Learjet Inc. 

P.O. Box 7707 

Wichita, KS 67277-7707 

United States 

www.bombardier.com 

TEL 316-946-2000 

FAX 316-946-2809 

February 15, 2011 

In Reply refer to: L706-02-11-0093 

SUBJECT: Submittal of Petition for Exemption – 14 CFR Part 25, Section 25.813(e) Amendment 

25-116 for Learjet Model LJ-200-1A10 

REF: FAA Project Number TC4960WI-T 

Dear Sir or Madam: 

In accordance with 14 CFR Part 11, Learjet Inc. submits this petition for exemption from 14 CFR 

Part 25, Section 25.813(e) Amendment 25-116, emergency exit access, for the Learjet Model 

LJ-200-1A10. Relief to this requirement would permit the installation of partition door(s) in the 

cabin of the new Learjet Model LJ-200-1A10. 

An application for a new Type Certificate (TC) has been submitted by Learjet Inc. for this new 

model and FAA Project no. TC4960WI-T has been assigned to this effort. The certification basis 

for the Learjet Model LJ-200-1A10 is 14 CFR Part 25, Amendment 25-1 through 25-127. 

The basis of this petition has already been established by the FAA in the granting of exemptions 

as shown in the following documents: 

• FAA Exemption No. 10188, issued December 27, 2010 – Gulfstream Aerospace Corp. 

for the Model GVI 

• FAA Exemption No. 8767, issued August 14, 2006 – Cessna Aircraft Company 

for the Model 750 (Citation X) 

• FAA Exemption No. 8621, issued October 3, 2005 – Cessna Aircraft Company 

for the Model 560XL (Citation XL) 

• FAA Exemption No. 8123, issued September 3, 2003 – Midcoast Aviation Inc. 

for the Dassault Aviation Mystere – Falcon 900 and Falcon 900EX 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 
L706-02-11-0093 

2 

Discussion of Relief from 14 CFR Part 25, Section 25.813(e) Amdt. 25-116

Learjet Inc. has prepared a petition for exemption to the following regulation: 

14 CFR Part 25, Section 25.813(e), Amendment 25-116 – “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, 

cross aisles and passageways).” 

When 14 CFR Part 25, Section 25.813(e) Amdt. 25-1 was issued to restrict installation of doors 

between passenger compartments it 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 isolated the passenger seating areas from crew work areas. These 

doors lowered noise levels in the passenger cabin and created effective work environments on 

these business aircraft. 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 recognize that an exit exists beyond an interior door 

forward or aft of the passenger compartment; and reach the exit beyond the door in the event of 

failure of the interior door to open or being jammed. 

For the Learjet Model LJ-200-1A10 executive business aircraft, Learjet Inc. 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 pocket doors. This will be accomplished by 

incorporating specific design features to ensure the passengers’ ability to effectively identify the 

exit and egress the aircraft is not diminished. 

Learjet Inc. is proposing specific design requirements to provide this level of safety appropriate 

to the operations of executive business aircraft, both private (14 CFR Part 91) and for hire 

(common carriage) (14 CFR Part 135) equipped with partitions and doors. 

The Learjet Model LJ-200-1A10 executive business aircraft will be designed to the requirements 

of 14 CFR Part 25, Transport category. These rules basically address airplanes that are used 

for the carriage of fare paying passengers or the general public. Additionally, the rules consider 

aircraft with a passenger seating of up to 500. The new Learjet Model LJ-200-1A10 will have a 

maximum seating capacity of ten (10) passengers, and will be equipped exclusively for 

executive business aircraft use. The difference between the commercial transport category 

aircraft used in airline operation and aircraft specifically used for executive business operations 

are not segregated in the 14 CFR Part 25 rules. Learjet contends that airplanes specifically 

designed for executive business operations, whether private or for hire (common carriage) 

should be eligible for the acceptance by exemption of cabin features which do not comply with 

the full requirements of 14 CFR Part 25 provided that they demonstrate and provide similar 

levels of safety. 
L706-02-11-0093 

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Aircraft specifically designed for executive business aircraft operation contain features designed 

to support passengers who fly frequently and are very familiar with the executive business 

aircraft in which they are traveling. The crew of an executive business aircraft is intimately in 

contact with the passengers thus the communications are first hand which ensures safety and 

understanding of operation. Furthermore, passengers will be briefed as to the proper use and 

safety features of the doors enhancing safety and ensuring rapid egress from the aircraft in an 

emergency situation. This is typically addressed in the pre-flight briefings from the pilots prior to 

take off for 14 CFR Part 91 / 135 operations and additionally in the passenger briefing cards for 

14 CFR Part 135 operations. 

The new Learjet Model LJ-200-1A10 will have a maximum seating capacity of ten (10) 

passengers and two (2) crew members. The standard floor plan arrangement will consist of four 

(4) club seating arrangement in the main passenger cabin (see Figure 1). 

 Over Wing Type III 

 Emergency Exit 

Entry/Type I Exit 

Single Pocket Door – Aft Lavatory 

 Optional Single Pocket Door - Mid-Cabin 

Figure 1 – Standard Floor Plan Arrangement 

Optional floor plan arrangements will also be available, they will consist of a three (3) club 

seating arrangements and a three (3) place side-facing divan (See Figure 2). All cabin 

arrangements will contain partitions with a pocket door that will divide the cabin from the aft 

lavatory. The aft lavatory area will consist of a vanity cabinet on the LH side and a toilet 

enclosure on the RH side with provisions for an optional belted seat. 
L706-02-11-0093 

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 Over Wing Type III

 Emergency Exit 

Entry/Type I Exit 

 Single Pocket Door – Aft Lavatory 

 Optional Single Pocket Door - Mid-Cabin 

Figure 2 – Example of Optional Seating Configuration 

Installed in the aft section of the main passenger cabin, as part of both the standard and 

optional seating arrangements, will be a manually operated single “pocket” door in the LH Aft 

Lavatory Partition that will separate the main passenger cabin from the aft lavatory. In addition, 

as a customer selected option, a manually operated single “pocket” door will be installed just aft 

of the RH forward galley. Both of these pocket doors will feature an electro-mechanical latch to 

maintain the door in the open (stowed) position when the aircraft landing gear is down or the 

flaps are not fully retracted and will remain open until the landing gear and flaps are both fully 

retracted. 

The main entry door, a Type I exit, will be located on the LH side of the aircraft, approximately 

three feet aft of the cockpit. The opening of the Type I exit is similar to the previously approved 

Bombardier BD-100-1A10 (Challenger 300). From inside the aircraft, a single rotary handle, 

located on the forward side of the door, is rotated upward releasing the locking mechanism 

allowing the door to open outward. A set of stairs are integrated into the door along with hand 

rails on the aft side to assist occupants in entering and exiting the aircraft. 

Installed on the RH side, just outboard of the toilet enclosure in the aft lavatory, will be a Type III 

emergency exit (similar to the Learjet Model 60). Opening of the Type III emergency exit from 

inside the aircraft will consist of rotating a handle up and aft which will allow the door to move 

upward to clear the lower latches and thus swing outward and forward along the fuselage. The 

door will remain attached to the door opening structure and will not be a removable plug style 

door like other aircraft in its class. Additionally, the Type III emergency exit door will have a 

latching mechanism to retain it in the open position. 

There are good technical arguments to support special consideration for this size of aircraft with 

a passenger count of ten (10) or less which is significantly less than the amount carried in airline 

service. One of which is the distance between the Type I and Type III emergency exits of 

approximately 18.5 feet and separated by one single aisle. Passengers leaving their seats will 

either move forward or aft to reach an emergency exit. In addition, opening of the Type III 

emergency exit from inside the aircraft will be much easier in that, in the event of an emergency, 
L706-02-11-0093 

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an occupant will not have to decide what to do with a door that is at least 20 inches wide by 36 

inches high weighing between 45 to 50 lbs. All he or she will have to do is rotate the handle up 

and aft, push the door outward and forward along the fuselage where it will lock into the open 

position. The opening of the Type I door from inside the aircraft will only require the rotation of 

the handle upward and pushing the door open. Furthermore, the proposed design features of 

the partitions with pocket doors will have safety features that will be equal to what is required by 

the rule and is further described in the Occupant Safety Considerations below. 

Occupant Safety Considerations

Similar to exemptions previously granted, Learjet Inc. proposes the following design 

requirements in the interest of safety: 

• The doors will be designed to be maintained in the open (stowed) position when the 

landing gear is down or the flaps are not fully retracted and will remain open until the 

landing gear and flaps are both fully retracted. The installation of the interior doors will 

therefore not adversely affect passenger recognition of the Type I and Type III 

emergency exits. 

• The doors will be designed so that they can only be closed (deployed) when the gear 

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

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

doors will default to the open (stowed) position. 

• In accordance with Learjet’s approach to compliance with 14 CFR 25.1309, the failure to 

egress through any individual emergency exit is classified as Major. Learjet will 

demonstrate that the probability of failure to egress through the Type I and Type III 

emergency exits, including the probability of failure of both interior doors in the deployed 

position, will meet the criteria for a failure scenario classified as Major. This will include 

conducting a quantitative analysis that shows 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). 

• The doors will have a hold-open feature that will be shown to withstand all emergency 

landing loads specified under 14 CFR 25.561(b). 

• Emergency exit locator / marking signs and emergency lighting in accordance with 14 

CFR 25.811 and 25.812 will be provided. 

• The doors between the passenger compartments and emergency exits will be frangible. 

The doors will be designed in three (3) separate sections; main section, header, and 

footer. Each of these sections will consist of individual composite panel segments, 

covered in veneer or laminate. The segments will be held together by a frangible rod. 

The doors will be tested for frangibility in both forward and aft directions utilizing a 5th

percentile female. The tests will ensure that the opening created by the 5th percentile 

female will allow a 95th percentile male to fit through. 

• Each door will have a minimum gap of .50 inches between the door header / cabin 

headliner and door footer / cabin floor. This gap will be to eliminate the pocket door 

header or footer from jamming against the cabin headliner or cabin floor thus enhancing 

the break through capabilities of the pocket door and maintaining rapid egress. The gap 

will also allow for an individual to grab the pocket door either at the top or bottom so as 

to continue moving the door once the frangible rods have been broken if required. The 

pocket doors will contain lanyards to retain the segmented panel portions that are 
L706-02-11-0093 

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designed to break and therefore keep them from blocking or creating any tripping 

hazards during egress. 

• An Amber CAS message will alert the pilots if the interior doors are not in the properly 

open (stowed) position for taxi, takeoff, and landing. 

• Any occupant seated in the lavatory during taxi, takeoff, and landing will be required to 

be an adult with a stature of 60 inches weighing 102 lbs., or greater. This information will 

be included in the Aircraft Flight Manual and placarded accordingly. 

Additional Safety Features and Justification

• The Type III over-wing emergency exit will be outward opening and will remain 

structurally attached to the door opening structure. Most other executive business 

aircraft in this class have a removable plug style door for their Type III emergency exit. 

This causes the person removing it to decide to throw it out the exit opening as many of 

the placards state or place it on a seat or some place out of the way in the cabin. In 

either case, it is an extra step to deal with. Typically, these doors weigh between 45 and 

50 lbs and are cumbersome to maneuver due to their size and interior features that are 

typically installed on them. 

• Similar to the Learjet Model 60, the Type III emergency exit will be located in the aft 

lavatory directly over the RH wing. The Learjet Model LJ-200-1A10 aircraft will be 

certified for ditching and therefore the exit has been located in the safest position. This 

will provide the occupants the best opportunity to safely egress the aircraft onto the wing 

and into a life raft or directly into the life raft as necessary. The life raft for this exit will be 

installed in a compartment between the vanity and toilet enclosure within a few feet of 

the Type III exit which allows for easy access and removal. 

• Most aircraft in this class have one of their emergency exits in the main cabin. On the 

Learjet Model LJ-200-1A10, moving the Type III emergency exit into the main cabin 

would require the addition of an assist means (self supporting slide) since the exit would 

be higher than six (6) feet off the ground. Furthermore, the table located between the 

seats where the exit is installed would create an additional obstruction that could delay 

the opening of the exit and potentially provide additional obstacles for rapid egress from 

the aircraft. 

Issue of Public Interest and Safety

Learjet Inc. has been manufacturing executive business aircraft for a wide variety of customers, 

world wide for more than forty-five (45) years. In 1993, the Model 60 was introduced into the 

market where the first Equivalent Level of Safety finding to 14 CFR Part 25, Section 25.813(e) 

Amdt 25-72 was granted by the FAA to Learjet Inc. This same Equivalent Level of Safety finding 

is still applied today. There are over three hundred and eighty (380) Model 60 executive 

business aircraft in service that include a partition with a single pocket door that separates the 

passenger cabin from the Type III emergency exit in the aft lavatory regardless of the type of 

operation (14 CFR Part 91 or Part 135). This Equivalent Level of Safety finding granted by the 

FAA requires the door to be secured open for taxi, takeoff, and landing. Additionally, the pocket 

door is frangible in the event that it may become jammed in the closed (deployed) position. 

Furthermore, when the aft lavatory is occupied for taxi, takeoff, and landing the occupant must 

be an adult with a stature of 60 inches tall and weigh 102 lbs. or greater. This has provided an 

acceptable level of safety for customer’s world wide for the last seventeen (17) years. 
L706-02-11-0093 

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In 2004, 14 CFR Part 25, Section 25.813(e) was amended to state, “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, cross-aisles and 

passageways)”. Previously, a door could be installed between passengers and an emergency 

exit provided that the passengers were not seated on both sides of the door. The regulation 

then only required the door to be secured open for taxi, takeoff, and landing. Due to the growing 

population of executive business aircraft including interior arrangements with separate rooms 

and so as to provide an additional level of safety, the FAA decided to amend the rule to not 

allow a door between a passenger compartment and an emergency exit. However since 2004, 

there have been approximately twenty three (23) exemptions granted to various business 

aircraft manufacturers allowing doors between passenger compartments and doors between a 

passenger compartment and an emergency exit with a list of stipulations that provide an 

adequate level of safety. The list of stipulations has included the following: 

• Each door between passenger compartments must be frangible. 

• Depending on the category of operation, the door must be either secured open or closed 

if the room is not occupied for taxi, takeoff, and landing. 

• There must be appropriate procedures to signal the crew if the door is not secured open 

(stowed) during taxi, takeoff, and landing. 

• The doors must be designed to be maintained in the open (stowed) position when the 

landing gear is down or the flaps are not fully retracted and will remain open until the 

landing gear and flaps are both fully retracted. 

• The doors must be designed so that they can only be closed (deployed) when the gear 

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

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

the doors will default to the open (stowed) position. 

• The doors must have a hold-open feature that will be shown to withstand all emergency 

landing loads specified under 14 CFR 25.561(b). 

Like other business aircraft manufacturers, Learjet Inc. is requesting the FAA grant a similar 

exemption for the door that will separate the main passenger cabin from the Type I emergency 

exit and the door that will separate the main passenger cabin from the Type III over-wing 

emergency exit in the aft lavatory. These safety features will ensure the same level of safety for 

passenger egress as is required for any emergency exit and will provide a clear egress path. 

Operation Outside of the United States

The European Aviation Safety Administration (EASA) Certification Standard (CS) 25.813 

regulation is not currently harmonized with 14 CFR 25.813 and does not restrict these types of 

door installations. 

Regardless of EASA requirements, per 14 CFR 11.81(h) Learjet requests consideration be 

given to extending this exemption for operation outside of the United States. Learjet aircraft are 

routinely registered and operated outside of the United States and projections are the same for 

the Learjet Model LJ-200-1A10. 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. Learjet believes that limiting this exemption to use within the U.S. 

would put unfair restrictions on the marketability of this aircraft.