UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the 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 of Federal Regulations 

GRANT OF EXEMPTION 

By letter dated January 30,2015, Mr. Robert Nilson, 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) of Title 14, Code of Federal 

Regulations (14 CFR). This exemption, if granted, would permit the installation of interior doors 

between passenger seats, which are occupiable during takeoff and landing, and the forward left 

hand emergency exit on Gulfstream Model GVII-G500 airplanes. The petitioner requests that the 

exemption be applicable to both private use aircraft (14 CFR part 91) and those used for hire 

(14 CFR part 135). 

The petitioner requests relief from the following regulation: 

Section 25.813(e) at Amendment 25-128 - No door may be installed between any passenger seat 

that is occupiable for takeoff and 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 of Transportation's Federal Docket 

Management System, on the Internet at http://regulations.gov, in Docket No. FAA-2015-0230. 

Supportive Information 

At Amendment 25-1 , 14 CFR 25.813( e) was revised to restrict installation of doors 

between passenger compartments. This did not restrict the installation of doors forward 

and aft of passenger compartments. As such, it continued to be common practice for 

business class aircraft to install doors which isolate the passenger seating areas from crew 
working 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 of any interior door between a passenger 

seat and any emergency exit, effectively restricting the use of all interior doors. In 

addition, the FAA revised§ 121.310(±)(6) to prohibit these doors in airplanes 

manufactured after November 27, 2006, and operated under part 121. However, at that 

time, the FAA chose not to amend part 13 5 or part 91. As a result, aircraft certified prior 

to Amendment 25-116, and operating under other than part 121, are permitted to 

incorporate these types of door 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 of the passenger compartment, and 2) reach the exit beyond 

the door in the event of failure 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 of the part 25 regulations while allowing for installation 

of certain interior doors. This will be accomplished by incorporating specific design 

features that provide an acceptable level of safety. 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 of the GVII-G500 interior doors are identical to the ones described in 

Exemption 10188 for the GVI and the following characteristics of the 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 of the interior doors will 

therefore not adversely affect the passenger recognition of the main entry door 

(MED). 

• The doors will only be installed forward of the 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 of safety 

(ELOS) memo AT5177 AT-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 of high passenger 

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density. These exits will also be indicated via locator signs and markers, as well 

as emergency escape path lighting. This heightened passenger awareness and ease 

of identification will increase the likelihood of passengers utilizing the over wing 

exits provided in the cabin versus defaulting to the entry door. 

The following design features of the 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 or flaps down). 

• The operation of the 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 of any failure of the 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 of failure to egress through the 

MED, including the probability of failure ofboth interior doors, will meet the 

criteria for a failure scenario classified as Major. This will include conducting a 

quantitative analysis that shows the probability of this 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 in the event that manual operation has not 

occurred. 

• An amber Caution Advisory System (CAS) message will alert pilots if an 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 passenger compartment. Each of the four over wing emergency exits 

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require single file egress and have been sized to provide a substantial egress area. 

This reduces the problems caused by passenger panic and congestion typical in 

single, larger exits. Smooth, effective egress of passengers through the existing 

over wing exits will also increase the likelihood of passengers 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 of the door. In case 

of an emergency, this design will allow a 5111 percentile female to create an 

aperture large enough for a 95111 percentile male to escape. 

Additional GVII Design Considerations: 

• The main entry door is also the flight crew emergency exit. In the event of an 

emergency evacuation, a trained crew member will be responsible to ensure egress 

is maintained through this passageway to the MED. 

• Through ELOS TC8700AT-T-C-1 to§ 25.807(i)(2), Gulfstream has addressed 

FAA Policy Number ANM-115-08-02, and has demonstrated that the GVII exit 

pair will provide equivalent egress capability to that of a required Type III exit. 

• The GVII-G500 emergency exits configuration is identical to the GVI emergency 

exits covered under the ELOS TC8700A T-T -C-1 and Gulfstream has 

demonstrated that the over wing exit pair was equivalent to the size and number 

of exits required by§ 25.807(g). The GVII-G500 will comply with§ 25.807(g) 

for required number of emergency exits through the over wing exits and 

Gulfstream has demonstrated that the MED was an emergency exit in excess of 

the minimum required on the left hand side of the aircraft. 

• Compliance with§ 25.807(i)(2) for ditching will be shown through the use of the 

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 of the Exemption on Safety 

Acceptance ofthe proposed GVII-G500 design will ensure that a level of safety 

consistent with the intent of the regulation has been provided. The design ofthe proposed 

interior doors will ensure the same level of safety for cabin egress as is required for any 

emergency exit and will provide a clear egress path. This, combined with other 

characteristics of the GVII such as redundancy of emergency exits, large area over-wing 

exits, and optimal location of emergency exits, will provide a level of safety exceeding 

that currently prescribed under part 25. 

Although the current operational requirements under parts 91 and 13 5 for this type of 

aircraft have not been amended to correspond to the part 25 restriction, Gulfstream 

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acknowledges that the part 25 change is an important enhancement to the level of safety 

offered by newly manufactured aircraft. The design criteria proposed by Gulfstrearn for 

the GVII raises the current level of safety to that envisioned by Amendment 25-128. 

Issue of Public Interest 

Gulfstrearn Aerospace Corporation designs, develops, manufactures, markets, and 

services the world's most technologically advanced business jet aircraft to an 

international market. Gulfstream's leadership position in the global business jet market is 

due to the efforts of its 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 impact the cabin and flight deck acoustics 

and the effectiveness of flight 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 of foreign aircraft manufacturers. The 

inability to provide such features will ultimately cause a reduction in perspective sales. 

The manufacture, completion, and support of Gulfstream aircraft would aid in the 

stabilization ofthejob market as well as the growth ofthe American economy, which is 

in the interest of the public. 

Since customers desire to have these interior doors, they may opt for aircraft designed to 

an earlier certification basis, in lieu of the GVII-G500. This will restrict advancements in 

safety introduced by Gulfstream with the GVII-G500, not only in the areas of cabin 

safety, but throughout the airplane. This is counterproductive to both Gulfstream and the 

FAA's goal of continuous improvement in overall safety. The advancement of aircraft 

safety is in the interest of the 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 of door installations. 

Regardless of EASA requirements, per 14 CFR 11.81 (h), Gulfstream requests that 

consideration be given to extending this exemption for operation outside of the 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 FAA part 25 as their airworthiness standard 

for transport category aircraft. Gulfstream believes that limiting this exemption to use 

within the United States would put unfair restrictions on the marketability of this aircraft. 

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Conclusion 

Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.813(e) 

that would allow for installation of certain interior doors on the GVII aircraft. In 

addition, Gulfstream believes that an exemption is in the public interest and will provide 

a level of passenger safety consistent with the current part 25 regulations. 

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 Gulfstream Aerospace Corporation. 

The FAA's analysis 

Following accident experience in the 1960's, the FAA amended part 25 to prohibit the 

installation of doors "between passenger 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 of accident investigations, that this door could be 

detrimental in evacuation of passengers, who tended not to recognize that there was an exit 

beyond the door, even if it 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 of the door. For example, a door could be 

installed across the main passenger aisle at the end of a cabin. The regulations only required that 

the door be open for takeoff and landing. It is now considered undesirable to permit the 

installation of a door between any passenger and an exit. Either through omission or mechanical 

failure, such a door could become jammed prior to the need for an emergency evacuation, 

preventing or delaying persons from evacuating, and resulting in fatalities or injuries that would 

not have occurred if the door were not present. The hazards associated with a jammed door are 

still present whether or not passengers are on both sides of the door, and the recognition factor 

has not been mitigated. Either scenario could result in the same consequences - failure of some 

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 of the fuselage. The GVII will 

instead have a Type I entry door on the forward left side, and two paired over-wing emergency 

exits on each side of the 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-inch rectangular 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 

of 3 5.18 inches. 

By comparison, a Type III exit, as defined by § 25.807 (which is the regulatory requirement for 

an aircraft of this passenger capacity), is a rectangular opening not less than 20 by 36 inches, with 

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its long axis oriented vertically. The Type III exit must have a step-up inside the airplane of not 

more than 20 inches and, if located over the wing, a step-down of not more than 27 inches. 

Although the GVII over-wing exits do not meet the dimensional requirements of a 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 of safety (ELOS) to allow installation of the nonstandard size over-wing exits in lieu of a 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 of the aircraft. The FAA disagrees with 

Gulfstream's statement that the MED is in excess of the minimum because the MED is one of the 

compensating factors used to support issuance of the ELOS to allow installation ofthe nonstandard size over-wing exits in lieu of a true Type III exit on the right-hand side of the aircraft. 

However, the FAA acknowledges that the aircraft has five exits in lieu of the required minimum 

two, as described above. The four over-wing exits provide a compensating factor to allow 

issuance of an ELOS to § 25.807(g). Each pair of over-wing exits must be shown to be 

equivalent to a single Type III exit. The substantiation of the over-wing exits must account for 

any obstructions of the exits as a result of other 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 with the interior doors installed. 

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 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 

or the flaps are not fully retracted and must remain open until the landing gear and flaps 

are both fully retracted. 

2. The doors must only be installed forward of the 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 AT5177 AT-T-C-1. 

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4. The doors must 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. 

5. The doors must be designed so that for any failure of the closing/latching mechanism, the 

doors will default to the open (stowed) position. 

6. Gulfstream must substantiate that the probability of failure to egress through the MED, 

including the probability of failure of both 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 shown to 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 if an 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 of the 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 must be easily broken/removed by the occupant when the 

door(s) is jammed and a placard must be installed on each side of the door(s) providing 

instruction on the operation of the frangibility feature ofthe door(s). A demonstration is 

required to show that a 5th percentile female can break through or remove the door from 

both sides of the door(s). The 5th percentile female test subject should be subjected to a 

typical preflight briefing and then may only use the information on the placard for 

determining how to operate the frangibility feature of the door(s). The demonstration 

must be conducted in accordance with an FAA approved test plan on a conformed 

installation. Additionally, the applicant must show that a 95th percentile male subject can 

exit through the door(s) opening created by the 5th percentile female. 

Issued in Renton, Washington, on MAY 1 5 2015 

~~ Michael Kaszycki 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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