# Gulfstream

A GENERAL DVNA:MICS COMPANY

U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE. Washington , DC 20590 November 20, 2015 G-ODA-15-0955

Subject: Request for Exemption from Section 25.813(e) ofTitle 14, Emergency Exit Access FAA Project No: TC-01-2010-0024 Attachment: Petition for Exemption - Installation of Mid-Cabin Interior Doors, Model GVII-G500 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-G500 model aircraft and its derivatives from full compliance with 14 CRF 25.813(e) at amendment 25-128, Emergency exit access, to allow for installation of interior doors between passenger compartments on private use aircraft. Ifyou have any questions or need additional information please contact Robert Glasscock at (912) 965- 6817 (via e-mail at robert.glasscock@guffstream.com) or the undersigned. Respectfully,

Robert Glasscock Director ODA Programs P.O. Box 2206, MIS R-02 Savannah , GA 31402-2206 robert.glasscock@gulfstream.com (912) 965-6817 Cc: N. Berryman , ACE-120A (via email) B. Whitton, Gulfstream ODA (via email) C. Underwood, ACE-120A (via email) M. Gordon,ANM-113 (via email) J. Nyberg, EASA (via email)

P. O . Box 2206 • Savannah , GA 31402 · 2206 USA • Telephone (912) 965·3000 • gu l fstream . com

### Petition for Permanent Exemption Gulfstream Aerospace Corporation Installation of Mid cabin pocket doors

Model GVII-G500 and its derivatives Relieffrom section 14 CFR Part 25.813(e) 

### Arndt 25-128 Gulfstream Aer6space Corporation (Gulfstream) of Savannah, Georgia has submitted an application to the FAA's Atlanta Airplane Certification Office fortype certification of a new, twinengine, transport category airplane to be known as the Gulfstream model GVII-G500. Gulfstream ODA project numberTC-01-2010-0024 has been assigned to this effort. The cabin inter jor ofthe GVII-G500, and its derivatives, relies on installation of mid cabin pocket doors to divide different sections ofthe passenger cabin areas and provide certain amenities and configuration options that have become the standard for executive class airplanes. 14 CFR 25.813(e) Amendment 25-128- States that no door may be installed between any passenger seat that is occupiable for take-off and landing and any passenger emergency exit, such that the door crosses any egress path (including aisles, cross-aisles and passageways) . In accordance with the provisions of 14 CFR 11.81 , Gulfstream requests an exemption to 14 CFR 25.813(e) for installations ofthese mid cabin pocket doors. Gulfstream proposes that specific design features ofthe GVII-G500 and its derivatives, and limiting this exemption to those aircraft that are operated as private use only (aircraft may not be offered for common carriage or operated for hire) will provide an appropriate level of safety. The information provided herein outlines this rationale. 

### Supportive Information 14 CFR 25.813(e) restricts the installation of any interior door between a passenger seat and any emergency exit, effectively restricting the use of all interior doors. Exemptions as!well as Equivalent Level of Safety (ELOS) have been granted by the FAA to the 14 CFR part 25 requirements allowing the installation of mid cabin doors when the aircraft is limited to private use only (aircraft may not be offered for common carriage or operated for hire). On June 08, 2009, the FAA released Special Federal Aviation Regulation (SFAR) 109 allowing the installation of interior doors when the aircraft is prohibited from operations involving the carriage of persons or property for compensation or hire beyond the remuneration afforded by 14 CFR part 91 , subpart F. Because Gulfstream operators transition between private use only and on-demand operations (14 CFR part 135) , Gulfstream is requesting an exemption based on the requirements ofthe applicable sections of SFAR 109 to allow the installation of mid cabin pocket doors when the aircraft is limited to private use only (prohibited from operations involving the carriage of personsor property for compensation or hire beyond the remuneration afforded by 14 CFR part 91) and locking out the door for common carriage or on-demand operations (14 CFR part 135 operations). Forthe GVII-500 airplane and its derivatives, Gulfstream believes that it is possible to provide a level of safety consistent with the intent ofthe 14 CFR Part 25 regulations while allowing installation of certain interior doors. This will be accomplished by incorporating specific design features that provide an acceptable level of safety. 

### Factors supporting the Petition Under private use only, passengers become exceptionally familiar with the operation of interior features and the locations ofthe exits on their Gulfstream product. Unlike common carriage or on-demand operations, the crew of a private use Gulfstream aircraft has daily contact with their passengers. This has a positive influence on communicating safety issues. In addition, dedicated crews normally operate private use aircraft. The combination ofthese factors and the design features listed below provides a level of safety commensurate with the level of safety envisioned by Amendment 25-128. The design features ofthe mid cabin pocket doors installed on the GVII-G500 and its derivatives will ensure that the passengers' ability to effectively egress the airplane is not diminished per the following criteria. • The Airplane Flight Manual Supplement (AFMS) will include appropriate limitation(s) to require a preflight passenger briefing describing the appropriate functions to be performed by the passengers and the relevant features of the airplane to ensure the safety ofthe passenger and crew. • The airplane will not be offered for common carriage or operated for hire or hire beyond the remuneration afforded by 14 CFR part 91 . The operating limitations section ofthe Airplane Flight Manual Supplement (AFMS) will be revised to prohibit any operations involving the carriage of persons or property for compensation or hire. • A placard stating that "Operations involving the carriage of persons or property

.for compensation or hire are prohibited, unless the mid-cabin door is locked in an

·open position" will be located in the area ofthe Airworthiness Certificate holder at the entrance to the flightdeck. • Each door between any passenger seat, occupiable fortaxi, take-off and landing , and any emergency exit will have a means to signal to the flight crew, at the flight deck, that the door is in the open position for taxi, take-off and landing.• Appropriate procedures/limitations will be established to ensure that any such door is in the open configuration for taxi, take-off and landing. • Each door between any passenger seat and any exit will have dual means to retain it in the open position, each ofwhich is capable of reacting the inertia _loads specified in 14 CFR 25.561 . ;- • Doors installed across a longitudinal aisle will translate laterally to open and close, e.g., pocket doors. • Each door between any passenger seat and any exit will be frangible in either direction. • Each door between any passenger seat and any exit will be operable from either side, and if a locking mechanism is installed, it will be capable of being unlocked from either side without the use of special tools. The mid cabin pocket door will be equipped with a locking device to retain the door in the stowed position to be used should the aircraft be offered for hire operations (such as on- 1 demand operati.ons under 14 CFR part 135). This locking device will physically secure the door in a stowed condition using a fastener which requires the use of a special tool, preventing passengers from removing the lockout feature and deploying the door. 

### Effectofthe exemption on Safety The exemption requested will not adversely affect the level of safety provided for the GVII-G500 and any subsequent derivative models. The design of the proposed mid cabin pocket door will ensure the same level of safety for cabin egress as is required for any emergency exit and clear egress path .

### Issue of Public Interest Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the world's most technologically advanced executive class airplane to an International market. Gulfstream's leadership position in the global executive class airplane is due to the efforts of its nearly ten thousand employees in the manufacturing plants, completion centers, and services across North America.The corporation utilizes numerous products, such as avionics and environmental control systems, from scores ofsuppliers located throughout the United States. Gulfstream competes for new business all over the world. This exemption will have a direct impact on sales ofthe GVII-G500 and its derivatives. The placement of mid cabin pocket door is significant to the owner/operator ofthe airplane. The flexibility to partition the airplane into individual rooms, such as private rooms, is paramount to an acceptable interior and is being requested by prospective airplane operators who compare the GVII-G500 and its derivatives with products 6fforeign airplane manufacturers. The inability to provide such features will ultimately cause a reduction in perspective sales. The manufacture, completion, and support of Gulfstream airplanes aids in the stabilization ofthe job market as well as the growth ofthe American economy, which is in the interest ofthe public. Since customers desire to have these mid cabin pocket doors, they may opt for airplane designed to an earlier certification basis, in the lieu of the GVII-G500 or its derivatives. This will restrict advancements in safety introduced by Gulfstream with the GVII-G500 and its derivatives, not only in the areas ofthe 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 airplane safety is in the interest ofthe public. 

### Operation**Out~**

### idethe United States In accordance with 14 CFR 11 .81 (h), Gulfstream requests consideration be given to extending this exemption for operation outside the United States. Gulfstream aircraft are routinely registered and' operated outside ofthe United States and projections are the same forthe GVIIG500 and its derivatives. Gulfstream believes that limiting this exemption to use within the United States would put unfair restrictions on the marketability of this aircraft.**~** 

### Waiver of Notice and Public Procedure In accordance with 14 CFR 11 .29 and 14 CFR 11 .87, Gulfstream requests that the period for public comment and publication be waived . This exemption is identical to the applicable sections of SFAR 109 except that it adds a lock out feature to be utilized should the aircraft be offered for hire operations (such as on-demand operations under 14 CFR part 135). Similar exemptions ofthis nature have been granted numerous times for similar installations.Previously Granted Exemptions: 

# . Exemption No. 1 0338A, Embraer S.A. Exemption No. 1 0274, Gulfstream Aerospace Exemption No. 10396, , Dassault Aviation Conclusion: Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.813(e) that would allow for installation of mid cabin pocket doors on the GVII-G500 and its derivatives for private use operations. In addition , Gulfstream believes that an exemption is in the public interest and will provide a level of passenger safety consistent with the current 14 CFR Part 25 regulations.