 9 inch aisle will result in a    |
|   | le | for restoring    | significant burden and is considered     |
|   |    | the aisle width  | unnecessary from a safety point of view, |
|   |    | required by §    | particularly for smaller business jets   |
|   |    | 25.815.          |                                          |
|   |    | Procedures must  | NOTE                                     |
|   |    | be established   |                                          |
|   |    | to ensure that   | This may not be an issue for commercial  |
|   |    | the required     | airliners that are outfitted with        |
|   |    | aisle widths are | executive interiors, however, for        |
|   |    | provided during  | smaller business jets, almost every      |
|   |    | taxi, takeoff,   | aircraft would be adversely affected     |
|   |    | and landing. The | given the relatively narrow width of the |
|   |    | aisle width is   | airplanes.                               |
|   |    | determined with  |                                          |
|   |    | seats in the     | The guidance that is proposed in draft   |
|   |    | most adverse,    | AC 25-17A is considered acceptable since |
|   |    | fixed position,  | this 9 inch minimum aisle width          |
|   |    | as described in  | requirement is not included.             |
|   |    | AC 25--17,       |                                          |
|   |    | Transport        | \(2\) The limitation of the proposed     |
|   |    | Airplane Cabin   | rule to private use operations is not    |
|   |    | Interiors        | acceptable given the fact that flexible  |
|   |    | Crashworthiness  | seating arrangements are required by     |
|   |    | Handbook, dated  | owners & operators of all business jets, |
|   |    | June 15,         | regardless of whether the operations     |
|   |    |                  | involved are private use or for hire as  |
|   |    | 1991\.           | in the case of FAR Part 135 air carriers |
|   |    |                  | introducing the requirement for a 9 inch |
|   |    |                  | aisle to be maintained results in a      |
|   |    |                  | significant burden to manufactures of    |
|   |    |                  | smaller business jets for the following  |
|   |    |                  | reasons:                                 |
|   |    |                  |                                          |
|   |    |                  | \(1\) A change to the TSO approved seats |
|   |    |                  | would be required in order to ensure the |
|   |    |                  | seat cannot lock in an "adverse"         |
|   |    |                  | position while still being able to       |
|   |    |                  | swivel or track past this point          |
|   |    |                  |                                          |
|   |    |                  | NOTE                                     |
|   |    |                  |                                          |
|   |    |                  | Modification of the seat assembly could  |
|   |    |                  | result in extensive cost impact,         |
|   |    |                  | particularly for seats that meet the     |
|   |    |                  | requirements of TSO-C127a.               |
|   |    |                  |                                          |
|   |    |                  | \(2\) The aisle is typically bordered by |
|   |    |                  | seats that are arranged in groupings of  |
|   |    |                  | four - given this configuration, most    |
|   |    |                  | seats would have to be modified in order |
|   |    |                  | to limit their travel                    |
|   |    |                  |                                          |
|   |    |                  | \(3\) A common arrangement is for the    |
|   |    |                  | aft cabin to be outfitted with two side  |
|   |    |                  | facing divans that deploy into the aisle |
|   |    |                  | to form a single extra large sleeping    |
|   |    |                  | surface - the proposed rule would make   |
|   |    |                  | it impossible to offer this              |
|   |    |                  | configuration and would negatively       |
|   |    |                  | impact the competitiveness (i.e. sales)  |
|   |    |                  | of the aircraft type. From a safety      |
|   |    |                  | point of view, the kinds of obstructions |
|   |    |                  | that can be reasonably expected to occur |
|   |    |                  | include leg rests that are extended into |
|   |    |                  | the aisle and divan seat pans that are   |
|   |    |                  | deployed into the aisle to form a large  |
|   |    |                  | sleeping surface. These kinds of         |
|   |    |                  | obstructions are unlikely to impede the  |
|   |    |                  | crew from moving about the cabin in an   |
|   |    |                  | emergency since it would be possible to  |
|   |    |                  | step over the leg rests or onto the      |
|   |    |                  | divan seat pan in order to move past the |
|   |    |                  | "obstruction".                           |
|   |    |                  |                                          |
|   |    |                  | NOTE                                     |
|   |    |                  |                                          |
|   |    |                  | While it is possible for seat backrests  |
|   |    |                  | to be deployed into the aisle such that  |
|   |    |                  | the aisle is obstructed, for smaller     |
|   |    |                  | business jets in particular this         |
|   |    |                  | configuration is considered unlikely to  |
|   |    |                  | occur during normal flight operations    |
|   |    |                  | since it results in minimal legroom for  |
|   |    |                  | the seated occupant. In the event seats  |
|   |    |                  | were to be so arranged, it would be a    |
|   |    |                  | relatively simple matter for the         |
|   |    |                  | crewmember to reconfigure the seat or to |
|   |    |                  | ask the seated occupant to do so -- the  |
|   |    |                  | means by which this is accomplished is   |
|   |    |                  | no more complicated than opening a door. |
+---+----+------------------+------------------------------------------+
| 2 | p  | There must be    | The proposed rule does not specify any   |
| 2 | .3 | means that meet  | criteria regarding the size of           |
|   | 87 | the requirements | compartment that must have a smoke or    |
|   | 44 | of § 25.858(a)   | fire detection system installed nor does |
|   |    | through (d) to   | it differentiate between lavatories and  |
|   | §  | signal the       | other kinds of rooms that can be closed  |
|   | 1  | flight crew in   | off from the rest of the cabin by a      |
|   | 3. | the event of a   | door. It is noted that the NPRM states,  |
|   | Fi | fire in any      | "such rooms would include large galley   |
|   | re | isolated room    | complexes, as well as bedrooms and       |
|   | D  | not occupiable   | conference rooms", however, it is felt   |
|   | et | for taxi,        | that this is insufficient to ensure      |
|   | ec | takeoff and      | uniform application of the rule. It is   |
|   | ti | landing, which   | recommended that the proposed rule be    |
|   | on | can be closed    | changed as follows in order to remove    |
|   |    | off from the     | ambiguity and simplify compliance        |
|   |    | rest of the      | findings:                                |
|   |    | cabin by a door, |                                          |
|   |    | from any likely  | \(1\) The final rule should specify the  |
|   |    | source. The      | size of compartment to which it is       |
|   |    | indication must  | applicable (i.e. maximum size of         |
|   |    | identify the     | compartment that does not require a      |
|   |    | compartment      | smoke or fire detection system)          |
|   |    | where the fire   |                                          |
|   |    | is located.      | \(2\) The rule should include text to    |
|   |    |                  | make it clear that the requirements of   |
|   |    |                  | FAR 25.854 are applicable to lavatories  |
|   |    |                  | and that a lavatory is not considered a  |
|   |    |                  | "room" in the context of this rule       |
|   |    |                  |                                          |
|   |    |                  | \(3\) The requirements of FAR 25.858(a)  |
|   |    |                  | through (d) should be duplicated in the  |
|   |    |                  | final rule                               |
|   |    |                  |                                          |
|   |    |                  | Based on these recommendations, the      |
|   |    |                  | proposed text should be changed to read  |
|   |    |                  | as follows: Excluding lavatories, each   |
|   |    |                  | isolated room not occupiable for taxi,   |
|   |    |                  | takeoff and landing which can be closed  |
|   |    |                  | off from the rest of the cabin by a door |
|   |    |                  | and whose size exceeds XX ft3 must be    |
|   |    |                  | equipped with a smoke or fire detection  |
|   |    |                  | system that meets the following:         |
|   |    |                  |                                          |
|   |    |                  | \(a\) The detection system must provide  |
|   |    |                  | a visual indication to the flight crew   |
|   |    |                  | within one minute after the start of a   |
|   |    |                  | fire from any likely source.             |
|   |    |                  |                                          |
|   |    |                  | \(b\) The indication must identify the   |
|   |    |                  | compartment where the fire is located.   |
|   |    |                  |                                          |
|   |    |                  | \(c\) The system must be capable of      |
|   |    |                  | detecting a fire at a temperature        |
|   |    |                  | significantly below that at which the    |
|   |    |                  | structural integrity of the airplane is  |
|   |    |                  | substantially decreased.                 |
|   |    |                  |                                          |
|   |    |                  | \(d\) There must be means to allow the   |
|   |    |                  | crew to check in flight, the functioning |
|   |    |                  | of each fire detector circuit.           |
|   |    |                  |                                          |
|   |    |                  | \(e\) The effectiveness of the detection |
|   |    |                  | system must be shown for all approved    |
|   |    |                  | operating configurations and conditions. |
|   |    |                  |                                          |
|   |    |                  | Where a value of at least 200 ft3 for XX |
|   |    |                  | would be considered acceptable.          |
|   |    |                  |                                          |
|   |    |                  | It also should be noted that if this     |
|   |    |                  | requirement forms part of the            |
|   |    |                  | certification basis, then in accordance  |
|   |    |                  | with 1(d) the airplane will be limited   |
|   |    |                  | to use private operations only           |
|   |    |                  | regardless of whether or not there are   |
|   |    |                  | any other design features which do not   |
|   |    |                  | comply fully with the requirements of    |
|   |    |                  | FAR 25.                                  |
+---+----+------------------+------------------------------------------+
| 2 | P  | Each cooktop     | The requirements for the installation of |
| 3 | .3 | must be designed | cook tops should be limited to the       |
|   | 87 | and installed to | minimum required precautions, adequate   |
|   | 45 | minimize any     | for private operation. The criteria      |
|   |    | potential threat | outlined in the Appendix are very        |
|   | §  | to the airplane, | constraining and should be alleviate in  |
|   | 14 | passengers and   | regards of the familiarity of the people |
|   | C  | crew. Compliance | with the aircraft, and the number of     |
|   | oo | with this        | flight attendant that are making the     |
|   | kt | requirement must | service on board.                        |
|   | op | be found in      |                                          |
|   |    | accordance with  |                                          |
|   |    | the criteria     |                                          |
|   |    | outlined in      |                                          |
|   |    | Appendix 1 of    |                                          |
|   |    | this SFAR        |                                          |
+---+----+------------------+------------------------------------------+
| 2 | p  | In addition to   | To substitute the word "at" by "for"     |
| 4 | .3 | the requirements |                                          |
|   | 87 | of § 25.851,     | In addition to the requirements of Sec.  |
|   | 45 | hand-held fire   | 25.851, hand-held fire extinguishers     |
|   |    | extinguisher     | must be installed ***[at]{.underline}*** |
|   | §  | must be          | every pair of exits certified on the     |
|   | 1  | installed at     | original type certificate in the         |
|   | 5. | every pair of    | passenger cabin***,***                   |
|   | Ha | exits certified  |                                          |
|   | nd | on the original  |                                          |
|   | Fi | type certificate |                                          |
|   | re | in the passenger |                                          |
|   | ex | cabin,           |                                          |
|   | ti | regardless of    |                                          |
|   | ng | whether the      |                                          |
|   | ui | exits are        |                                          |
|   | sh | deactivated for  |                                          |
|   | er | the proposed     |                                          |
|   | s. | configuration.   |                                          |
|   |    | Extinguishers    |                                          |
|   |    | must be evenly   |                                          |
|   |    | distributed      |                                          |
|   |    | throughout the   |                                          |
|   |    | cabin. These     |                                          |
|   |    | extinguishers    |                                          |
|   |    | are in addition  |                                          |
|   |    | to those         |                                          |
|   |    | required by      |                                          |
|   |    | paragraph 14 of  |                                          |
|   |    | this SFAR,       |                                          |
|   |    | unless it can    |                                          |
|   |    |                  |                                          |
|   |    | be shown that    |                                          |
|   |    | the cook top was |                                          |
|   |    | installed in the |                                          |
|   |    | immediate        |                                          |
|   |    | vicinity of the  |                                          |
|   |    | original exits.  |                                          |
+---+----+------------------+------------------------------------------+
| 2 |    |                  | The proposal that fire extinguishers be  |
| 4 |    |                  | installed at every pair of exits         |
| - |    |                  | certified on the original type           |
| 2 |    |                  | certificate in addition to the           |
|   |    |                  | requirements of FAR 25.851 is not        |
|   |    |                  | satisfactory for the following reasons:  |
|   |    |                  |                                          |
|   |    |                  | \(1\) The phrase "in addition to the     |
|   |    |                  | requirements of § 25.851" suggests that  |
|   |    |                  | fire extinguishers installed at each     |
|   |    |                  | pair of exits to meet this new           |
|   |    |                  | requirement do not count toward the      |
|   |    |                  | number of fire extinguishers required by |
|   |    |                  | FAR 25.851                               |
|   |    |                  |                                          |
|   |    |                  | \(2\) The phrase "installed at every     |
|   |    |                  | pair of exits" is considered to be       |
|   |    |                  | ambiguous in that it does not specify a  |
|   |    |                  | maximum distance from or location        |
|   |    |                  | relative to each exit nor does it        |
|   |    |                  | account for the fact that a pair of      |
|   |    |                  | exits on a wide body airliner are        |
|   |    |                  | substantially further apart than on a    |
|   |    |                  | regional jet (this means that proximity  |
|   |    |                  | of extinguisher to exit can vary         |
|   |    |                  | depending on width of the cabin)         |
|   |    |                  |                                          |
|   |    |                  | \(3\) The phrase "installed at every     |
|   |    |                  | pair of exits" does not account for      |
|   |    |                  | cases where more than one exit is        |
|   |    |                  | installed in close proximity to another, |
|   |    |                  | as in the case of two over wing exits    |
|   |    |                  |                                          |
|   |    |                  | \(4\) As proposed, the rule introduces a |
|   |    |                  | new requirement that will be applicable  |
|   |    |                  | to installation of an executive interior |
|   |    |                  | on any transport category airplane,      |
|   |    |                  | regardless of layout or size (i.e.       |
|   |    |                  | including smaller business jets), which  |
|   |    |                  | is problematic for the following         |
|   |    |                  | reasons:                                 |
|   |    |                  |                                          |
|   |    |                  | \(i\) There is no underlying safety      |
|   |    |                  | issue for smaller business jets to be    |
|   |    |                  | addressed                                |
|   |    |                  |                                          |
|   |    |                  | NOTE                                     |
|   |    |                  |                                          |
|   |    |                  | For an airplane such as the Gulf stream  |
|   |    |                  | 550, which has two pairs of over wing    |
|   |    |                  | exits but a relatively small cabin       |
|   |    |                  | compared to an airliner, the rule makes  |
|   |    |                  | no sense.                                |
|   |    |                  |                                          |
|   |    |                  | \(ii\) If this requirement forms part of |
|   |    |                  | the certification basis, then in         |
|   |    |                  | accordance with 1(d) the airplane will   |
|   |    |                  | be limited to use private operations     |
|   |    |                  | only regardless of whether or not there  |
|   |    |                  | are any other design features which do   |
|   |    |                  | not comply fully with the requirements   |
|   |    |                  | of FAR 25                                |
|   |    |                  |                                          |
|   |    |                  | It is recommended that the proposed rule |
|   |    |                  | be changed as follows in order to remove |
|   |    |                  | ambiguity and simplify compliance        |
|   |    |                  | findings:                                |
|   |    |                  |                                          |
|   |    |                  | \(1\) The number of fire extinguishers   |
|   |    |                  | required in the cabin should be the      |
|   |    |                  | greater of the number required by FAR    |
|   |    |                  | 25.851 or the number required to ensure  |
|   |    |                  | an adequate distribution of              |
|   |    |                  | extinguishers as intended by this        |
|   |    |                  | proposed rule                            |
|   |    |                  |                                          |
|   |    |                  | \(2\) An adequate distribution/minimum   |
|   |    |                  | number of fire extinguishers can be      |
|   |    |                  | achieved by ensuring that the distance   |
|   |    |                  | between the required cabin fire          |
|   |    |                  | extinguishers is no greater than the 60  |
|   |    |                  | feet between exits that is required per  |
|   |    |                  | FAR 25.807(f)(4) Based on these          |
|   |    |                  | recommendations, the proposed text       |
|   |    |                  | should be changed to read as follows:    |
|   |    |                  |                                          |
|   |    |                  | *Fire extinguishers that meet the        |
|   |    |                  | requirements of § 25.851 must be         |
|   |    |                  | distributed throughout the cabin such    |
|   |    |                  | that the maximum distance between any    |
|   |    |                  | two fire extinguishers is less than 60   |
|   |    |                  | feet and the maximum distance between    |
|   |    |                  | any part of the cabin that can be        |
|   |    |                  | occupied during flight and the nearest   |
|   |    |                  | fire extinguisher is less than 30 feet.  |
|   |    |                  | If required, additional fire             |
|   |    |                  | extinguishers over and above the number  |
|   |    |                  | required by § 25.851 must be installed   |
|   |    |                  | to meet this requirement.*               |
+---+----+------------------+------------------------------------------+
| 2 |    | New paragraph    | Current FAA regulations 14 CFR §§25.601, |
| 5 |    |                  | 25.603, 25.613, 25.619, 25.561, and      |
|   |    |                  | 25.789, only address the use of glass in |
|   |    |                  | windshields, instrument or display       |
|   |    |                  | transparencies, window applications, and |
|   |    |                  | certain special applications where no    |
|   |    |                  | other material will serve. In either     |
|   |    |                  | this proposed rulemaking or its next     |
|   |    |                  | revision, the FAA should consider        |
|   |    |                  | permitting the use of glass partitions,  |
|   |    |                  | panels, etc. in private use jets when    |
|   |    |                  | those objects are manufactured and       |
|   |    |                  | installed in a manner that assures       |
|   |    |                  | safety is complied with.                 |
|   |    |                  |                                          |
|   |    |                  | Owners of private use jets have          |
|   |    |                  | requested permission to use glass        |
|   |    |                  | partitions within the passenger cabin    |
|   |    |                  | compartment of the airplanes. The FAA    |
|   |    |                  | has previously issued Special Conditions |
|   |    |                  | to allow such use.                       |
|   |    |                  |                                          |
|   |    |                  | If a supplier/manufacturer can           |
|   |    |                  | demonstrate that a glass product (e.g.   |
|   |    |                  | bullet-proof glass) does not shatter,    |
|   |    |                  | and installs this product in a manner    |
|   |    |                  | that assures proper restraint to         |
|   |    |                  | withstand in-flight and crash loads,     |
|   |    |                  | then we consider that the                |
|   |    |                  | safety-compliant glass product should be |
|   |    |                  | viewed the same as non-glass products.   |
+---+----+------------------+------------------------------------------+