Gulfstream 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

, , June 11, 2015 

~ ,, G-ODA-15-0454 

Page 1 of 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) of Savannah, Georgia has received FAA 

Type Certificate No. T00015AT for the Gulfstream model GVI (Transport Category) on 

September 7, 2012 under FAA Project NumberTC8700AT-T. The GVI cabin interior relies 

on the installation of various doors to 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 of public interest to support a request for 

exemption to the requirements §25.813(e). 

Issue Statement and Petition Request 

14 CFR 25.813(e), Amendment 25-116- States in part that 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). 

Currently, the GVI design incorporates two doors between the passenger seating areas and 

the main entry door allowed per Exemption No. 10188 from 14 CFR 25.813(e) (See Figure 1, 

Current Acoustic and Forward Vestibule Door Arrangement). 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 a forward vestibule door and is offered on certain interior 

configurations. An example of one such configuration is depicted below. Its purpose is to 

provide: 

1) Isolation of the crew rest facilities in accordance with guidance per AC 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.com 
ACOUSTIC DOOR 

Figure 1 

Current Acoustic and Forward Vestibule Door Arrangement 

A proposed change to the GVI interior design incorporates mid-cabin pocket doors with a 

design identical to the Forward Vestibule Door currently certified for the GVI aircraft (See 

Figure 2, Proposed Mid-Cabin Pocket Door Arrangement). This door is offered as an option 

on certain interior configurations. An example of one such configuration is depicted below. Its 

purpose is to provide: 

1) Private cabin sections for conducting business meetings in flight. 

2) Isolation of additional crew rest facilities in accordance with guidance per AC 121-31, 

providing improved quality of the sound levels and light levels. 

OVER-WING EMERGENCY EXITS 

OVER-WING EMERGENCY EXITS 

Figure 2 

Proposed Mid-Cabin Pocket Door Arrangement 
In accordance with the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 14 

CFR 25.813(e) for installation of the mid-cabin interior door. This would allow the GVI 

aircraft to improve the quality of the sound levels and light levels in an aft crew sleeping 

facility in accordance with guidance per AC 121-31 as well as providing private areas for 

business. Gulfstream proposes that specific design features, combined with the unique 

configuration of the GVI, will provide an overall level of safety beyond that intended when the 

FAA promulgated Amendment 25-116. Based on these features 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 of doors between 

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

14 CFR 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 14 CFR 121.310(f)(6), to prohibit these doors in airplanes manufactured after 

November 27, 2006, and operated under 14 CFR Part 121. However, at that time the FAA 

chose not to amend 14 CFR Part 135 or 14 CFR Part 91. As a result, aircraft certified prior 

to Amendment 25-116, and operating under other than 14 CFR 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 of the interior door to open. 

In June 08, 2009, the FAA released Special Federal Aviation Regulation (SFAR) No. 109 

allowing the installation of interior doors and listing restrictions as well as criteria needed to 

be met in order to present an acceptable level of safety for Part 91 operations. Mid-cabin 

pocket doors are currently installed on some interior configurations of the GVI aircraft for Part 

91 operations based on the criteria and restrictions listed in SFAR No. 109. 

Exemptions as well as Equivalent Level of Safety (ELOS) have been granted by the FAA to 

numerous business jets models allowing the installation of mid-cabin doors. Gulfstream 

recognizes that most of these 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 door within the passenger cabin 

as the lavatory/vanity is occupied during taxi, takeoff and landing. 
For the GVI aircraft, Gulfstream believes that it is possible to provide a level of safety 

consistent with the intent of the 14 CFR 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 passengers' ability to 1) effectively identify the exit and 2) egress the aircraft. 

Factors Supporting the Petition 

The Mid-Cabin pocket door will be designed with features identical to the Forward Vestibule 

Door currently certified for the GVI aircraft. The following design features of the GVI MidCabin Door will ensure that the passenger's ability to effectively identify the exit is not 

diminished: 

• The door 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 door will therefore not 

adversely affect passenger recognition of the Main Entry Door (MED) or over wing 

emergency exits. 

• The MED is the only door available to enter the aircraft. Consequently, the MED 

location is inherently established for all passengers upon boarding. 

• 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 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. 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 locator sign 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 of the GVI interior door and passenger cabin will ensure that 

the passenger's ability to effectively egress the aircraft is not diminished by ensuring that the 

door will be open and latched for taxi, takeoff and landing, without requiring passenger or 

crew action. These features are currently present on the Forward Vestibule Door certified for 

the GVI aircraft. 

• The door will be designed to automatically open (stow) and latch when the airplane has 

been configured for landing (gear down or flaps 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 door will have dual means of restrain in the open position, each of which is capable 

of reacting 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 for 
landing (gear down or flaps down) and will remain activated until the airplane has 

returned to an airborne flight configuration (landing gear and flaps both fully retracted). 

• With the door in the open (stowed) position, the critical forward emergency landing 

loads will not cause the door to deploy and block access to the main entry door or overwing emergency exits. 

• The operation of the door to the closed (deployed) position will require manual 

activation. The door will be designed so that it can only be closed (deployed) when the 

gear and flaps are fully retracted (airborne configuration), or for ground maintenance 

activity. 

• The door will be designed so that for any failure of the closing/latching mechanism, the 

door will default to the open (stowed) position. 

• The door will be placarded to be open for taxi, takeoff, and landing (TT&L). Normal 

door operation by passengers is manual, including opening the door for taxi, 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 Amber CAS message will alert the pilots if any of the internal doors (acoustic door, 

forward vestibule or mid-cabin pocket door) is not in the properly open (stowed) 

position for TT&L. 

• In accordance with 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 demonstrate that the probability of failure to egress through the Main 

Entry Door (MED), including the probability of failure of the interior doors, will meet the 

criteria for a failure scenario classified as Major. This will be accomplished by design 

review of the mid-cabin door installation as compared to the currently certified Forward 

Vestibule Door which included conducting a quantitative analysis that showed the 

probability of this scenario to be less than 10-5 per flight hour. This hazard criticality is 

based on 14 CFR 25.783(b)(2). 

• This door will be designed to be frangible from either side of the door. In case of an 

emergency, this design will allow a 5th percentile female to create an aperture large 

enough to allow for a 95th percentile male to escape. Compliance to this requirement 

will be accomplished by design review of the new mid-cabin pocket door compared to 

the currently certified mid-cabin pocket door. 

• 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 require single file 

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 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 (MED) (See Figure 3, GVI Emergency 

Egress Routes). 
Additional GVI Design Considerations: 

• Gulfstream demonstrated the over wing exit pair to be equivalent to the size and 

number of exits required by 14 CFR 25.807(g) through an Equivalent Level of Safety 

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 of a required Type Ill exit through an Equivalent Level of Safety Finding to 14 CFR 

25.813(c)(2) and addressed FAA Policy number ANM-115-08-02. This was 

documented in issue papers C-7, and C-8. Interior doors are opened automatically on 

landing configuration, in a manner that crew procedures or placards are not relied upon 

to ensure awareness of, as well as access to the over wing 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 of the overwing emergency exits as required by 14 CFR 25.807(g). The forward entry door is not 

utilized under this scenario for emergency evacuation and applicable placards are 

provided. The Airplane Flight Manual defines proper procedures for exiting the aircraft 

in these conditions. 

• Many of the passengers typically utilizing Executive Class aircraft are frequent 

passengers who are familiar with the operation of the interior features and locations of 

emergency exits. 

---. Passenger Emergency Exit 

• • • • • • • • • Crew Emergency Exit 

Figure 3 

GVI Emergency Egress Routes 

Effect of the Exemption on Safety 

Acceptance of the proposed GVI design will ensure that a level of safety consistent with the 

intent of the regulation has been provided. The design of the 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 GVI 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 

Amendment 25-116 to 14 CFR Part 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 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 Gulfstream for the GVI raises the 

current level of safety to that envisioned by Amendment 25-116 to Part 25. 

Issue of Public Interest 

Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services 

the world's most technologically advanced business jet aircraft to an international market. 

Gulfstream leadership in the global business jet 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 of suppliers located throughout the United 

States. Gulfstream competes for new business all over the world. This exemption will 

directly impact the 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 other 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 of 

the job market as well as the growth of the 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 GVI. This will restrict advancements in safety 

introduced by Gulfstream with the GVI, 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 aircraft safety. The advancement of aircraft safety is in the interest of 

the public. 

Operation Outside of the United States 

Per 14 CFR 11.81 (h) Gulfstream requests consideration be given to extending this 

exemption for operation outside of the United States. Gulfstream aircraft are routinely 

registered and operated outside of the United States. Granting this extension of privileges 

will allow for operations based within foreign countries, including EU member countries, 

having bilateral agreements with the United States accepting FAA 14 CFR Part 25 as their 

airworthiness standards for transport category aircraft. Gulfstream believes that limiting this 

exemption to use within the U.S. would put unfair restrictions on the marketability of this 

aircraft. 

Conclusion 

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

that would allow for 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 

passenger safety 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