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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 Gulfstream 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. The 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 through 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 equipped with multiple-passenger interior 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 operators request the installation of privacy cabin doors 

when outfitting of the aircraft is accomplished. 

Title 14 Code of Federal Regulations (14 CFR) section 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 and landing. A second condition is that the door 

(or other suitably located partition or bulkhead) must 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 certification basis for the model G250 airplane. 
 

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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 

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 landing 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 decompression 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” positive manual latch (third in the door assembly), 

which will virtually prevent the door from deploying 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 into the aisle. This condition will be easily 

noticeable by the crew in preparation for taxi, 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 design requirements which they must comply to be 

eligible to use this exemption. 
 

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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 

Figure 1 – Model G250 Fwd RH Pocket Door Installation 

 

Figure 2 – Pocket Door Latched and Unlatched Condition 
 

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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 

In the past, FAA’s position 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 under 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 passengers 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 probability of failure with the door in the deployed 

position is highly unlikely due to the triple door latch approach specified in items 2 and 3 above. With 

a fail-resistant door design, the importance of how familiar 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 operating 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 during an emergency landing. To that end GAC has 

developed step-by-step procedure to educate passengers 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 achieved 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. These procedures will be reviewed, 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 seats next to an emergency exit. That is, this seat 

position would be required to meet similar requirements 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 emergency 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 emergency 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 emergency 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 evaluation where the pocket door is installed in the 

aircraft. 

iii. The pass/fail criteria will be agreed upon with the FAA, and could consist of demonstrating 

that both evacuation evaluations were completed 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), 
 

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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 

i.e. pax flow rate = 90 sec/44 pax = 2.05 sec/pax. Thus, the proposed tmax would be 2.05 x 

(G250 max pax capacity), or tmax = 2.05 x (19) = 38.9 seconds. For the actual test the number 

of test subjects may be reduced to minimize the risk of injuries, therefore, tmax will be based on 

the actual test subject count. Both tests would 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 separated 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 without 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 configuration. The other group would make the trials in 

the reverse order. The elapsed escape time will 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 pocket door by comparing the average time of the 

groups to evacuate the aircraft. However, the intent of the tests will be to demonstrate that both 

configurations can be evacuated with an averaged time less than the tmax defined above. 

GAC is of the opinion that these tests will demonstrate 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 Appendix 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 configuration 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 the 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. 
 

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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 

Operation Outside of the United States

The European Aviation Safety Administration (EASA) Certification Specifications (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) 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 their 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 doors 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 positive 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