Gulfstream 

A GENERAL DYNAMICS COMPANY 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE. 

Washington , DC 20590 

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August14,2015 

G-ODA-15-0657 

Subject: Request for Exemption from Section 25.809(a) of Title 14 Code of Federal 

Regulations, Overwing Emergency Exits Viewing Means 

FAA Project No: TC-01-201 0-0024 

Attachment: Petition for Exemption - Overwing Emergency Exits Viewing Means, Model GVII 

Dear Sirs: 

In accordance with 14 CFR Part 11, Gulfstream Aerospace Corporation requests consideration of the 

enclosed petition for exemption. This petition is being submitted to relieve the Gulfstream GVII model 

aircraft from full compliance with 14 CRF 25.809(a) at amendment 25-116, Emergency exit arrangement, 

for the requirement to provide a means to view the areas of evacuee ground contact from the overwing 

exit window. 

If you have any questions or need additional information please contact: 

Robert Glasscock 

Gulfstream Aerospace Corporation 

P.O. Box 2206, M/S R-02 

Savannah, GA 31402-2206 

robert.g lasscock@gulfstream .com 

(912) 965-6817 

Respectfully, 

Robert Glasscock 

Director ODA Programs 

Gulfstream Aerospace Corporation 

Cc: N. Berryman, ACE-120A (via email) 

C. Underwood, ACE-120A (via email) 

B. Whitton, Gulfstream ODA (via email) 

R. Nilson, Gulfstream ODA (via email) 

PO. Box 2206 • Savannah, GA 31402-2206 USA • Telephone (912) 965-3000 • gulfstream.com 
G-ODA-15-0657, Attachment 

August 14, 2015 

Petition for Permanent Exemption 

Gulfstream Aerospace Corporation 

Overwing Emergency Exits 

Means for Viewing Likely Areas of Evacuee Ground Contact 

Model GVII-G500 

Relieffrom section 14 CFR Part 25.809(a) Arndt. 25-116 

Gulfstream Aerospace Corporation (Gulfstream) of Savannah, Georgia has submitted 

application to the FAA's Atlanta Aircraft Certification Office for type certification of a new, twinengine, transport category aircraft to be known as the Gulfstream model GVII-G500. Project 

number TC-01-201 0-0024 has been assigned to this effort. 

14 CFR 25.809(a), Amendment 25-116 states that each emergency exit, including each flight 

crew emergency exit, must be a movable door or hatch in the external walls of the fuselage, 

allowing an unobstructed opening to the outside. In addition, each emergency exit must have 

means to permit viewing of the conditions outside the exit when the exit is closed. The viewing 

means may be on or adjacent to the exit provided no obstructions exist between the exit and the 

viewing means. Means must also be provided to permit viewing of the likely areas of evacuee 

ground contact. The likely areas of evacuee ground contact must be viewable during all lighting 

conditions with the landing gear extended as well as in all conditions of landing gear collapse. 

The GVII-500 emergency exit configuration consists of the Type I Main Entry Door, along with 

two pairs of overwing emergency exits which will be demonstrated to provide equivalent or 

better egress flow rate as a single Type Ill overwing exit. These overwing emergency exits are 

identical in size and shape to those certified on the GVI. The GVII-G500 will have a maximum 

seating capacity of 19 passengers and the overwing exits are centrally located in the passenger 

cabin. The exits house large oval windows which provide a full panoramic view of the wing 

surface as well as the ground area just beyond the point of occupant first contact. 

Partial relief is being sought for the GVII-G500 and its derivatives, from the requirements of 14 

CFR 25.809(a) for the overwing exits since this outside viewing means does not permit viewing 

of the likely area of the evacuee ground contact prior to exit opening. Relief is necessary since 

literal compliance with the rule, would, at a minimum, require extensive design changes to the 

airplane (such as movement of the exits forward or complete redesign of the exit configuration) 

to provide the view of the exact ground location as currently prescribed. Furthermore, due to the 

height of the wing versus the height of the doors, a truly compliant configuration may ultimately 

not be physically obtainable. 

In accordance with the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 

14 CFR 25.809(a}, for the GVII-G500 and its derivatives, with regards to: 

• Viewing of the ground contact area under all lighting and landing gear conditions 

for overwing emergency exits. 

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G-ODA-15-0657, Attachment 

August 14, 2015 

Supportive information 

Notice of Proposed Rulemaking (Notice No. 96-9) was published in the Federal Register on July 

24, 1996 (61 FR 38552). The notice proposed to upgrade several cabin safety requirements 

including outside viewing means. The FAA's response to the commenters was that the impact of 

14 CFR 25.809(a) went beyond what was envisioned in the rulemaking process for the overwing 

exits on some airplanes. 

The intent of the requirement was to enable a person to ascertain whether to open an exit, and 

whether it was safe to evacuate through the exit, based on the assessment of the outside 

conditions. To the extent that the means used for the determination of the former did not also 

allow an assessment of the ground, it was agreed that an additional viewing means might be 

necessary, and that the additional means might be somewhat remote from the exit. Therefore 

the amendment was reworded to allow for dual purpose of the viewing means, and to 

distinguish the required locations of the two. The intent of the rule was that it was not necessary 

for a person to be able to view the ground-contact point while in position to open an overwing 

exit. The rule itself refers to the ground-contact view separately from the view of conditions 

outside the exit, but the intent of the rule was not clearly expressed in the rule language. EASA 

incorporated the improved language in their Certification Specification (CS) at Amendment 

25/12, dated July 13, 2012. CS 25.809(a)(3) states: "For non-over-wing passenger emergency 

exits, a means must also be provided to permit viewing of the likely areas of evacuee ground 

contact when the exit is closed with the landing gears extended or in any condition of collapse. 

Furthermore, the likely areas of evacuee ground contact must be viewable with the exit closed 

during all ambient lighting conditions when all landing gears are extended." 

Factors supporting the Petition 

Based on the design and location of the elliptical windows, Gulfstream believes that the ability to 

perform a fully effective visual assessment of outside aircraft conditions and evacuation route 

with the overwing exits closed is provided. The arrangement of the large elliptical windows at 

the overwing exits provides a field of view of approximately 140°. A view of the full surface of 

the wing as well as the ground area surrounding the wing, including areas just feet from the 

location of likely occupant ground contact is provided. With this large panoramic view an 

occupant can directly see the wing surface to ensure no hazards are present but will also be 

provided a view of enough of the ground area to make a logical assessment as to the conditions 

at the point of contact prior to opening the exit. 

Once the evacuee steps onto the surface of the wing they will be then be able to follow the 

appropriate escape route and view the ground where they would likely make contact to confirm 

no hazards exist. Evacuees will be capable of viewing the escape route and ground during all 

lighting conditions. The exterior egress lighting is integral to the emergency lighting system. 

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G-ODA-15-0657, Attachment 

August 14, 2015 

Effect of the Exemption on Safety 

Granting this exemption would not affect safety, because: 

The proposed configuration provides a level of safety consistent with the intent of the rule and 

provides an effective means to assess outside conditions prior to opening overwing exits. The 

GVII-GSOO model aircraft design is consistent with industry present state-of-the-art and design 

practice. 

The GVII-GSOO and its deriviatives will comply with anticipated future harmonized requirements 

as written in the EASA CRD to NPA 2010-11 and now incorporated in EASA CS 25.809(a) at 

Arndt 12. 

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'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 services 

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. 

Granting this exemption would benefit the public as a whole, because it: 

a) Minimizes significant cost impacts and avoids investing time and efforts to develop a 

design that would meet some aspects of the present regulation which will be changed in 

the future. 

b) Allows the Gulfstream GVII model designs to meet EASA and FAA anticipated future 

harmonized regulation preventing competitive disadvantage due to additional 

design/manufacturing complexity and increased weight. 

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G-ODA-15-0657, Attachment 

August 14, 2015 

Operation Outside the United States 

The European Aviation Safety Agency (EASA) Certification Standard (CS) 25.809(a) is not 

currently harmonized with 14 CFR 25.809(a). 

Regardless of EASA requirements, 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 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 14 CFR 

part 25 as their airworthiness standard for transport category aircraft. Gulfstream believes that 

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

this aircraft. 

Conclusion 

Gulfstream believes that the GVII-G500 design provides a means for safe and effective 

assessment of outside conditions and hazards, both on-wing and ground, prior to opening the 

overwing exits and provides a level of passenger safety consistent with the current Part 25 

regulations. It is proposed that the above arguments favor a partial exemption from 14 CFR 

25.809(a) for the GVII-G500 and its derivatives, and that the issuance of an exemption is in the 

public interest. 

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