# Gulfstream

A GENERAL DYNAMICS COMPANY

U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 NewJerseyAvenue, SE. Washington , DC 20590 L-**~; ~**  ... ; . ··: i i] ·r August14,2015 G-ODA-15-0657

Subject: Requestfor Exemption from Section 25.809(a) ofTitle 14 Code of Federal Regulations, Overwing Emergency Exits Viewing Means FAA Project No: TC-01-2010-0024 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 exitwindow. Ifyou 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.glasscock@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.comG-ODA-15-0657, Attachment August 14, 2015 Petition for Permanent Exemption Gulfstream Aerospace Corporation Overwing Emergency Exits Means forViewing Likely Areas of Evacuee Ground Contact Model GVII-G500 Relieffrom section 14CFR Part 25.809(a) Arndt. 25-116 Gulfstream Aerospace Corporation (Gulfstream) of Savannah, Georgia has submitted application to the FAA's Atlanta Aircraft Certification Officefortype certification ofa new, twinengine, transport category aircraftto be known as the Gulfstream model GVII-G500. Project numberTC-01-2010-0024 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 doororhatch in the external walls ofthe fuselage, allowing an unobstructed opening to the outside. In addition, each emergency exit must have means to permit viewing ofthe conditions outside the exitwhen the exit is closed. Theviewing means may be on oradjacentto the exit provided no obstructions exist between the exit and the viewing means. Means must also be provided to permit viewing ofthe likely areas ofevacuee ground contact. The likely areas ofevacuee ground contact must be viewable during all lighting conditions with the landing gearextended as well as in all conditions of landing gearcollapse. The GVII-500 emergency exit configuration consists oftheType I Main Entry Door, along with two pairs ofoverwing 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-G500will 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 panoramicview ofthe wing surface as well as the ground areajust beyond the point ofoccupantfirst contact. Partial relief is being soughtforthe GVII-G500 and its derivatives, from the requirements of 14 CFR 25.809(a) forthe overwing exits since this outside viewing means does not permitviewing ofthe likely area ofthe evacuee ground contact priorto 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 ofthe exits forward orcomplete redesign ofthe exit configuration) to provide the view ofthe exact ground location as currently prescribed. Furthermore, due to the height ofthe wing versus the height ofthe doors, a truly compliant configuration may ultimately not be physically obtainable. In accordancewith the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 14 CFR 25.809(a}, forthe GVII-G500 and its derivatives, with regards to:

• Viewing ofthe ground contact area underall lighting and landing gearconditions for overwing emergency exits. 1G-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 thatthe impact of 14 CFR 25.809(a) went beyond whatwas envisioned in the rulemaking processforthe overwing exits on some airplanes. The intent ofthe requirement was to enable a person to ascertain whetherto open an exit, and whether itwas safeto evacuatethrough the exit, based on the assessment ofthe outside conditions. To the extentthatthe means used forthe determination ofthe former did not also allow an assessment ofthe ground, it was agreed that an additional viewing means might be necessary, and thatthe additional means might be somewhat remote from the exit. Therefore the amendmentwas reworded to allow for dual purpose ofthe viewing means, and to distinguish the required locations ofthe two. The intent ofthe rule was that it was not necessary for a person to be able to viewthe ground-contact point while in position to open an overwing exit. The rule itself refers to the ground-contactview separatelyfrom the view ofconditions outside the exit, butthe intent ofthe rule was not clearly expressed in the rule language. EASA incorporated the improved language in their Certification Specification (CS) atAmendment 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 permitviewing ofthe likely areas ofevacuee ground contactwhen the exit is closed with the landing gears extended or in any condition ofcollapse. Furthermore, the likely areas ofevacuee 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 ofthe elliptical windows, Gulfstream believes thatthe abilityto perform a fully effective visual assessment ofoutside aircraft conditions and evacuation route with the overwing exits closed is provided. The arrangement ofthe large elliptical windows at the overwing exits provides a field ofview ofapproximately 140°. A view ofthe full surface of the wing as well as the ground area surrounding the wing, including areasjustfeet 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 ofenough ofthe ground area to make a logical assessment as to the conditions atthe point ofcontact priorto opening the exit. Once the evacuee steps onto the surface ofthe wing they will be then be able to followthe appropriate escape route and viewthe ground where theywould likely make contactto confirm no hazards exist. Evacuees will be capable ofviewing the escape route and ground during all lighting conditions. The exterior egress lighting is integral to the emergency lighting system.

2G-ODA-15-0657, Attachment August 14, 2015



### Effectofthe Exemption on Safety Granting this exemption would not affect safety, because: The proposed configuration provides a level ofsafety consistentwith the intent ofthe rule and provides an effective means to assess outside conditions priorto opening overwing exits. The GVII-GSOO model aircraft design is consistentwith 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 NPA2010-11 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 mosttechnologically advanced businessjet aircraftto an International market. Gulfstream's leadership position in the global businessjet 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 ofsuppliers located throughoutthe United States. Gulfstream competes for new business all overthe world. Granting this exemption would benefitthe 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 ofthe 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 dueto additional design/manufacturing complexity and increased weight.

3G-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 ofthe United States. Gulfstream aircraft are routinely registered and operated outside ofthe United States and projections arethe same forthe Model GVII. Granting this extension of privileges will allowfor operations based within foreign countries, having bilateral agreements with the United States accepting FAA 14 CFR part 25 as their airworthiness standard fortransport 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 thatthe GVII-G500 design provides a meansforsafe and effective assessment ofoutside conditions and hazards, both on-wing and ground, priorto opening the overwing exits and provides a level ofpassengersafety consistent with the current Part 25 regulations. It is proposed thatthe above argumentsfavor a partial exemption from 14 CFR 25.809(a) forthe GVII-G500 and its derivatives, and thatthe issuance ofan exemption is in the public interest.

4