July23, 2015

U.S. DepartmentofTransportation Docket ManagementSystem 1200 NewJerseyAvenue SE West Building Ground Floor, Room W12-140 Washington, DC 20590 

# Associated AirCenter

AAC-CERT-15-054 Page 1of7

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) interiordoors between passenger compartments, and §25.815 MinimumAisle Width.

Reference: (1) Airbus Company, Model A320-232, S/N 6659 (2) A320-232 Floorplan drawing (3) AAC-CERT-15-033, "Petitionfor Exemption" dated May07,2015

DearOffice ofthe ChiefCounsel:

Enclosed please find Associated AirCenter'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 madeto the initial application (reference 3): (1) Corrected all 25.785(h)(2) referencesto 25.785(h)(1), amdt25-51. (2) Corrected all 25.785(j) references to 25.785(d), amdt25-51. (3) Removed all referencesto 25.853(d), since it is not necessary. (4) Added a request that the privileges ofthis Exemption be extended outside ofthe United States.

This exemption is forthe Airbus A320-232, serial number6659. Mostofthe text used in this request has been taken from (1) GrantofExemption obtained byAAC in Exemption No. 8460 for Boeing Model 747-400, (2) Partial Grant of Exemption obtained byAAC 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 byThe Boeing Company in Exemption No. 10879for Boeing Model 8321 Lemmon Ave 214 350 4111 Dallas, TX 75209 214 351 2375MC-CERT-15-054 Page 2of? 787-8 and -9 airplanes, (5) Partial Grant of Exemption obtained by Airbus Company in Exemption No. 

### 7489forAirbus Model A319 CJ airplanes.

Associated Air Center requests the requirement for Federal Register publication be waived since good cause has been demonstrated bythe previous grantsforexemption. These prior Exemptions, on the same regulations, have allowed interested persons to submittheircomments.

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 (referto attached reference (2) floorplan). AAC request thatthe privileges of this Exemption be extended outside ofthe United States. When in service, this airplane is expected to operate as "private, notfor hire" category.

We respectfully awaitthe Federal Aviation Administration's approval.

In case additional information is required to processthis applicationfor Exemption, please do not hesitateto contact me at (972) 559-7062, orby email atjose.moravargas@associated.aero. Sincerely,

Jose M a-Vargas Certification Director Associated AirCenterEXEMPTION REQUEST A320-232 S/N 6659 Applicable Regulations AAC-CERT-15-054 Page 3of7

14 CFR Part§25.785(h)(1) Amendment25-51. FlightAttendantdirect view. 14 CFR Part§25.785(d) Amendment25-51. Firm handholdsalong each aisle

. 14 CFR Part §25.813(e) Amendment 25-46. Interior doors between passenger compartmentsandemergencyexits. 14 CFR Part §25.815 Amendment 25-38. Requires minimum aisle width in the passengercompartment. 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 includethe AirbusA320-232, 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) & 14CFR25.785(j) atamdt25-72. Discussion The Federal Aviation Regulations (FARs) do not considerthe situation ofprivate 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 ofthe 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 4of7 The FAA position of previous Exemptions listed above for the Boeing Models 747-4, 747-8, 787-8/-9, and A319 not requiring flight attendantdirectview, firm handhold along each aisle, interiordoors permitted with provisions, and minimum aisle width during non critical flight phases, should also be granted to the Airbus Model A320-232 Serial Number6659. 14 CFR25.785 (h) (1): Flightattendantdirect view. The requirement for flight attendant seats to be located to provide a direct view ofthe passenger cabin is not practical for compliance with executive type interior to be installed on the Airbus A320-232 airplane. The complexity ofthe 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 CFR25.785 (d): Firm handholds alongeach aisle The requirementfor afirm handhold along aisles cannot be metforcertain areas in the passengercabin dueto 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 ofthe high quality interiorand 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 andemergencyexits. Private areas ordining rooms will often need to span the whole cabin ora portion ofthe cabin in orderto 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 passengercompartments and between the exits will be compliant with the requirements previously identified in Exemptions No. 8460, 10809, 10686, 7489 and 10879. 14 CFR25.815: Prohibits aisle width reduction during allphases offlight. 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 otherarrangements. Some ofthese arrangements can reduce the aisle widths below those specified in 14 CFR 25.815. Advisory Circular (AC) 25-17A contains a "private use" provision which provided aisle width reduction acceptability only during en-route flight and only ifclear instructions are provided requiring that the seats be positioned for taxi, takeoff and landing in an arrangementthat meetsthe required aisle width. AAC proposesto be compliantwith the criteria established in AC 25-17A for private use aircraft. Reference Exemption No. 10809 & 10686 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 airplanesto 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 interestofthe people ofthe United States ofAmerica. 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 Airplanesto 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 profitabilityofthese manufacturersand theirsupplying/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 ofthe 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 numberofthese types ofairplaneswill probably be sold to "offshore" clients, improving the United States balance oftrade. 7. Since the passengers aboard these airplanes will not be revenue paying customers ofthe airlines, there can be no degradation to airline passengersafety, and therefore no detrimental impacton the public at large.

Conclusion As reference to the previously noted partial/granted Exemptions, the FAA's conclusion on each ofthose Exemptions is pasted below:

1. Exemption No. 8460 stated that "the FAAfound that agrantofexemption 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 AdministratorAAC-CERT-15-054 Page 6of7 granted Associated Air Center an exemption from the requirements ofTitle 14 CFR Part 25.785 (d) and 25.813(e)fora 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-SCwith provisionsfora 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 provisionsfora Boeing Model 7 47-8. 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)forAirbus A319CJ airplane. 5. Exemption No. 10879 stated that "the FAA found that a grant ofexemption 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 ofTitle 14 CFR Part 25.813(e) at amendment 25-116with provisionsfor Boeing 787-8 and -9 airplanes. Associated Air Centerseeks similar reliefwith the same provisionsforthe Airbus Model A320-232, S/N 6659 airplane. In addition, AAC request that the privileges of this Exemption be extended outside ofthe United States. Granted Exemptions as described in Exemptions listed above, are subjectto the following provisions:**~** The airplane must not be operated for hire oroffered for common carriage. This provision does not preclude the operator from receiving remuneration to the extent consistentwith 14CR parts 125 and 91, subpart F, as applicable.**~** A majorityofflight-attendant seats must be oriented to face the passengercabin.**~** Each door between passenger compartments must be frangible (only manually operated pocketdoorsare installed- no electrical doors). Doors that fall into Category 1 must be in the open position during taxi, takeoff, and landingwhen the room is occupied. Doors thatfall into Categories 2, 3, or4 must be in the open position during taxi, takeoffand landing, regardless ofoccupancyofthe room. Doors thatfall into Category 5 must be in the closed position during taxi, takeoff, and landing.AAC-CERT-15-054 Page 7of7 Appropriate procedures must be established to both signal the flight crew in the event adoorbetween passengercompartments is not in the proper position, and prohibitTT&L. Doors in Category 5do not need to complywith this requirement. For Category 5 doors, installing placards located on or near the door, and indicating thatthe doormust be closed forTT&L is acceptable. Doors between passenger compartments must have dual means to retain them in the open position. Each means must be capable ofwithstanding the inertia loads specified in§25.561. Doors in Category 5do not need to complywith this requirement becausetheyare required to be closed forTT&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, ordivider) during in-flight operations only, provided that all areas ofthe 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 bythe FAA, by inspection. Aisle width requirements of § 25.815 must be maintained during Taxi, Takeoff and Landing. Any cabin furnishing (e.g seat, table, ordivider) that can be positioned to intrude into the aisle must be clearly placarded to be in the proper location (i.e not intruding intothe minimum required aisle) during Taxi, Takeoffand Landing.