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: 11 April 2014

Subject:

Petition for Exemption under FAR 11.63 for 14 CFR §25.813(e) – to allow the 

installation of electrically actuated doors between passenger compartments.

References:

1) ODA-955292-NE Project No. ODA-GED-P039

2) Type Certificate Data Sheet A16WE 

General Background:

The proposed exemption is specifically for the installation of electrically 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 

exemptions, i.e. Boeing 737-700IGW (6820 & 6820A), Boeing 737-800 (7609), 

that already exist and SFAR 109 for Transport Category Airplanes that provides

guidance for the installation of doors between compartments but does not 

adequately address the installation of electronically operated 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-P039. There are (4)

electronic pocket doors planned for this Executive, private use, interior 

installation.
Petition for Exemption FAR §25.813(e) 11 April 2014

To allow the installation of electrical actuation of doors between passenger compartments

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Exemption Requested:

The petitioner requests that to be exempted from FAR 25.813(e) states “No door 

may be installed in any partition between passenger compartments”.

The 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 PSCP 

as the means of compliance when the installation requires electronically operated 

doors.

Occupant Safety Considerations Related to FAR 25.813(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. 25.813(e), PATS proposes the following safety features to ensure that the 

addition of electrical actuation does not adversely affect emergency egress 

capability or pose any risk of physical injury to the passengers or crew:

(a) The pocket door is a typical mechanical door with the addition of an

electrical actuator and a control box. The system will be equipped with 

operation switches on each 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 (powered) or not, it is possible stow or 

deploy it manually.

(b) In case the door blade is blocked during deploying, its motion automatically

stops and or retracts into the closed (stowed) position if powered. It is also

possible to override the powered system and stow it manually. 

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

to:

1. Allow 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. Following an extremely improbable pressurization system failure resulting

in an airplane decompression event, the door frangibility will act as a blowout panel.

2., In 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. 
Petition for Exemption FAR §25.813(e) 11 April 2014

To allow the installation of electrical actuation of doors between passenger compartments

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(c) Each door between any passenger seat and any exit 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)

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

use and will be operated under a foreign authority. The Flight Manual 

Supplement will have a limitation and a placard, in the area of the Airworthiness 

Certificate holder at the entrance to 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 Boeing Business Jets 737-

700IGW, 737-800, and 737-900, would suffer without exemptions of this nature. 

The placement of interior doors 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 exemptions of this nature have been granted numerous times for 

similar installations.
Petition for Exemption FAR §25.813(e) 11 April 2014

To allow the installation of electrical actuation of doors between passenger compartments

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Conclusions:

The Federal Aviation Regulations did not consider the situation of executive use

larger single aisle Transport Category airplanes. 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 alternative 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