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Gulfstream Aerospace LP ¤ c/o IAI Dept. 4199 ¤ Ben Gurion Int'l Airport 70100 ¤ ISRAEL

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 GALP Ref: FAA/11033/CG January 29, 2011

To: U.S. Department of Transportation Docket Operations West Building Ground Floor

Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Subject: Petition for FAA Exemption for Installation of Doors Between Passenger Compartments in the Gulfstream Aerospace LP model Gulfstream G250 Airplanes.

Dear Sir (Madam):

Gulfstream Aerospace Corporation (GAC) and Gulf stream Aerospace LP (GALP) are currently engaged in the development and type certification of the new derivative model Gulfstream 250 (G250) airplane. The Model G250 is a derivative of the current Gulfstream 200 (formerly Galaxy), which is approved under Type Certificate A53NM. Th e model G250 is being certified under Transport Airplane Directorate Type Certification Project No. AT0329IB-T. This new airplane model is being certified to 14 CFR Part 25, Amendments 25-1 th rough 25-120, which includes certification to the requirements of §25.813 at Amendment 25-116. This petition for exemption presents the issues and specific petition request, proposed test criteria and guidelines, and a statement of public interest.

Issue Statement and Petition Request

The model G250 airplane will be eq uipped with multiple-passenger in terior arrangements that will include doors between passenger seats and emergency exits. The G250 will most often be used for executive air transportation under Parts 91 and 135 of the Federal Aviation Regulations. Due to the nature of the transportation involved many operator s request the installation of privacy cabin doors when outfitting of the aircraft is accomplished.



### Title 14 Code of Federal Regulations (14 CFR) se ction 25.813(e) states: “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 patch (including aisles, crossaisles and passageways)”. According to the FAA, section 25.813(e) exists to ensure that passengers do not become isolated in a passenger compartment during an emergency. The intended means of ensuring this is the prohibition against doors between passenger seats and emergency exits. However, exemptions have been granted to this rule if sufficient compensation is provided to achieve an acceptable level of safety and that the airplane be limited to private use not for hire not for common carriage. One of the conditions is that the door must be latched open during taxi, takeoff a nd landing. A second condition is that the door (or other suitably located partition or bulkhead) mu st be equipped with an emergency egress panel. An emergency egress panel is a panel that can be broken through by a passenger who may be inadvertently trapped behind the door (this is typically addressed by providing a “frangible door”). Therefore, in accordance with 14 CFR Part 11.25, GAC and GALP petition for permanent exemption from the requirements of 14 CFR §25.813(e), in order to allow installation of a forward compartment door in the model G250 cabin interior. It is intended that this exemption will be included in the type certificate requirements as a part of the cer tification basis for the model G250 airplane.2 of 6

Gulfstream Aerospace LP ¤ c/o IAI Dept. 4199 ¤ Ben Gurion Int'l Airport 70100 ¤ ISRAEL

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 Justification and Safety Considerations

Specifications for the Model G250 Cabin Interior include an option for the installation of a pocket door on the aft side of the RH Fwd galley. This pocket door installation will separate the cabin passenger seats that are occupiable for taxi, take-off and landi ng from the Main Entry Door of the aircraft, an emergency exit (reference Figure 1). This pocket door installation will not be in compliance with the requirements of 14 CFR 25.813(e); therefore, GAC and GALP proposes pursuing a request for exemption from demonstrating compliance to this requirement. During outfitting the out fitter will demonstrate that there are sufficient compensating design features in the pocket door assembly and surrounding cabin interior installations such that an acceptable level of safety can be afforded to the occupants. A list of the proposed compensating features will comprise of, but may not be limited to, the following:

1. The door to be installed will be of a sliding type and will retract laterally into a pocket compartment located aft of the Fwd RH galley assembly. The door will not divide the passenger compartment and the occupants will still have direct access to the RH Aft emergency exit (Type III). The door will be designed to be frangible, with features that will allow a 5th percentile female to easily swing the door open in case of an emergency, resulting in an aperture large enough to allow for a 95th percentile male to escape, in addition to having blowout capability for rapid decompressi on events. The pocket door will provide no more resistance to a person passing through it than a normal cabin curtain.

2. The door will be placarded to be latched open during taxi, take-off, and landing. The door design will include dual internal latching mechanisms, which operate independently of one another. This redundant approach would minimize the probability of the door unlocking due to fuselage distortion in an emergency landing, and would be capable of supporting the inertia loads specified in 14 CFR 25.561.

3. The door will also feature a “quarter turn” posit ive manual latch (third in the door assembly), which will virtually prevent the door from deploy ing into the aisle when the lock is engaged. This “quarter turn” manual lock would also be capable of reacting the inertia load factors specified in 14 CFR 25.561 due to the mass of the pocket door.

4. The nature of the G250 pocket door design will be such that in an unlatched condition the door will be spring-pushed and partially deployed in to the aisle. This condition will be easily noticeable by the crew in preparation for ta xi, take-off and landing (reference Figure 2). Additionally, GAC proposes installing visual indicators on the pocket door to enhance

identification of the unlatched condition. These indicators, or markers, will be added on the forward side and next to the inboard edge of the pocket door, and will only be visible to the crew when the door is not engaged in the latched position. Likewise, the position of the quarter-turn lock, described in item 3 above, will be easily identifiable by the crew. A “quarterturn” in the horizontal position will indicate a positive lock of the door.

5. Bulkhead divider type emergency exit sign(s) will be installed to ensure that the level of passenger guidance required to find an exit will be provided. This sign will also address FAA concerns regarding the recognition problem as it relates to the location of the emergency exit (MED) forward of the pocket door.

6. Placard describing pocket door frangibility procedure will be added to the door installation.

7. Interior outfitters will be provided with an Interior Certification Requirements Document to ensure that they are aware of the special desi gn requirements which they must comply to be eligible to use this exemption.3 of 6

Gulfstream Aerospace LP ¤ c/o IAI Dept. 4199 ¤ Ben Gurion Int'l Airport 70100 ¤ ISRAEL

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 Figure 1 – Model G250 Fwd RH Pocket Door Installation

Figure 2 – Pocket Door Latched and Unlatched Condition4 of 6

Gulfstream Aerospace LP ¤ c/o IAI Dept. 4199 ¤ Ben Gurion Int'l Airport 70100 ¤ ISRAEL

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 In the past, FAA’s positio n regarding doors that cross an egress path has been that the operation of the aircraft be limited to private use not for hire not for common carriage. However, GAC would respectfully like to request applicability of this exemption to aircraft that would be operated u nder 14 CFR, Part 135 certification. GAC is of the opinion that in addition to the pocket door and cabin design features listed above, other provisions can be made to address FAA’ s concerns regarding the installation of this type of door in aircraft operated under 14 CFR Part 135 rules. The following provisions and rational are presented as the basis for this

request:

a. FAA opposition to allow the exemption for aircraft under14 CFR Part 135 operation appears to be based on the potential lack of familiarity that pa ssengers in these aircraft could exhibit regarding pocket door procedures during an emergency landing. GAC understands the concern; however, the proposed pocket door design would be such that the pr obability of failure with the door in the deployed position is highly unlikely due to the triple door latc h approach specified in ite ms 2 and 3 above. With a fail-resistant door design, the importance of how fa miliar a passenger needs to be with the emergency procedures for the pocket door is significantly diminished, and should allow for this exemption to be applicable for G250 aircraft ope rating under Part 135 rules.

b. Passenger knowledge of the pocket door emergency procedures would only be critical in the very unlikely event where the pocket door has deployed dur ing an emergency landing. To that end GAC has developed step-by-step procedure to educate pass engers on the emergency operation of the pocket door. These procedures will be the same regardless of type of aircraft operation (private or for hire). Passenger instruction on the pocket door emergency operation will be ac hieved by requesting the crew (via the Aircraft Flight Manual Supplement, AFMS) to perform a pre-flight de-briefing regarding the Model G250 pocket door emergency procedures. Th ese procedures will be re viewed, coordinated and approved by the FAA.

c. Furthermore, GAC proposes treating one of the seats (RH or LH) installed immediately aft and adjacent to the pocket door in similar fashion as s eats next to an emergency exit. That is, this seat position would be required to meet similar requ irements as those specified on 14 CFR Subpart 135.129, which requires operators to make a determination on whether the occupant seated at the emergency seat will be qualified to operate the emerge ncy exit. Except, in this case the operator (via the crew) would be required to make a determination on whether or not the passenger at this seat is qualified to operate the pocket door after an emerge ncy landing, in the very unlikely event that the pocket door has deployed.

d. The pocket door design features specified above (items1 through 6) make it highly unlikely that the pocket door be deployed during taxi, take-off and landing; and make it highly unlikely that the pocket door would deploy across the egress path during an emergency landing condition. In addition, instructional procedures and features as described in paragraphs “b” and “c” above will ensure that the occupants are well informed on pocket door emergenc y operation should the need arise. However, in order to validate the effectiveness of the pocket door design features, and operational procedures immediately after an emergency landing, GAC proposes performing a comparative cabin egress test, as

follows:

Proposed Test Criteria and Guidelines

i. This test will demonstrate that the pocket door deployed into the egress path has minimal effect on the ability of the occupants to rapidly egress the aircraft after an emergency landing.

ii. The evacuation test will consist of performing a baseline cabin egress test (based on a FAA defined criteria) where no pocket door installation is included as part of the aircraft interior, and comparing the results against a similar evalua tion where the pocket door is installed in the

aircraft.

iii. The pass/fail criteria will be ag reed upon with the FAA, and could consist of demonstrating that both evacuation evaluations were comple ted within a pre-defined maximum time (t

max ). GAC would propose that the t

max be determined based on the maximum passenger capacity for the Model G250 and the passenger evacuation flow rate (pax flow rate) per 14 CFR 25.803(c),5 of 6

Gulfstream Aerospace LP ¤ c/o IAI Dept. 4199 ¤ Ben Gurion Int'l Airport 70100 ¤ ISRAEL

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 i.e. pax flow rate = 90 sec/44 pax = 2.05 sec/pax. Thus, the proposed t

max would be 2.05 x (G250 max pax capacity), or t

max = 2.05 x (19) = 38.9 seconds. For the actual test the number of test subjects may be reduced to mini mize the risk of injuries, therefore, t

max will be based on the actual test subject count. Both tests woul d be performed using test subjects who are not familiar with aircraft operations (worst case scenario), and who would be selected per FAA defined criteria. The test subjects would be sepa rated into two groups, with the same number of people, not to exceed the Model G250 maximum passenger capacity.

iv. The test would be performed in accordance with the principle of the Latin Square, where each aircraft interior configuration (with and withou t the pocket-door) is tried once by each group and appear once in each possible order. That is, one group would try first the baseline configuration and then the pocket door configuratio n. The other group would make the trials in the reverse order. The elapsed escape time w ill be recorded for each group and each test configuration.

v. The effectiveness of egress for the interior configuration with the pocket door will be compared to that of the interior without pock et door by comparing the average time of the groups to evacuate the aircraft. However, the inte nt of the tests will be to demonstrate that both configurations can be evacuated with an averaged time less than the t

max defined above.

GAC is of the opinion that these tests will demonstr ate that the pocket door installation has minimal effect on the evacuation rate of the aircraft, and more importantly, that cabin safety has not been compromised by the installation of the pocket door. The aforementioned Latin Square evaluation is similar to evaluation procedures described in Appe ndix 4, of AC 25-17A, for non-standard exit doors on transport category aircraft. The approach has been adapted to support the pocket door evaluation.

Statement of Public Interest

GAC and GALP provide marketing, sales, aircraft completion and product support services for the Gulfstream 250 airplane. GAC and GALP employ a very large staff to design, manufacture, and install the executive interiors for the G250 airplanes that are operated worldwide. The owners of business jet aircraft very often prefer a configur ation that includes compartment doors which reduce cabin ambient noise, and provide for privacy or a comfortable rest area when needed.

The importance of business aviation to the well being of the United States economy cannot be overstated. Business aviation enables a company to maximize its two most important assets, time and people. A business aircraft reduces not only flight time but total business travel time, allowing a higher degree of productivity through greater point-to-point service and the ability to better utilize the existing national airport network, in essence bringing the business closer to its intended customer.
The office-like environment that exists on board the business aircraft allows the travel time of busy executives to be a more productive time.
Current trends in the world economies show that the business aircraft market is expected to grow again. Therefore, the demand for these corporate aircraft and the benefits they present to business makes it essential that the petitioner be granted t he regulatory relief requested. Failure to achieve this goal will result in a significant loss of income, both in domestic and foreign trade for the United States, the petitioner and the intended business operators of these aircraft. The stabilizing effect that manufacture and support of corporate aircraft has on the job market is significant and definitely in the public interest.

Lastly, since customers desire to have these interior doors, they may opt for aircraft designed to an earlier certification basis, in lieu of the G250. This will restrict advancements in safety introduced by GAC with the G250, not only in the areas of cabin safety, but throughout the aircraft. This is counter productive to both GAC/GALP and the FAA’s goal of continuous improvement in overall aircraft safety. The advancement of aircraft safety in the best interest of the public.6 of 6

Gulfstream Aerospace LP ¤ c/o IAI Dept. 4199 ¤ Ben Gurion Int'l Airport 70100 ¤ ISRAEL

Tel: +972-3-935-6624 ¤ Fax: +972-3-935-6750 Operation Outside of the United States

The European Aviation Safety Administration (EASA) Certification Specifications (CS) 25.813 regulation is not currently harmonized with 14 CF R 25.813 and does not restrict these types of door

installations.

Regardless of EASA requirements, per 14 CFR 11.81( h) GAC petitions consideration be given to extending this exemption for operation outside of the United States. GAC/GALP aircraft are routinely registered and operated outside of the United States and projections are the same for the Model G250. Granting this extension of privileges will allow for operations based within foreign countries, including European Union member countries, having bilateral agreements with the United States accepting FAA 14CFR Part 25 as equivalent to t heir airworthiness standards for transport category aircraft. GAC believes that limiting this exemption to use within the U.S. would put unfair restrictions on the marketability of the Model G250.

Conclusion

GAC and GALP believe that the above arguments justify an exemption from 14CFR 25.813(e) that

would allow installation of cabin interior door s on the Model G250 aircraft, operated under both Part 91 and Part 135 rules. GAC and GAP further believe that this exemption is in the public interest and will provide a level of occupant safety consistent with the current 14 CFR rules.

GAC and GALP look forward to hearing your positi ve response regarding the subject petition. If we may be of further assistance concerning this matter contact the undersigned at your earliest

convenience.

Sincerely,

GULFSTREAM AEROSPACE LP

Baruch Marom Airworthiness and Certification Manager Ben Gurion International Airport 70100, Israel

CC: Mike Borfitz, ANM-116 ,FAA PCM, Renton, Washington Dan Jacquet, ANM-115 ,Airframe/Cabin Safety , Renton, Washington Bill Vickers , ASW-190, FAA, Special Certification Office, Dallas , Texas Vladimir Novicov,G250 PCM , CAAI Rick Trusis , Gulfstream Aerospace Corporation ,Savannah , Ga. Jeffrey A. Gibbs,Gulfstream Aerospace LP, Ben Gurion Airport,Israel Charles Celli, Gulfstream Aerospace Corporation, Dallas,Texas. Brad Kraft , Gulfstream Aerospace Corporation, Dallas, Texas. David Neese , Gulfstream Aerospace Corporation, Dallas, Texas. Moshe Kollet , Israel Aerospace Industries, Ben Gurion Airport,Israel Charly Gaber, Gulfstream Aerospace LP,Ben Gurion Airport, Israel