# Gulfstream

U.S. Department ofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 New JerseyAvenue, SE Washington, DC 20590 ,, June 11, 2015

**~** ,, G-ODA-15-0454 Page 1of 8

Subject: Petition for FAA Exemption for Installation of Doors Between Passenger Compartments in the Gulfstream Aerospace Model GVI Airplanes

Dear Sir (Madam):
Gulfstream Aerospace Corporation (Gulfstream) ofSavannah, Georgia has received FAA Type Certificate No. T00015ATforthe Gulfstream model GVI (Transport Category) on September7, 2012 under FAA Project NumberTC8700AT-T. The GVI cabin interior relies on the installation ofvarious doorsto provide certain amenities and configuration options that have become the standard for Executive Class aircraft. This petition for exemption presents the issues and specific petition request and details ofpublic interestto support a requestfor exemption to the requirements §25.813(e).
Issue Statement and Petition Request
14 CFR 25.813(e), Amendment 25-116- States in partthat no door may be installed between any passengerseat that is occupiable fortakeoffand landing and any passenger emergency exit, such thatthe door crosses any egress path (including aisles, crossaisles and passageways). Currently, the GVI design incorporates two doors between the passengerseating areas and the main entry doorallowed per Exemption No. 10188from 14 CFR 25.813(e) (See Figure 1, CurrentAcoustic and Forward Vestibule DoorArrangement). One door is an acoustic door provided between the forward vestibule and the main entry door. Its purpose is to maintain an acceptable acoustic level in the passenger cabin and pilot compartment and is standard equipment. The second door is aforward vestibule doorand is offered on certain interior configurations. An example ofone such configuration is depicted below. Its purpose is to provide: 1) Isolation ofthe crew restfacilities in accordancewith guidance perAC 121-31. 2) Separation between passenger and crew areas including the galley, crew rest, and cockpit.

P,O, Box 2206, Savannah, Georgia 31402-2206 o Telephone (912) 965-3000 "gulfstream.comACOUSTIC DOOR

Figure 1 CurrentAcoustic and Forward Vestibule DoorArrangement
A proposed change to the GVI interior design incorporates mid-cabin pocket doors with a design identical tothe Forward Vestibule Doorcurrently certified forthe GVI aircraft (See Figure 2, Proposed Mid-Cabin Pocket DoorArrangement). This door is offered as an option on certain interior configurations. An example ofone such configuration is depicted below. Its purpose is to provide: 1) Private cabin sectionsfor conducting business meetings in flight. 2) Isolation ofadditional crew rest facilities in accordance with guidance perAC 121-31, providing improved quality ofthe sound levels and light levels.

OVER-WING EMERGENCY EXITS

OVER-WING EMERGENCY EXITS Figure 2 Proposed Mid-Cabin Pocket DoorArrangementIn accordance with the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 14 CFR 25.813(e) for installation ofthe mid-cabin interiordoor. This would allowthe GVI aircraft to improvethe quality ofthe sound levels and light levels in an aft crew sleeping facility in accordance with guidance perAC 121-31 as well as providing private areas for business. Gulfstream proposes that specific design features, combined with the unique configuration ofthe GVI, will provide an overall level ofsafety beyond that intended when the FAA promulgated Amendment 25-116. Based on thesefeatures Gulfstream proposes that this exemption be applicable to both private use aircraft (14 CFR Part 91) and those used for hire (14 CFR Part 135). The information provided herein will outline this rationale. 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 or aft of passenger compartments. As such it continued to be common practice for business class aircraft to install doors which isolate the passengerseating areas from crewwork areas. These doors lower noise levels in the passenger cabin and create effective work environments. On October27, 2004, Amendments 25-116 and 121-306, titled "Miscellaneous Cabin Safety Changes," were published in the Federal Register. This revised 14 CFR 25.813(e) to restrict the installation of any interior door between a passengerseat and any emergency exit, effectively restricting the use ofall interior doors. In addition, the FAA revised 14 CFR 121.310(f)(6), to prohibit these doors in airplanes manufactured after November27, 2006, and operated under 14 CFR Part 121. However, atthat time the FAA chose notto amend 14 CFR Part 135 or 14 CFR Part 91. As a result, aircraft certified prior to Amendment 25-116, and operating under otherthan 14 CFR Part 121, are permitted to incorporate these types ofdoor installations.
When Amendment 25-116 was issued, the FAA noted thatthis change was incorporated due to concerns over passengers' ability to 1) recognize that an exit exists beyond an interior doorforward oraft ofthe passenger compartment; and 2) reach the exit beyond the door in the event offailure ofthe interiordoorto open.
In June 08, 2009, the FAA released Special Federal Aviation Regulation (SFAR) No. 109 allowing the installation ofinterior doors and listing restrictions as well as criteria needed to be met in orderto present an acceptable level ofsafety for Part 91 operations. Mid-cabin pocket doors are currently installed on some interior configurations ofthe GVI aircraft for Part 91 operations based on the criteria and restrictions listed in SFAR No. 109. Exemptions as well as Equivalent Level ofSafety (ELOS) have been granted by the FAAto numerous businessjets models allowing the installation of mid-cabin doors. Gulfstream recognizes that most ofthese exemptions and ELOS were limited to Part 91 operations. However, there are examples in which such operational limitation was not required, such as the ELOS for aft lavatory door in the Cessna Citation 680 (ELOS TC2548WI-T-AG-2) which also creates two passenger compartments separated by a doorwithin the passenger cabin as the lavatory/vanity is occupied during taxi, takeoffand landing.Forthe GVI aircraft, Gulfstream believes that it is possible to provide a level ofsafety consistentwith the intent ofthe 14 CFR Part 25 regulations while allowing for installation of certain interiordoors. This will be accomplished by incorporating specific design features that provide an acceptable level ofsafety. Thesefeatures will ensure the designwill not diminish a passengers' ability to 1) effectively identifythe exit and 2) egress the aircraft.
Factors Supporting the Petition
The Mid-Cabin pocket doorwill be designed with features identical to the Forward Vestibule Door currently certified forthe GVI aircraft. The following designfeatures ofthe GVI MidCabin Doorwill ensure that the passenger's ability to effectively identifythe exit is not diminished:

• The doorwill 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 interiordoorwill therefore not adversely affect passenger recognition ofthe Main Entry Door (MED) oroverwing emergency exits.

• The MED is the only dooravailable to enterthe aircraft. Consequently, the MED location is inherently established for all passengers upon boarding.

• The overwing emergency exits are optimally located in the passengercompartment, in clear and obvious view, and are in an area of high passengerdensity. These exits will also be indicated via locatorsigns and markers, as well as emergency escape path lighting. This heightened passengerawareness and ease of identification will increase the likelihood of passengers utilizing the overwing exits provided in the cabin versus defaulting to the entry door. Reference Figure 3, GVI Emergency Egress Routes.

• Emergency exit locator and marking signs and emergency lighting in accordance with 14 CFR 25.811 and 25.812 will be provided. An Exit locator sign will be installed on the mid-cabin door bulkhead. This exit locatorsign will be visible when the pocket door is closed and when the pocket door is open, eliminating any confusion as to where the emergency exit is located.
The following design features ofthe GVI interior door and passenger cabin will ensure that the passenger's ability to effectively egressthe aircraft is not diminished by ensuring thatthe doorwill be open and latched fortaxi, takeoffand landing, without requiring passengeror crew action. These features are currently present on the Forward Vestibule Doorcertified for the GVI aircraft.

• The doorwill be designed to automatically open (stow) and latch when the airplane has been configured for landing (gear down orflaps down) and will remain open and latched until the airplane has returned to an airborne flight configuration (landing gear and flaps both fully retracted).

• The doorwill have dual means of restrain in the open position, each ofwhich is capable ofreacting all emergency landing loads specified under 14 CFR 25.561(b). This dual hold-open feature is automatically activated when the airplane has been configured forlanding (gear down orflaps down) and will remain activated until the airplane has returned to an airborne flight configuration (landing gearand flaps both fully retracted).

• With the door in the open (stowed) position, the critical forward emergency landing loads will not cause the doorto deploy and block access to the main entry doororoverwing emergency exits.

• The operation ofthe doorto the closed (deployed) position will require manual activation. The doorwill be designed so that it can only be closed (deployed) when the gear and flaps are fully retracted (airborne configuration), orforground maintenance activity.

• The doorwill be designed so that for any failure ofthe closing/latching mechanism, the doorwill defaultto the open (stowed) position.

• The doorwill be placarded to be open fortaxi, takeoff, and landing (TT&L). Normal dooroperation by passengers is manual, including opening the doorfortaxi, takeoff and landing. However, the automatic opening and latching feature will ensure a clear egress paths should the door not have been stowed manually.

• An AmberCAS messagewill alert the pilots ifany ofthe internal doors (acoustic door, forward vestibule or mid-cabin pocket door) is not in the properly open (stowed) position forTT&L.

• In accordancewith the Gulfstream approach to compliance with 14 CFR 25.1309, the failure to egress through any individual emergency exit is classified as Major. Gulfstream will demonstratethat the probability offailure to egress through the Main Entry Door (MED), including the probability offailure ofthe interiordoors, will meetthe criteria for a failure scenario classified as Major. This will be accomplished by design review ofthe mid-cabin door installation as compared to the currently certified Forward Vestibule Doorwhich included conducting a quantitative analysis that showed the probability ofthis scenario to be less than 10-5 perflight hour. This hazard criticality is based on 14 CFR 25.783(b)(2).

• This doorwill be designed to be frangible from either side ofthe door. In case ofan emergency, this design will allow a 5th percentile female to create an aperture large enough to allowfor a 95th percentile male to escape. Complianceto this requirement will be accomplished by design review ofthe new mid-cabin pocket doorcompared to the currently certified mid-cabin pocket door.

• The overwing emergency exits have been designed so that they can all be deployed at the sametime to provide multiple, redundant egress paths forescape from the passenger compartment. Each ofthe four overwing emergency exits require singlefile egress and have been sized to provide substantial egress area. This reduces the problems caused by passenger panic and congestion typical in single, larger exits. Smooth, effective egress ofpassengers through the existing overwing exits will also increasethe likelihood ofpassengers utilizing the overwing exits as opposed to seeking alternate escape routes further away (MED) (See Figure 3, GVI Emergency Egress Routes).

### Additional GVI Design Considerations:

• Gulfstream demonstrated the overwing exit pairto be equivalent to the size and numberofexits required by 14 CFR 25.807(g) through an Equivalent Level ofSafety Finding to 14 CFR 25.807 documented in issue paper C-1.

• Gulfstream demonstrated that the GVI exit pair provides equivalent egress capability to that ofa required Type Ill exitthrough an Equivalent Level ofSafety Finding to 14 CFR 25.813(c)(2) and addressed FAA Policy numberANM-115-08-02. This was documented in issue papers C-7, and C-8. Interior doors are opened automatically on landing configuration, in a mannerthat crew procedures or placards are not relied upon to ensure awareness of, as well as access to the overwing emergency exists in accordance with 14 CFR 25.809(b) and 25.813(c)(2)(ii).

• Compliance with 14 CFR 25.807(i) for ditching is shown through the use ofthe overwing emergency exits as required by 14 CFR 25.807(g). Theforward entry door is not utilized underthis scenario for emergency evacuation and applicable placards are provided. TheAirplane Flight Manual defines proper procedures for exiting the aircraft in these conditions.

• Many ofthe passengerstypically utilizing Executive Class aircraft are frequent passengers who are familiarwith the operation ofthe interiorfeatures and locations of emergency exits.

---. Passenger Emergency Exit

••••••••• Crew Emergency Exit Figure 3 GVI Emergency Egress Routes 

### Effectofthe Exemption on Safety Acceptance ofthe proposed GVI 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 clearegress path. This combined with other characteristics ofthe GVI such as redundancy ofemergency exits, large area overwing exits and optimal location of emergency exits, will provide a level ofsafety exceeding that currently prescribed under Amendment 25-116 to 14 CFR Part 25.Although the current operational requirements under Parts 91 and 135forthis type ofaircraft have not been amended to correspond to the Part 25 restriction, Gulfstream acknowledges that the Part 25 change is an important enhancementto the level ofsafety offered by newly manufactured aircraft. The design criteria proposed by Gulfstream forthe GVI raises the current level ofsafety to that envisioned byAmendment 25-116 to Part 25.
Issue of Public Interest
Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the world's mosttechnologically advanced businessjet aircraft to an international market. Gulfstream leadership in the global businessjet market is due to the efforts of its nearly eleven 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 ofsuppliers located throughoutthe United States. Gulfstream competes for new business all overthe world. This exemption will directly impactthe options to be offered to prospective customers who prefer a cabin configuration that provides private areas for business as well as additional crew rest areas for long-haul Part 135 operations, thereby having a direct effect on GVI sales. The ability to provide additional cabin separations is being requested by prospective aircraft operators who compare the GVI with products of European and otherforeign aircraft manufacturers. The inability to provide such features will ultimately cause a reduction in perspective sales. The manufacture, completion, and support ofGulfstream aircraftwould aid in the stabilization of thejob market as well as the growth ofthe American economy, which is in the interest ofthe public.
Since customers desire to have these interiordoors, they may optfor aircraft designedto an earlier certification basis, in lieu ofthe GVI. Thiswill restrict advancements in safety introduced by Gulfstream with the GVI, not only in the areas ofcabin safety, butthroughout the airplane. This is counterproductive to both Gulfstream and the FAA's goal of continuous improvement in overall aircraft safety. The advancement ofaircraft safety is in the interest of the public. Operation Outside ofthe United States
Per 14 CFR 11.81(h) Gulfstream requests consideration be given to extending this exemption for operation outside ofthe United States. Gulfstream aircraft are routinely registered and operated outside ofthe United States. Granting this extension of privileges will allowfor operations based within foreign countries, including EU membercountries, having bilateral agreements with the United States accepting FAA 14 CFR Part 25 as their airworthiness standards fortransport category aircraft. Gulfstream believes that limiting this exemption to use within the U.S. would put unfair restrictions on the marketability ofthis aircraft.
Conclusion
Gulfstream believes thatthe above arguments favor an exemption from 14 CFR 25.813(e) thatwould allowfor installation of mid-cabin interior doors on the GVI aircraft. In addition, Gulfstream believes that an exemption is in the public interest and will provide a level of passengersafety consistent with the current Part 25 regulations.Should you have any questions or require further clarification, please contact me at (912) 395-8575.

Respectfully submi ed,

Eme P (Kip) Wiltse ODA Enterprise Program Administrator Gulfstream Aerospace Corporation