July 23, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue 

SE West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Associated 

AirCenter 

AAC-CERT -15-054 

Page 1 of7 

Subject: Petition for Exemption - Relief from Title 14 CFR Parts §25.785(h)(1) 

Flight Attendant direct view, §25.785(d) firm handholds along each aisle, 

§25.813(e) interior doors between passenger compartments, and §25.815 

Minimum Aisle Width. 

Reference: (1) Airbus Company, Model A320-232, S/N 6659 

(2) A320-232 Floorplan drawing 

(3) AAC-CERT-15-033, "Petition for Exemption" dated May 07,2015 

Dear Office of the Chief Counsel: 

Enclosed please find Associated Air Center's (AAC) Petition for Exemption. This petition 

is a correction to the initial application (reference 3) made by AAC and based on the 

email from Transport Airplane Directorate, dated July 21, 2015. The following were the 

corrections made to the initial application (reference 3): 

(1) Corrected all 25.785(h)(2) references to 25.785(h)(1 ), amdt 25-51. 

(2) Corrected all 25.785(j) references to 25.785(d), amdt 25-51. 

(3) Removed all references to 25.853(d), since it is not necessary. 

( 4) Added a request that the privileges of this Exemption be extended outside of the 

United States. 

This exemption is for the Airbus A320-232, serial number 6659. Most of the text used in 

this request has been taken from (1) Grant of Exemption obtained by AAC in Exemption 

No. 8460 for Boeing Model 747-400, (2) Partial Grant of Exemption obtained by AAC in 

Exemption No. 10809 for Boeing Model 747-8, (3) Partial Grant of Exemption obtained 

by L-3 Communications in Exemption No. 10686 for Boeing Model 747-8, (4) Grant of 

Exemption obtained by The Boeing Company in Exemption No. 10879 for Boeing Model 

8321 Lemmon Ave 214 350 4111 

Dallas, TX 75209 214 351 2375 
MC-CERT-15-054 

Page 2 of? 

787-8 and -9 airplanes, (5) Partial Grant of Exemption obtained by Airbus Company in 

Exemption No. 7489 for Airbus Model A319 CJ airplanes. 

Associated Air Center requests the requirement for Federal Register publication be 

waived since good cause has been demonstrated by the previous grants for exemption. 

These prior Exemptions, on the same regulations, have allowed interested persons to 

submit their comments. 

Associated Air Center requests that the same relief with the same prov1s1ons be 

extended to include this Airbus A320-232, S/N 6659, subject of our request for 

Exemption (refer to attached reference (2) floorplan). AAC request that the privileges of 

this Exemption be extended outside of the United States. When in service, this airplane 

is expected to operate as "private, not for hire" category. 

We respectfully await the Federal Aviation Administration's approval. 

In case additional information is required to process this application for Exemption, 

please do not hesitate to contact me at (972) 559-7062, or by email at jose.moravargas@associated .aero. 

Sincerely, 

Jose M a-Vargas 

Certification Director 

Associated Air Center 
EXEMPTION REQUEST 

A320-232 S/N 6659 

Applicable Regulations 

AAC-CERT -15-054 

Page 3 of7 

14 CFR Part §25. 785(h)(1) Amendment 25-51. Flight Attendant direct view. 

14 CFR Part §25.785(d) Amendment 25-51. Firm handholds along each aisle. 

14 CFR Part §25.813(e) Amendment 25-46. Interior doors between passenger 

compartments and emergency exits. 

14 CFR Part §25.815 Amendment 25-38. Requires minimum aisle width in the 

passenger compartment. 

Background 

Associated Air Center requests that the relief provided for the airplanes covered by 

previously granted Exemptions, relative to the subject requirements be expanded to 

include the Airbus A320-232, S/N 6659: 

1. Exemption No. 8460, Docket No. FAA-2004-18913, Grant of Exemption 

from §§25.785(d) and §§25.813(e) for Boeing Model 747-400 airplane. 

2. Exemption No. 10809, Docket No. FAA-2013-0277, Partial Grant of 

Exemption from §§25.785(h)(2), §§25.785(j), §§25.813(e), §§25.815, and 

§§25.853(d) for Boeing Model 747-8 airplane. 

3. Exemption No. 10686, Docket No. FAA-2012-0707, Partial Grant of 

Exemption from §§25.785(h)(2), §§25.785(j), §§25.791(a), §§25.795, 

§§25.813(e), §§25.815, and §§25.853(d) for Boeing Model 747-8 airplane. 

4. Exemption No. 10879, Docket No. FAA-2013-0015, Grant of Exemption 

from §§25.813(e) for Boeing Model 787-8 and -9 airplane. 

5. Exemption No. 7489, Docket No. FAA-2000-8262, Partial Grant of 

Exemption from §§25.785(h)(2), §§25.807(d)(7) and §§25.813(e) for Airbus 

Model A319CJ airplane. 

NOTE: 14 CFR 25.785(h)(1) amdt 25-51 & 14 CFR 25.785(d) amdt 25-51 is the same as 14 CFR 

25.785(h)(2) & 14 CFR 25.785(j) at amdt 25-72. 

Discussion 

The Federal Aviation Regulations (FARs) do not consider the situation of private use not 

for hire transport category airplanes, in the 14CFR Part 25 requirements. Those 

requirements are predicated on airline common carrier, commercial passenger 

operations carrying fare paying passengers from the general public. Associated Air 

Center believes that the design of an airplane for private use, and the associated 

operation of the airplane in private use, should justify an exemption, based on the fact 

that 14CFR Part 25 regulations do not currently cover or consider such a design and 

operation. 
AAC-CERT -15-054 

Page 4 of7 

The FAA position of previous Exemptions listed above for the Boeing Models 747-4, 

747-8, 787-8/-9, and A319 not requiring flight attendant direct view, firm handhold along 

each aisle, interior doors permitted with provisions, and minimum aisle width during non 

critical flight phases, should also be granted to the Airbus Model A320-232 Serial 

Number 6659. 

14 CFR 25.785 (h) (1): Flight attendant direct view. 

The requirement for flight attendant seats to be located to provide a direct view of the 

passenger cabin is not practical for compliance with executive type interior to be 

installed on the Airbus A320-232 airplane. The complexity of the interior arrangement, 

coupled with the need to retain proximity to emergency exits is impractical to 

demonstrate compliance. Reference Exemption No. 10809, 10686 & 7489 for 

compliance method to the requirements identified in these Exemptions. 

14 CFR 25.785 (d): Firm handholds along each aisle 

The requirement for a firm handhold along aisles cannot be met for certain areas in the 

passenger cabin due to wide open spaces between individual seat backs which typically 

provide an adequate handhold. This is prevalent in dining rooms, lounges, offices, 

bedrooms and lavatories. With the cabin spaciousness, there is a readily identifiable 

"aisle" throughout. Any feature hanging down from the ceiling would diminish the 

appearance of the high quality interior and is not acceptable to the customer. Reference 

Exemption No. 8460, 10809, & 10686 for compliance method to the requirements 

identified in these Exemptions. 

14 CFR 25.813 (e): Prohibits installation of interior doors between passenger 

compartments and emergency exits. 

Private areas or dining rooms will often need to span the whole cabin or a portion of the 

cabin in order to be practical. For such arrangements, privacy can only be provided by 

means of doors, and therefore, an exemption is needed to allow full use of airplane 

capabilities without compromising safety for those onboard. Interior doors between 

passenger compartments and between the exits will be compliant with the requirements 

previously identified in Exemptions No. 8460, 10809, 10686, 7 489 and 10879. 

14 CFR 25.815: Prohibits aisle width reduction during all phases of flight. 

Unlike typical commercial aircraft, private use airplanes (i.e. not for hire or common 

carriage) have seats that can be moved or rotated during flight operations. The seating 

can be reconfigured to accommodate meetings and other arrangements. Some of these 

arrangements can reduce the aisle widths below those specified in 14 CFR 25.815. 

Advisory Circular (AC) 25-17 A contains a "private use" provision which provided aisle 

width reduction acceptability only during en-route flight and only if clear instructions are 

provided requiring that the seats be positioned for taxi, takeoff and landing in an 

arrangement that meets the required aisle width. AAC proposes to be compliant with the 

criteria established in AC 25-17 A for private use aircraft. Reference Exemption No. 

10809 & 1 0686 for compliance method to the requirements identified in these 

Exemptions. 
Basis for Exemption 

AAC-CERT-15-054 

Page 5 of? 

As stated in Exemptions No. 8460, 10809, 10686, 10879 and 7489, the FAA is aware 

that the precedent has been established for other private use narrow/wide body 

airplanes to be exempted from the subject requirements. 

Exemption Will Be In The American Public Interest 

Approval of this request for certain exemptions for the Airbus Model A320-232 when 

configured for executive application, and operated under FAR Part 91 or Part 125, is in 

the public interest of the people of the United States of America. 

1. Given the proliferation of Executive Configured Transport Category Airplanes 

currently taking place, and anticipated in the near future, approval of these 

exemptions will enable the United States manufacturers of Transport Category 

Airplanes to effectively compete in this expanding market. 

2. Additional sales of United States manufactured airplanes outside of the traditional 

airline market, and completion of many of them at United States owned and 

operated Aircraft Completion Facilities, will serve to increase the profitability of these 

manufacturers and their supplying/supporting companies. 

3. Stability and improved financial performance of these United States companies 

gives greater job stability to the workers employed by the companies, causing a 

stabilizing influence to the United States economy, due to the consumer spending 

activities associated with stable workers. 

4. Improved financial performance of United States owned and operated corporations 

and increased work force stability translates to continued and improved local, state 

and federal tax revenues which in turn adds to the stability of the total United States 

economy. 

5. Improved financial performance allows United States corporations to continue to 

invest in Research and Development allowing the United States to maintain or 

improve its competitive position in the world economy. 

6. A large number of these types of airplanes will probably be sold to "offshore" clients, 

improving the United States balance of trade. 

7. Since the passengers aboard these airplanes will not be revenue paying customers 

of the airlines, there can be no degradation to airline passenger safety, and therefore 

no detrimental impact on the public at large. 

Conclusion 

As reference to the previously noted partial/granted Exemptions, the FAA's conclusion 

on each of those Exemptions is pasted below: 

1. Exemption No. 8460 stated that "the FAA found that a grant of exemption was in 

the public interest and would not adversely affect safety. Therefore, pursuant to 

the authority contained in § 49 U.S.C. §§ 40113 and 44701 the Administrator 
AAC-CERT-15-054 

Page 6 of7 

granted Associated Air Center an exemption from the requirements of Title 14 

CFR Part 25.785 (d) and 25.813(e) for a Boeing Model 747-400. 

2. Exemption No. 10809 stated that "the FAA found that a partial grant of 

exemption was in the public interest. Therefore, pursuant to the authority 

contained in 49 U.S.C. 40113 and 44701, the administrator granted Associated 

Air Center an exemption from the requirements of Title 14 CFR Part 

25.785(h)(2), 25.785(j), 25.813(e), 25.815, and 25.853(d) and special conditions 

25-368-SC with provisions for a Boeing Model 747-8. 

3. Exemption No. 10686 stated that "the FAA found that a partial grant of 

exemption was in the public interest. Therefore, pursuant to the authority 

contained in 49 U.S.C. 40113 and 44701 the Administrator granted L-3 

Communications Integrated Systems, L.P., an exemption from the 

requirements of Title 14 CFR Parts 25.785(h)(2), 25.785(j), 25.791(a), 25.795, 

25.813(e), 25.815, and 25.853(d), and Special Condition 25-368-SC, with 

provisions for a Boeing Model 7 4 7-8. 

4. Exemption No. 7489 stated that, "the FAA found that a partial grant of 

exemption was in the public interest. Therefore, pursuant to the authority 

contained in 49 U.S.C. §§ 40113 and 44701 the Administrator granted The 

Airbus lndustrie, an Exemption from the requirements of Title 14 CFR Part 

785(h)(2), 25.807(d)(7) and 25.813(e) for Airbus A319CJ airplane. 

5. Exemption No. 10879 stated that "the FAA found that a grant of exemption was 

in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 

40113 and 44701 the Administrator granted The Boeing Company, an 

exemption from the requirements of Title 14 CFR Part 25.813(e) at amendment 

25-116 with provisions for Boeing 787-8 and -9 airplanes. 

Associated Air Center seeks similar relief with the same provisions for the Airbus Model 

A320-232, S/N 6659 airplane. In addition, AAC request that the privileges of this 

Exemption be extended outside of the United States. Granted Exemptions as described 

in Exemptions listed above, are subject to the following provisions: 

~ The airplane must not be operated for hire or offered for common carriage. This 

provision does not preclude the operator from receiving remuneration to the 

extent consistent with 14 CR parts 125 and 91, subpart F, as applicable. 

~ A majority of flight-attendant seats must be oriented to face the passenger cabin. 

~ Each door between passenger compartments must be frangible (only manually 

operated pocket doors are installed- no electrical doors). 

Doors that fall into Category 1 must be in the open position during taxi, takeoff, 

and landing when the room is occupied. 

Doors that fall into Categories 2, 3, or 4 must be in the open position during taxi, 

takeoff and landing, regardless of occupancy of the room. 

Doors that fall into Category 5 must be in the closed position during taxi, takeoff, 

and landing. 
AAC-CERT-15-054 

Page 7 of7 

Appropriate procedures must be established to both signal the flight crew in the 

event a door between passenger compartments is not in the proper position, and 

prohibit TT&L. Doors in Category 5 do not need to comply with this requirement. 

For Category 5 doors, installing placards located on or near the door, and 

indicating that the door must be closed for TT&L is acceptable. 

Doors between passenger compartments must have dual means to retain them 

in the open position. Each means must be capable of withstanding the inertia 

loads specified in§ 25.561. Doors in Category 5 do not need to comply with this 

requirement because they are required to be closed for TT&L. 

A means to signal the flight crew must be in place in the event of a fire in an 

isolated passenger compartment, and the detection system must meet the 

requirements of§ 25.858(a) through (d). 

Compliance is required with § 25.815, except that aisle width may be reduced to 

0 inches between any cabin furnishing (e.g seat, table, or divider) during in-flight 

operations only, provided that all areas of the cabin remain easily accessible in 

the event of an emergency (e.g., in-flight fire or decompression) with interior 

furnishings in the most adverse positions. Accessibility must be demonstrated to 

the FAA by test or analysis supported by test data, or, in circumstances agreed 

to by the FAA, by inspection. 

Aisle width requirements of § 25.815 must be maintained during Taxi, Takeoff 

and Landing. 

Any cabin furnishing (e.g seat, table, or divider) that can be positioned to intrude 

into the aisle must be clearly placarded to be in the proper location (i.e not 

intruding into the minimum required aisle) during Taxi, Takeoff and Landing.