Presented to:

The United States of America Department of Transportation

Federal Aviation Administration

Manager Transport Aircraft Directorate

1601 Lind Avenue SW Renton, Washington 98055

- 4056

Petitioner:
William J Ertle, II, ODA Operations Manager / STC ODA Administrator

PATS Aircraft Systems

21652 Nanticoke Avenue Georgetown, DE 19947 (302) 253

- 6180
William.Ertle@PATSAIRCRAFT.COM

Date : 1 1 April 2014

Subject : Pe tition for Exemption under FAR 1 1.63 for 14 CFR § 25 .813 (e)

– to allow the

installatio n of electrical ly actuated doors between passenger compartments

.

Re ferences : 1) ODA

- 955292

- NE Project No. ODA

- GED

- P 03 9 2) Type Certificate Data Sheet A16WE

General Background :

The proposed exempt ion is sp ecifically for the installation of e lect rically operated

Pocket Doors in Executive

, VIP or Head of State interiors installed and designated “private, not

- for

- hire

, not

- for

- common carriage ”

. There are TCDS

exemp tions

, i.e. Boeing 737

- 700IGW ( 6820 & 6820A )

, Boeing 737

- 800 ( 7609 )

, that already exist and SFAR 109 for Transport Category Airplanes that provide s guidance for the installation of doors between compartments but do es n ot adequately address the installat ion of e lectronically o perated doors between
compartments.

The project aircraft and initial use of this exemption will be in a Boeing 737

- 700IGW S/N 38854 under PATS ODA project ODA

- GED

- P0 39. There ar e ( 4 ) electronic po cket doors planned for this Executive, p rivate u se, interior

installation

.P etition for E xemption FAR § 25.813(e) 11 April 2014

T o allow the installation of electrical actuation of doors between passenger compartments

2 of 4 Exemption Requested :

The petitioner requests t hat to be exempted from FAR 25. 8 13(e ) states “No door may be installed i n any partition between passenger compartments ”

.

T he petitioner also requests that this exemption be used as a means of compliance for future installation of this type in other transport category airplanes

. PATS propose to reference the use of this exemption in future P SCP as the means of compliance when the installation requires electronically operated

doors.

Occupant Safety Considerations Related to FAR 2 5. 813 (e ) :

1. The door actuation system is designed to maintain the same level of safety as that afforded by a manual pocket door installation

. In lieu of the requirements of

Sec. 2 5.813(e), PATS proposes the following safety features to ensure that the

addition of electrical actuati on does not adversely affect emergency egress capability or pose any risk of physical injury to the passengers or crew: (a) The p ocket door is a typical mechanical door with the addition of an electrical actuator and a control box. The system will be equipp ed with operation switches on e ach side of the door

. Aside from the electrical components, the door behaves as a typical mechanical door, i.e., whether the electrical mechanism is operational ( p owered) or not, it is possible stow or deploy it manually.

(b) In case the door blade is blocked during d eploying, its motion automatically stops and or retracts in to the closed (stowed) position if powered

. I t is also possible to override the powered system an d stow it manually

. (c) The door will have a frangibility feature which is designed for a dual purpose

to :

1

. A llow passengers to pass through in the event a extreme condition should result in a door being closed or partially closed after an accident, the door is frangible in both directions and provides a means to get through the door to reach the exit(s).

2

. F ollowing a n e xtremely improbable pressurization system failure resulting in an airplane decompression event

, t he door frangibility will act as a blow

out panel

.

2

. , I n addition to the above, the following guidance found in SFAR 109 will also apply :

(a) Each door between any passenger seat, occupiable for taxi, takeoff, and landing, and any emergency exit must have a means to signal to the flightcrew, at the flightdeck, that the door is in the open position for taxi, takeoff and landing.

(b) Appropriate procedures/limitations must be established to ensure that any such door is in the open configuration for takeoff and landing.P etition for E xemption FAR § 25.813(e) 11 April 2014

T o allow the installation of electrical actuation of doors between passenger compartments

3 of 4 (c) Each door between any passenger seat and any ex it must have dual means to retain it in the open position, each of which is capable of reacting the inertia loads specified in Sec. 25.561.

(d) Doors installed across a longitudinal aisle must translate laterally to open and close, e.g., pocket doors.

(e ) Each door between any passenger seat and any exit must be frangible in

either direction.

(f) Each door between any passenger seat and any exit must be operable from either side, and if a locking mechanism is installed, it must be capable of being unlocked from either side without the use of special tools.

Operation of Aircraft outside the United States

- § 11.81(h)

M any times the aircraft being modified are for Executive, YIP or Head of State

use a nd will be operated unde r a foreign authority

. T h e Flight Manual Supplement will have a limitation and a placard, in the area of the Airworthiness

Certificate holder at the entrance t o the flightdeck stating that “ Operations involving the carriage of persons or property for compensation or hire are prohibited''.

Public Interest :

Sales of center

- aisle air transport jets, such as the Boei ng Business Jets 737

- 700IGW

, 737

- 800, and 737

- 900, would suffer without exemptions of this nature

. The placement of interior d oors is quite significant to the owner/operator of the airplane. The flexibility to partition the airplane into individual rooms, such as private meeting rooms or bedrooms, is paramount to an acceptable interior. The availability of private meeting rooms and bedrooms is essential. . Granting this exemption would allow heads of state and executives to conduct their business and create more jobs for the public.

Granting this exemption would be in the public interest because US aircraft

manufacturers could sell more large aircraft outside the typical airline market.

Publication of Petition :

PATS respectfully request that the petition be processed and that the publication and the comment procedures be waived in accordance with 14 CFR 11.29 and

11 .87 since e xemptions of this nature have been granted numerous times for

similar installations

.P etition for E xemption FAR § 25.813(e) 11 April 2014

T o allow the installation of electrical actuation of doors between passenger compartments

4 of 4 Conclusions :

The Federal Aviation Regulations d id not consider the situation of executive use larger single aisle Transport Category airplane s

. The FAA has published Special Requirements for Private Use Transport Category Airplanes, SFAR No. 109 (74 FR 21533, May 8, 2009), which, significantly reduced the need for case

- by

- case review of individual petitions for exemption for private

- use airplanes but did not

cover this situation.

.
PATS have proposed alternati ve features that provide the occupants an acceptable level of safety for the intended use of the airplane.

Thank you for your time and consideration to this request.

Respectfully Submitted

William J. Ertle II