UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

Exemption No. 11182 

Dassault Aviation Regulatory Docket No. FAA-2014-1007 

for an exemption from§ 25.1447(c)(1) of 

Title 14, Code of Federal Regulations 

GRANT OF EXEMPTION 

By letter dated October 23, 2014, , Mr. Remy Lamelot, Certification Manager, Dassault Aviation, 

54 Avenue Marcel Dassault- BP 24, 33701 Merignac Cedex, France, petitioned the Federal 

Aviation Administration (FAA) for an exemption from the requirements of§ 25.1447(c)(1) of 

Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted would permit relief 

from the requirement for passenger oxygen masks to be automatically presented before the cabinpressure altitude exceeds 15,000 feet for the Falcon 7X series airplanes. 

The petitioner requests relief from the following regulation(s): 

Section 25.1447(c)(1) requires, in pertinent part, that there must be an oxygen-dispensing 

unit connected to oxygen-supply terminals immediately available to each occupant, 

wherever seated. If certification for operation above 30,000 feet is requested, the 

dispensing units providing the required oxygen flow must be automatically presented to 

the occupants before the cabin-pressure altitude exceeds 15,000 feet, and the crew must 

be provided with a manual means to make the dispensing units immediately available in 

the event of failure of the automatic system. 

The petitioner supports its request with the following information: 

This section quotes the relevant information from the petitioner's request, with minor edits for 

clarity. The complete petition is available at the Department of Transportation's Federal Docket 

Management System, on the Internet at http://regulations.gov, in Docket No. FAA-2014-1007. 
Summary 

In accordance with the provisions of 14 CFR 11.81, Dassault Aviation respectfully 

petitions for a permanent exemption from § 25.144 7 (c)( 1) to allow the installation of a 

passenger oxygen system which, when operating into or out of an airfield with a pressure 

altitude greater than 14,000 ft but lesser than 15,000 ft, ensures the automatic presentation 

of oxygen dispensing units to occupants before cabin altitude exceeds 16,000, rather than 

15,000 ft, as required per§ 25.1447(c)(l). 

Background/Extent of Relief Sought 

The Falcon 7X Series is designed to meet the requirements of 14 CFR part 25 for 

transport category aircraft. These rules were written at a time when all airfields 

accessible to such aircraft were located below 14,000 ft. As a result, the aircraft cabin 

altitude was never supposed to reach 15,000 ft under normal circumstances, and having 

an oxygen system that automatically presents oxygen masks when cabin altitude reaches 

15,000 feet was an adequate compromise between occupants' safety and the conduct of 

operations on high-altitude airfields. 

The Falcon 7X is already certified for high landing field elevation (LFE) operations, with 

a maximum airfield pressure altitude of 14,000 ft. However, a few airfields with an LFE 

between 14,000 ft and 15,000 ft above mean sea level exist in the Chinese regions of 

Tibet and Sichuan. This means that under standard atmospheric conditions, pressure 

altitude on these airfields will be between 14,000 ft and 15,000 ft. These airfields are 

accessible to transport category aircraft. 

When operating out of or into such airfields, the cabin altitude may thus reach values 

close to or even equal to 15,000 ft before takeoff or after landing. This could result in 

unwanted presentation of oxygen masks and the need for a maintenance operation in 

order to store them back into their boxes, plus a possible cancellation or delay of the 

planned flight. 

The change proposed is designed to maintain an equivalent level of safety while 

minimizing the possibility of such unwanted deployment of oxygen masks. 

The current design of the passenger oxygen system has one pressure altitude setpoint of 

14,500 feet± 500ft (accounting for sensor tolerance), thus ensuring automatic 

presentation of oxygen masks before cabin altitude reaches 15,000 ft. 

In the proposed design, a second setpoint of 15,500 ft, ± 500 ft, is implemented in the 

oxygen system. The cabin pressure control system automatically commands the oxygen 

system to use this second setpoint when aircraft pressure altitude is below 24,800 ft and 

one of the following conditions is true: 

• Aircraft is on ground and aircraft pressure altitude is above 14,000 ft, OR 

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• Aircraft is in climb and the pressure altitude at take off was above 14,000 ft, OR 

• Aircraft is in descent and the selected LFE is above 14,000 ft. 

Under all other conditions, the mask deployment setpoint remains at the current value, 

i.e., 14,500 ft, ± 500 ft. 

The manual mask deployment control ("Override" position of the oxygen control 

rotactor) is unchanged and remains available at any moment whatever the setpoint value. 

Note that the maximum cabin pressure altitude reached in flight under normal operating 

conditions is not modified compared to current certified design, which was found 

compliant with§ 25.841(a). When takeoff airfield pressure altitude is between 14,000 ft 

and 15,000 ft, the cabin pressure control system will pre-pressurize the aircraft before 

takeoff and set the cabin pressure altitude to 13,542 ft (same value as today when 

operating from a 14,000 ft airfield). During climb, the cabin pressure control system 

(CPCS) will let the cabin pressure increase, ensuring that a cabin altitude not more than 

7,950 ft is reached before the aircraft climbs above 25,000 ft pressure altitude. This 

behavior is identical to current design already certified for operations up to 14,000 ft 

airfield altitude. 

As a result, the setpoint for the cabin high altitude warning CAS [crew alerting system] 

message is unchanged and remains set at 14,200 ft for high LFE operations. The high 

cabin altitude warning is inhibited on ground in order to avoid nuisance warnings. The 

high cabin altitude warning setpoint is reset to the normal value of 8,000 ft when the 

aircraft altitude climbs above 24,800 ft. This feature (changing the setpoint ofthe cabin 

altitude warning message) is already part ofthe existing design for high LFE operations. 

Conversely, when LFE is between 14,000 ft and 15,000 ft, the CPCS will keep cabin 

pressure altitude below 7,950 ft until the aircraft descends below 24,800 ft pressure 

altitude. At that point, the high altitude warning threshold will be shifted from 8,000 ft to 

14,200 ft, and the CPCS will let the cabin pressure altitude increase until it reaches 

13,542 ft. The CPCS will keep the aircraft pressurized at 13,542 ft cabin pressure 

altitude until landing is completed. This behavior is identical to the existing aircraft when 

landing at an airfield with LFE equal to 14,000 ft. 

As a result, this proposed design change does not degrade the level of safety as far as 

§ 25.841(a) is concerned. It will be demonstrated by system safety analysis that cabin 

pressure altitude always remains below 15,000 ft under any reasonably probable failure 

condition. 

Public Interest 

Dassault Aviation performs the completion and interior furbishing of most ofthe aircraft 

it produces in Dassault Falcon Jet manufacturing plant of Little Rock, AR. Falcon 

aircraft are fitted with many products such as avionics, auxiliary power units, 

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environmental control systems, from several suppliers based in the United States. The 

exemption will directly impact the utility of the Falcon 7X for high-altitude operations 

and will allow fulfilling an explicit request from customers for such capability, thus 

having a direct effect on sales. These extra sales will benefit the economy in all 

communities where Dassault Falcon Jet and its suppliers are located, which is in the 

public interest. 

Reasons why granting the exemption will not adversely affect safety 

The safety features described above will ensure the avoidance of unwanted oxygen mask 

deployment during operations on high altitude airports, while still providing for automatic 

deployment in case of cabin depressurization or lack of pressurization (the highest 

possible cabin altitude for mask deployment being 16,000 ft), and for manual deployment 

in case of failure of the automatic mode. 

It will be demonstrated by system safety analysis that proposed design for pressurization 

and passenger oxygen systems meets or exceeds all failure probability requirements. 

The exemption requested would thus have no adverse impact on current level of safety 

for the Falcon 7X aircraft. 

Additional Information 

In the scope of this petition, Dassault Aviation takes benefit from previous grant of 

exemptions issued by FAA dealing with the setting of oxygen mask deployment setpoint 

above 15,000 ft for high airfield operations. Please note that FAA has previously granted 

such exemptions to several models with much larger passenger capacity than the Dassault 

Falcon 7X Series. 

Exempt. Issue Expir. FAA Disp. Regulation Petitioner Aircraft 

No Date Date Office 

6076 04/26/1995 (NoExpire) (NA) Granted 25.841 (a) The Boeing B757 

25.1447(c)(l) Company 

6994 09/16/ 1999 (NoExpire) (NA) Partially 25.1447(c)(l) Airbus A319, 

Granted Industrie A320, 

A321 

8668 12/02/2005 (NoExpire) (NA) Granted 25.1447(c)(l) The Boeing B737 

Company 

9801 12/ 1212008 (No Expire) (NA) Granted 25.1447(c)(l) The Boeing B787 

Company 

10044 04/01 /20 I 0 (NoExpire) (NA) Granted 25.1447(c)(l) Gulfstream GIV-X 

Aerospace GV-SP 

Corporation 

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Request for waiver from publication and comments 

Considering the above listed exemptions, it is Dassault Aviation's opinion that the 

requested exemption is identical to exemptions granted previously and that granting this 

petition would not set a precedent. As a result, Dassault Aviation respectfully requests 

that action on this petition should not be delayed by publication and comment procedures. 

Exercise of exemption privileges and operation outside US 

Considering the multitude of countries in which Falcon 7X Series are sold and operated, 

it is very likely that this exemption should be recognized by some other countries usually 

agreeing with FAA position. Moreover, all the existing airfields with altitude higher than 

14,000 ft are located outside the United States. Dassault Aviation thus requests extension 

ofthis exemption outside the United States. 

Federal Register publication 

The FAA has determined that good cause exists for waiving the requirement for Federal Register 

publication for public comment because the request is identical in all material respects to 

previously granted exemptions; the exemption, if granted, would not set a precedent; and any 

delay in acting on this petition would be detrimental to Dassault Aviation. 

The FAA's analysis 

The FAA considers that granting this petition is in the public interest for the reasons stated by the 

petitioner, and because this exemption is effectively identical to previously granted exemptions. 

The petitioner requests an exemption for the Dassault Aviation Falcon 7X series airplanes and 

seeks relief from the requirement of§ 25.144 7 (c)( 1 ), which states that oxygen-dispensing 

equipment for occupants must be automatically presented before the cabin-pressure altitude 

reaches 15,000 feet. The petitioner's current design of the passenger oxygen system has only one 

pressure altitude set point of 14,500 feet, ± 500 feet (accounting for sensor tolerance), thus 

ensuring automatic presentation of oxygen masks before cabin altitude reaches 15,000 feet. The 

petitioner's proposed design of the passenger oxygen system provides for a second pressure 

altitude set point of 15,500 feet, ± 500 feet. For operation ofthe Dassault Aviation Falcon 7X 

series airplane into and out of an airport with a landing field above 14,000 feet, the cabin 

pressure control system automatically commands the passenger oxygen system to use this second 

set point when aircraft pressure altitude is below 24,800 feet and any one of the following 

conditions is true: 

• Airplane is on the ground and the airplane pressure altitude is above 14,000 feet; or 

• Airplane is in climb and the pressure altitude at takeoff was above 14,000 feet; or 

• Airplane is in descent and the selected landing field elevation is above 14,000 feet. 

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Under all other conditions, the passenger oxygen mask deployment set point remains at the 

original value (i.e., 14,500 feet, ± 500 feet). 

The FAA's decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. §§ 40113 and 44701 delegated to me 

by the Administrator, I grant Dassault Aviation an exemption from the requirement of 

14 CFR 25.1447(c)(1) that the passenger oxygen equipment be automatically presented before 

the cabin pressure altitude exceeds 15,000 feet. For Dassault Model 7X series airplanes, this 

grant of exemption will permit passenger oxygen masks to be automatically presented before the 

cabin pressure altitude exceeds 16,000 feet when operating into and out of airports with altitudes 

above 14,000 feet. This exemption is granted to the extent necessary to reduce the occurrence of 

inadvertent deployment of oxygen masks. 

Issued in Renton, Washington, on FEB 1 9 2015 

John 

~~~ P. Piccola, Jr. 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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