UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION RENTON, WASHINGTON 98057-3356

In the matter ofthe petition of Exemption No. 11610

Gulfstream Aerospace Corporation Regulatory Docket No. FAA-2015-0230 for an exemption from§ 25.813(e) of Title 14, Code ofFederal Regulations

GRANT OF EXEMPTION By letter dated January 30,2015, Mr. RobertNilson, Director, Gulfstream Aerospace Corporation, P.O. Box 2206, Savannah, Georgia, petitioned the Federal Aviation Administration (FAA) for an exemption from the requirements of§ 25

.813(e) ofTitle 14, Code ofFederal Regulations (14 CFR). This exemption, ifgranted, would permit the installation ofinterior doors between passenger seats, which are occupiable during takeoffand landing, and the forward left hand emergency exit on Gulfstream Model GVII-G500 airplanes. The petitioner requests thatthe exemption be applicable to both private use aircraft (14 CFRpart 91) and those used for hire (14 CFRpart 135). The petitioner requests relieffrom the following regulation: Section 25.813(e) at Amendment 25-128

- No door may be installed between any passenger seat that is occupiable for takeoffand landing and any passenger emergency exit, such that the door crosses any egress path (including aisles, crossaisles, and passageways). 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 ofTransportation's Federal Docket Management System, onthe Internet at http://regulations.gov, in DocketNo. FAA-2015-0230. Supportive Information At Amendment 25-1 , 14 CFR 25.813(e) was revised to restrict installation ofdoors between passenger compartments
. This did not restrict the installation ofdoors forward and aft ofpassenger compartments. As such, it continued to be common practice for business class aircraft to install doors which isolate the passenger seating areas from crewworking areas. These doors lower noise levels in the passenger cabin and create effective work environments. On October 27,2004, Amendments 25-116 and 121-306, titled "Miscellaneous Cabin Safety Changes," were published in the Federal Register. This revised § 25.813(e) to restrict the installation ofany interior door between a passenger seat and any emergency exit, effectively restricting the use ofall interior doors. In addition, the FAA revised§ 121.310(±)(6) to prohibitthese doors in airplanes manufactured afterNovember 27, 2006, and operated under part 121. However, at that time, the FAA chose not to amend part 135 orpart 91. As a result, aircraft certified prior to Amendment 25-116, and operating under otherthan part 121, are permitted to incorporate these types ofdoor installations. When Amendment 25-116 was issued, the FAA noted that this change was incorporated due to concerns over passengers' ability to 1) recognize that an exit exists beyond an interior door forward or aft ofthe passenger compartment, and 2) reach the exitbeyond the door in the event offailure ofthe interior door to open. For the GVII-G500 aircraft, Gulfstream believes that it is possible to provide a level of safety consistent with the intent ofthe part 25 regulations while allowing for installation ofcertain interior doors. This will be accomplished by incorporating specific design features that provide an acceptable level ofsafety. These features will ensure the design will not diminish a passenger's ability to 1) effectively identify the exit, and 2) egress the aircraft. Factors Supporting the Petition The design features ofthe GVII-G500 interior doors are identical to the ones described in Exemption 10188 for the GVI and the following characteristics ofthe GVII-G500 interior doors and passenger cabin will ensure that the passengers' ability to effectively identify the exit is not diminished:

• The doors will be designed to automatically open (stow) based on the airplane being configured for landing and will remain open until the airplane has returned to an airborne flight configuration. The installation ofthe interior doors will therefore not adversely affect the passenger recognition ofthe main entry door (MED).

• The doors will only be installed forward ofthe passenger seating area and between passenger seats and the MED. The MED is the only door available to enter the aircraft and its location is inherently established for all passengers upon boarding.

• Emergency exit locator, marking signs, and emergency lighting will be provided. Gulfstream will comply with the criteria defined in equivalent level ofsafety (ELOS) memo AT5177AT-T-C-1 (ELOS to §§ 25

.811(d) and 25

.812(b)).

• The over wing emergency exits are optimally located in the passenger compartment, in clear and obvious view, and are in an area ofhigh passenger 2density. These exits will also be indicated via locator signs and markers, as well as emergency escape path lighting. This heightened passenger awareness and ease ofidentification will increase the likelihood ofpassengers utilizing the over wing exits provided in the cabin versus defaulting to the entry door. The following design features ofthe GVII-G500 interior doors and passenger cabin will ensure that the passenger's ability to effectively egress the aircraft is not diminished by ensuring that the doors will be open for taxi, take-off, and landing, without requiring passenger or crew action.

• The doors will be designed to automatically open (stow) when the airplane has been configured for landing (gear down orflaps down).

• The operation ofthe door to be closed (deployed position) will require manual activation. The doors will be designed so that they can only be closed (deployed) when the gear and flaps are fully retracted (airborne configuration), or for ground maintenance activity

.
• The doors will be designed so that, in case ofany failure ofthe closing/latching mechanism, they will default to the open (stowed) position.

• In accordance with Gulfstream's approach to compliance with§ 25.1309, the failure to egress through any individual emergency exit is classified as Major. Gulfstream will demonstrate that the probability offailure to egress through the MED, including the probability offailure ofboth interior doors, will meetthe criteria for a failure scenario classified as Major. This will include conducting a quantitative analysis that shows the probability ofthis scenario to be less than 

### 10-5 per flight hour. This hazard criticality is based on § 25.783(b)(2).

• The doors will have a hold-open feature that will be shown to react all emergency landing loads specified under§ 25.561(b).

• The doors will be placarded to be open and latched for taxi, take-off , and landing (TT&L)

. Manual operation to the open (stowed) position is the primary means by which the doors should be open and stowed for TT&L. The automatic opening feature will ensure egress paths inthe eventthat manual operation has not occurred.

• An amber Caution Advisory System (CAS) message will alertpilots ifan interior door is not in the proper open (stowed) position for TT&L.

• With the doors in the open (stowed) position, the critical forward emergency landing loads will not cause door to deploy and block access to the MED

.
• The over wing emergency exits have been designed so that they can all be deployed at the same time to provide multiple, redundant egress paths for escape from the passengercompartment. Each ofthe four overwing emergency exits 3require single file egress and have been sized to provide a substantial egress area. This reduces the problems caused bypassengerpanic and congestion typical in single, larger exits

. Smooth, effective egress ofpassengers through the existing over wing exits will also increase the likelihood ofpassengers utilizing the over wing exits as opposed to seeking alternate escape routes further away from the MED.

• Both doors will be designed to be frangible from either side ofthe door. In case ofan emergency, this design will allow a 5111 percentile female to create an aperture large enough for a 95 111 percentile male to escape. Additional GVII Design Considerations:

• The main entry door is also the flight crewemergency exit. In the event ofan emergency evacuation, a trained crew member will be responsible to ensure egress is maintained through this passageway to the MED.

• ThroughELOS TC8700AT-T-C-1 to§ 25.807(i)(2), Gulfstream has addressed FAA PolicyNumber ANM-115-08-02, and has demonstrated that the GVII exit pairwill provide equivalent egress capability to that ofa required Type III exit.

• The GVII-G500 emergency exits configuration is identical to the GVI emergency exits covered under the ELOS TC8700AT-T-C-1 and Gulfstream has demonstrated that the over wing exitpair was equivalent to the size and number ofexits required by§ 25.807(g). The GVII-G500 will comply with§ 25.807(g) for required number ofemergency exits through the over wing exits and Gulfstream has demonstrated that the MED was an emergency exit in excess of the minimum required onthe left hand side ofthe aircraft.

• Compliance with§ 25.807(i)(2) for ditching will be shown through the use ofthe over wing emergency exits as required by§ 25.807(g). The forward entry door will not be utilized under this scenario for emergency evacuation and applicable placards will be provided. The airplane flight manual will define proper procedures for exiting the aircraft in these conditions. 

### Effect ofthe Exemption on Safety Acceptance oftheproposed GVII-G500 design will ensure that a level ofsafety consistentwith the intent ofthe regulation has been provided. The design ofthe proposed interior doors will ensure the same level ofsafety for cabin egress as is required for any emergency exit and will provide a clear egress path. This, combined with other characteristics ofthe GVII such as redundancy ofemergency exits, large area over-wing exits, and optimal location ofemergency exits, will provide a level ofsafety exceeding that currently prescribed underpart 25. Although the current operational requirements under parts 91 and 135 for this type of aircraft have not been amended to correspond to the part 25 restriction, Gulfstream 4acknowledges that the part 25 change is an important enhancementto the level ofsafety offered by newly manufactured aircraft. The design criteriaproposed by Gulfstrearn for the GVII raises the current level ofsafety to that envisioned by Amendment 25-128. 

### Issue ofPublic Interest Gulfstrearn Aerospace Corporation designs, develops, manufactures, markets, and services the world's most technologically advanced businessjetaircraft to an international market. Gulfstream's leadership position in the global businessjetmarket is due to the efforts ofits nearly ten thousand employees in the manufacturing plants, completion centers, and service centers across North America. The corporation utilizes numerous products, such as avionics and environmental control systems, from scores of suppliers located throughout the United States. Gulfstream competes for new business all over the world. This exemption will directly impactthe cabin and flight deck acoustics and the effectiveness offlight crew sleeping facility design, thereby having a direct effect on GVII-G500 sales. The ability to provide an additional acoustical barrier from external noise for the flight deck and cabin are being requested by prospective aircraft operators who compare the GVII-G500 with products offoreign aircraft manufacturers. The inability to provide such features will ultimately cause a reduction in perspective sales. The manufacture, completion, and support ofGulfstream aircraft would aid in the stabilization ofthejob market as well as the growth ofthe American economy, which is in the interest ofthe public. Since customers desire to have these interior doors, they may opt for aircraft designed to an earlier certification basis, in lieu ofthe GVII-G500. This will restrict advancements in safety introduced by Gulfstream with the GVII-G500, not only in the areas ofcabin safety, but throughout the airplane. This is counterproductive to both Gulfstream and the FAA's goal ofcontinuous improvement in overall safety. The advancement ofaircraft safety is in the interest ofthe public. 

### Operation Outside the United States The European Aviation Safety Agency (EASA) Certification Standard (CS) 25.813 regulation is not currently harmonized with 14 CFR 25.813 and does not restrict these types ofdoor installations. Regardless ofEASA requirements, per 14 CFR 11.81(h), Gulfstream requests that consideration be given to extending this exemption for operation outside ofthe United States and projections are the same for the Model GVII. Granting this extension of privileges will allow for operations based within foreign countries, having bilateral agreements with the United States accepting FAApart 25 as their airworthiness standard for transport category aircraft. Gulfstream believes that limiting this exemption to use within the United States would putunfair restrictions on the marketability ofthis aircraft.



### 5Conclusion Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.813(e) that would allow for installation ofcertain interior doors onthe GVII aircraft. In addition, Gulfstream believes that an exemption is in the public interest and will provide a level ofpassenger safety consistent with the current part 25 regulations. Federal Register publication The FAAhas determined that good cause exists for waiving the requirement for Federal Register publication for public commentbecause the request is identical in all material respects to previously granted exemptions; the exemption, ifgranted, would not set a precedent; and any delay in acting on this petition would be detrimental to Gulfstream Aerospace Corporation. The FAA's analysis Following accident experience in the 1960's,the FAA amended part 25 to prohibitthe installation ofdoors "betweenpassenger compartments" at Amendment 25-15. At the time of the amendment, it was common practice to divide the first class and tourist class cabins with a solid door. We determined, in the course ofaccident investigations, that this door could be detrimental in evacuation ofpassengers, who tended not to recognize that there was an exit beyond the door, even ifit were the closest available

. The resulting regulatory change was geared specifically at preventing this occurrence. However, the regulation was worded such that doors may be installed between passengers and exits,provided that passengers are not on both sides ofthe door. For example, a door could be installed across the main passenger aisle at the end ofa cabin. The regulations only required that the doorbe open for takeoffand landing. Itis now considered undesirable to permitthe installation ofa door between anypassenger and an exit. Eitherthrough omission or mechanical failure, such a door could becomejammedprior to the need for an emergency evacuation, preventing or delaying persons from evacuating, and resulting in fatalities or injuries that would not have occurred ifthe door were not present. The hazards associated with ajammed door are still present whether or not passengers are on both sides ofthe door, and the recognition factor has not been mitigated. Either scenario could result in the same consequences - failure ofsome passengers to evacuate the airplane

. The Gulfstream GVII will have a maximum passenger capacity of 19. Part 25 requires such an airplane to have at least one Type III or larger exit in each side ofthe fuselage. The GVII will instead have a Type I entry door onthe forward left side, and two paired over-wing emergency exits oneach side ofthe aircraft (in a manner similar to previous Gulfstream airplanes) so as to maintain a family relationship with previous Gulfstream models. Each GVII over-wing exit will provide a 26-inch by 32-inchrectangular opening with its long axis oriented parallel to the floor. The GVII over-wing exit will have a step-up distance of 25.03 inches and a step-down distance of35.18 inches. By comparison, a Type III exit, as defined by § 25.807 (which is the regulatory requirement for an aircraft ofthis passenger capacity), is a rectangular opening not less than 20 by 36 inches, with 6its long axis oriented vertically. The Type III exit must have a step-up inside the airplane ofnot more than 20 inches and, iflocated over the wing, a step-down ofnot more than 27 inches. Although the GVII over-wing exits do not meet the dimensional requirements ofa Type III exit, each exit is larger in area (797 square inches) than a Type III exit (678 square inches). Gulfstream has been issued an equivalent level ofsafety (ELOS) to allow installation ofthe nonstandard size over-wing exits in lieu ofa true Type III exit. The applicant states that the GVII aircraft complies with§ 25.807(g) for required number of emergency exits through the over-wing exits and that the MED is an emergency exit in excess of the minimum required on the left-hand side ofthe aircraft. The FAA disagrees with Gulfstream's statementthat the MED is in excess ofthe minimum becausethe MED is one ofthe compensating factors used to support issuance ofthe ELOS to allow installation ofthe nonstandard size over-wing exits in lieu ofa true Type III exit on the right-hand side ofthe aircraft. However, the FAA acknowledges that the aircraft has five exits in lieu ofthe required minimum two, as described above. The four over-wing exits provide a compensating factor to allow issuance ofan ELOS to § 25.807(g). Each pair ofover-wing exits must be shown to be equivalentto a single Type III exit. The substantiation ofthe over-wing exits must account for any obstructions ofthe exits as a result ofother ELOS activity related to the exits. Section 25.807(h) requires that the MED be readily accessible. Gulfstream has proposed several features to ensure the MED will remain readily accessible withthe interior doors installed. The FAA's decision In consideration ofthe foregoing, I find that a grant ofexemption is in the public interest. Therefore, pursuantto the authority contained in 49 U.S.C. §§ 40113 and 44701 delegated to me by the Administrator, I grant Gulfstream Aerospace Corporation an exemption from 14 CFR 25.813(e). The exemption is granted to the extent necessary to allow Gulfstream Aerospace Corporation to install interior doors on Gulfstream Model GVII airplanes. This exemption is subject to the following conditions:
1. The doors must be designed to automatically open (stow) when the landing gear is down orthe flaps are not fully retracted and mustremain open until the landing gear and flaps are both fully retracted.
2. The doors must only be installed forward ofthe passenger seating area and between the passenger seats and the main entry door (MED). 3. Emergency exit locator, marking signs, and emergency lighting must meet the criteria defined in ELOS AT5177AT-T-C-1.

74. The doors mustbe designed so that they can onlybe closed (deployed) whenthe gear and flaps are fully retracted (airborne configuration), orfor ground maintenance activity. 5. The doors mustbe designed so that for any failure ofthe closing/latching mechanism, the doors will default to the open (stowed) position. 

### 6. Gulfstream must substantiatethat the probability offailure to egress through the MED, including the probability offailure ofboth interior doors, to be less than 1 

## o-5 per flight hour. This hazard criticality is based on§ 25.783(b)(2).
7. The doors must have a hold-open feature that will be shownto react to all emergency landing loads specified under§ 25.561(b).
8. The doors must be placarded to be open and latched for taxi, takeoff, and landing (TT&L).
9. An amber CAS message must be installed that will alert the pilots ifan interior door is not in the proper open (stowed) position for TT&L.
10. With the doors in the open (stowed) position, the critical forward emergency landing loads must not cause either door to deploy and block access to the MED. 11. The doors must be designed to be frangible from either side ofthe door. The design must allow a 5th percentile female to create an aperture large enough to allow a 95th percentile male to escape. The door mustbe easily broken/removed by the occupantwhenthe door(s) isjammed and a placard mustbe installed on each side ofthe door(s) providing instruction on the operation ofthe frangibility feature ofthe door(s). A demonstration is required to showthat a 5th percentile female canbreakthrough orremove the door from both sides ofthe door(s). The 5th percentile female test subject should be subjected to a typical preflight briefing and then may only use the information onthe placard for determining how to operate the frangibility feature ofthe door(s)

. The demonstration must be conducted in accordance with an FAA approved test plan on a conformed installation. Additionally, the applicant must showthat a 95th percentile male subject can exitthrough the door(s) opening created by the 5th percentile female.

Issued in Renton, Washington, on 

## MAY 1 52015



# ~~ Michael Kaszycki Acting Manager, Transport Airplane Directorate Aircraft Certification Service 

### 8