**[PETITION FOR EXEMPTION]{.underline}**

**Subject**: Petition for Exemption from Title 14 CFR §25.813(e) --
doors

between passenger compartments

**Airplane**: Lockheed L1011-385-3, s/n 293A-1249, N388LS -- Privately
Owned,

Executive Configuration

**Reference**: FAA Project No. ST8715SC-T

**[Introduction]{.underline}**

Future Jet Aerodesign LLC (FJA), on behalf of the STC applicant Las
Vegas Sands Corporation is petitioning for exemption from certain Title
14 Code of Federal Regulations (14CFR) part 25 regulations. This
exemption is being sought for only one airplane --Lockheed L1011-385-3,
airplane serial number 293A-1249, which will be configured with VIP
executive interior and operated for private use only, and not operated
for hire, or for common carriage.

This petition requests that the FAA grant an exemption from certain
provisions of 14

CFR part 25 for the above referenced airplane, similar to relief
previously granted to

other private not-for-hire airplanes. For reference, FJA notes the
following exemptions

describe in pertinent part relief previously granted relative to
requirements for doors between passenger compartments.

 Exemption No. 6820A, Docket No. 29253, Partial Grant of Exemption from

§§25.807(d)(7), 25.813(e), and 25.853(d), for BoeingModel 737-700IGW
airplane.

 Exemption No. 7107, Docket No. 29800, Partial Grant of Exemption from

§25.813(e), for BoeingModel 757-200 airplane.

 Exemption No. 7489, Docket No. FAA-2000-8262, Partial Grant of
Exemption

from §§25.785(h)(2), 25.807(d)(7), and 25.813(e), for Airbus Model
A319CJ

airplane.

 Exemption No. 7609, Docket No. FAA-2001-9458, Grant of Exemption from

§§25.785(h)(2), 25.807(d)(7), 25.813(e) and 25.853(d), for BoeingModel
737-800

airplane.

 Exemption No. 8461, Docket No. FAA-2004-18022, Grant of Exemption from

§§25.785(d) and 25.813(e), for Boeing Model 767-300ER airplane.

**[REQUEST]{.underline}**

FJA requests that the above referenced airplane, when configured for
private use and

utilized under operating rules 14 CFR part 91 or part 125, be exempted
from the

following requirements of Title 14 CFR part 25:

 §25.813(e), Amendment 25-32 -- Prohibits installation of interior
doors between

passenger compartments.

**Sections of 14 CFR Affected**

Section 25.813(e), at Amendment 25-32, states:

No door may be installed in any partition between passenger
compartments.

**Information to Support Grant of Exemption -- General**

Title 14 CFR part 25 governs design certification of transport category
airplanes. The

primary intent of these regulations, as written, is to assure that
airplane manufacturers

provide for the appropriate design features in their respective airplane
to meet the

standards necessary to protect the traveling public. Clearly, there is a
requirement in the

interest of safety to provide appropriately stringent regulatory
standards for certification.

However, it is also clear that these regulations are intended to
regulate the certification of

"commercial" airplanes, which are "for hire" to the general public.

While the majority of these regulations represent a common sense
inclusion for any

airplane regardless of its intended use, a few are obviously intended to
regulate situations

that are specific to an airline, or for hire operation. When a transport
category airplane is

operated under 14 CFR part 91 or part 125, some of the 14 CFR part 25
rules have

acceptance criteria that are inappropriate, or are not compatible, with
this type of

operation and the intended use of the airplane.

Transport category aircraft intended for private use, whether originally
designed for

private use or public, revenue-type operations and then utilized under
14 CFR part 91 or

part 125, are used for personal (corporate) non-revenue operations,
which represent

significant operational differences from the typical revenue operation.
The differences

represented in these private operations can best be described as
follows:

1\. Operation is limited to the private use of an individual(s),
corporation, or

government and does not include public -- for hire -- operations.

2\. Passenger capacity of the aircraft is significantly less than an
equivalent aircraft in

commercial operations. Typically, the capacity is less than 30% of that
found in

an airline configuration.

3\. Flight and cabin crews are typically highly trained, and far more
familiar with the

individual aircraft they are operating, since it is normally the primary
aircraft on

which they always perform their duties.

4\. Security is extremely high in terms of access to the aircraft while
on the ground

and with respect to individuals boarding the aircraft.

5\. Passengers on these aircraft are typically repeat passengers, and
represent

corporate employees or individual owners and family members. As a
result, the

passengers are far more familiar with the layout of the individual
aircraft and the

associated emergency equipment and exits.

6\. Custom interior layouts, furnishings, fixtures, furniture, cabinets,
galleys, etc. are

more representative of "board room" type furnishings, than airline style
interiors.

Seat pitch and aisle widths are typically substantially more spacious
than an

airline interior.

The airplane that is the subject of this petition is a privately owned
and operated airplane

being completed with a VIP executive interior. The FAA has previously
granted

exemptions, for transport category airplanes operated in private use,
that are similar to

those requested in this petition for exemption.

The seating configuration being installed in the subject airplane will
provide seating for

maximum 34 passengers. The certified passenger capacity for this
airplane is 315.

The passenger count of the subject airplane therefore represents less
than 11 % of the capacity allowed for this airplane.

**Information to Support Grant of Exemption -- Interior Doors**

Private areas, such as bedrooms and conference rooms, are essential to
the

owner/operator of private, not-for-hire airplanes. For such
arrangements, privacy can

only be provided by means of doors, and, therefore, an exemption is
needed to allow full

use of airplane capabilities without compromising safety for those
onboard. All

passengers are equally important, wherever they are located.

The proposed interior configuration installs interior doors between
passenger compartments along the egress path at the following locations:

 Aft Lounge -- Opening located between approximately Sta. 1580 This is
a "pocket" type door across the main cabin longitudinal aisle that
translates laterally to open and close.

 Massage Room -- Opening located at approximately Sta. 853 to Sta. 905.
This is a "double swing" type door across the main cabin longitudinal
aisle that

translates laterally to open and close.

The risk for occupants due to the installation of interior doors between
passenger

compartments should be considered acceptable for the following reasons:

 Each door between passenger compartments will be frangible.

 Each door between passenger compartments will provide remote
indication of door

position to the flight crew. Appropriate procedures and limitations will
be provided

to ensure that the doors are in the proper position for takeoff and
landing.

 Each door between passenger compartments will have dual means to
retain it in the

open position for taxi, takeoff and landing, each of which will be
capable of

withstanding the inertia loads specified in 14 CFR 25.561.

 Anydoor installed across a longitudinal aisle will translate laterally
to open and

close.

 The airplane will be operated under 14 CFR part 91 or part 125 and
will not be

operated for hire or offered for common carriage.

**Evaluation of Public Interest**

The approval of this Petition for Exemption would demonstrate the FAA's
willingness to

deal with the issues involved with this Exemption, and would be in the
public interest for

the following reasons:

 Given the proliferation of executive configured transport category
airplanes

currently taking place, and anticipated in the near future, this type of
exemption

will enable US manufacturers of transport category airplanes greater
flexibility to

effectively compete in this expanding market.

 Additional sales of US manufactured airplanes outside of the
traditional airline

market, and completion of many of them at US owned and operated aircraft

completion centers, will serve to increase the profitability of these
manufacturers

and their supplying/supporting companies.

 Stability and improved financial performance of these US companies
gives

greater job stability to the workers employed by the companies, causing
a

stabilizing influence to the greater US economy, due to the consumer
spending

activities associated with stable workers.

 Improved financial performance of US owned and operated corporations,
and

increased workforce stability, translates into continued and improved
local, state,

and federal tax revenues, which in turn adds to the stability of the
total US

economy.

 Improved financial performance allows US corporations to continue to
invest in

research and development allowing the US to maintain or improve its
competitive

position in the world economy.

 A large number of these types of airplanes will probably be sold to
"offshore"

clients, improving the US balance of trade.

 There is no degradation of safety involved with this request and
therefore no

detrimental impact to the public at large.

**Petition for Exemption**

In consideration of the foregoing discussion, Future Jet Aerodesign LLC
, on behalf of the STC applicant Las Vegas Sands Corporation petitions
for exemption from the following portions of 14 CFR Part 25 for the
subject L1011-385-3

airplane:

§25.813(e), at Amendment 25-32, as interior doors are installed between

passenger compartments.

Future Jet Aerodesign LLC on behalf of the STC applicant Las Vegas Sands
Corporation, respectfully requests the FAA's consideration of the
foregoing petition.

**Request for Waiver of Publication**

WAI believes that good cause exists, in accordance with 14 CFR §11.87,
to waive the

publication and comment requirements of 14 CFR part 11, §11.85. In
particular, we feel

that the intent of this petition, the reasons presented, and the relief
requested are

effectively identical to those of exemptions previously granted by the
FAA. Therefore,

this request will not set a precedent. Accordingly, FJA requests a
waiver for the

publication and comment period, so that the airplane can be delivered
back to the

customer without delay.

**Name and Address of the Petitioner**

Future Jet Aerodesign, LLC

c/o Mr. Leonard G. Olson, Managing DER

36549 State Highway 64

Wills Point, TX 75169

Office Tel: (903) 873-4477

Mobile Tel: (214) 649-5005

Fax: (903) 873-4479