UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL A VIA TI ON ADMINISTRATION 

RENTON, WASHING TON 98057-3356 

In the matter of the petition of 

Exemption No. 17058 

VT DRB Aviation Consultants Regulatory Docket No. FAA-2015-8751 

for an exemption from§ 25.817 of Title 

14, Code of Federal Regulations 

GRANT OF EXEMPTION 

By letter dated October 23, 2015, Mr. Darryl Seow, Vice President-Certification, VT DRB 

Aviation Consultants, 27326 US Highway 281 North, San Antonio, Texas, 78260, petitioned the 

Federal Aviation Administration (FAA) for an exemption from the requirements of§ 25.817 of 

Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted, would permit four 

seats abreast on one side of the aisle in a dining room as part of an executive (VIP) interior 

installation on a Boeing Model 777-200 airplane. 

The petitioner requests relief from the following regulation: 

Section 25.817 - On airplanes having only one passenger aisle, no more than three seats 

abreast may be placed on each side of the aisle in any one row. 

The petitioner supports its request with the following information: 

This section quotes the relevant information from the petitioner's request with minor edits for 

clarity. The complete petition is available at the Department of Transportation's Federal Docket 

Management System, on the Internet at http://regulations.gov, in Docket No. F AA-2015-8751. 

Aisle with Four Seats Abreast 

The owner/operator of the aircraft desires to have a dining room with a dining table that 

seats four on each side, which equates to an aisle with four seats abreast. The petitioner 

proposes that the four seats abreast are placed on only one side of the aisle ( emergency 

exit path) of the row, which leaves fewer seats abreast along that row than a passenger 

plane with three seats abreast on each side of the aisle on any one row. Thus, the 
modification does not impact the passengers' ability to egress; there are no seats or 

monuments directly in front of the said seats to impede passengers from gaining access to 

the aisle leading to emergency exits. 

Airplane Model 

This petition is submitted in support of the installation of a VIP interior on a Boeing 

Model 777-200 (reference single-use Supplemental Type Certificate (STC) Project 

Number ST1935DRB-T). The applicable type certificate data sheet is TOOOOlSE, 

revision 37, with a certification basis of part 25, effective February 1, 1965, as amended 

by Amendments 25-1 through 25-82. 

International Operations 

The operator of this U.S.-registered aircraft, who has contracted with VT DRB Aviation 

Consultants for the installation of a VIP interior, routinely flies to Europe, Eastern 

Europe, etc. The dining table that seats four on each side is expected to remain a part of 

this aircraft interior in the same geographic regions. Therefore, in accordance with 14 

CFR 11.83, VT DRB Aviation Consultants requests that this exemption apply to both 

domestic and international operations. 

Extent of Relief and Safety 

VT DRB Aviation Consultants proposes relief from 14 CFR 25.817 (an aisle with three 

seats abreast) in lieu of an aisle with four seats abreast on only one side of the aisle. It is 

shown that this modification does not impact the passengers' ability to egress. There are 

no seats or monuments directly in front of the said seats to impede passengers from 

gaining access to the escape path. 

Safety is the primary concern of the VIP interior installation. Safety requirements of the 

original type certification of the aircraft will be complied with, as defined by the aircraft 

type certificate data sheet (TOOOO 1 SE). 

Public Benefit 

Granting this petition for exemption is clearly in the interest of transport category airplane 

modifiers given the proliferation of transport category VIP interior configurations such as 

this one. Approval of this exemption will enable manufacturers who employ workers in 

the U.S.A. to effectively compete in this expanding market that has a preference for 

longer dining tables. Additionally, sales of VIP configured interiors outside of the 

traditional airline market will serve to increase manufacturers' profitability and that of 

their suppliers/vendors, which equates to improved financial performance in the U.S.A. 

and the U.S.A. 's partners abroad. 

VT DRB Aviation Consultants respectfully requests that this petition be granted. 

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Federal Register publication 

Although the petitioner requested that action on its petition not be delayed for publication in the 

Federal Register, the FAA found that the petition, if granted, would set a precedent. Therefore, 

to allow an opportunity for the public to comment on the petition, a summary of it was published 

in the Federal Register on April 27, 2016 (81 FR 24930). No comments were received. 

The FAA's Analysis 

The FAA agrees that granting an exemption would be in the public interest for the reasons stated 

by the petitioner. As more transport category airplanes have been configured ( or reconfigured) 

for private use, the FAA has given considerable attention to the issue of appropriate regulation of 

such airplanes. Some of the current regulations governing design certification of transport 

category airplanes are not compatible with private use of such airplanes. Because of this, we 

have received a number of petitions for exemption from certain regulations. We have granted 

such exemptions when we find that to do so is in the public interest and when it does not 

adversely affect the level of safety provided by the regulations. 

Low passenger density (i.e., VIP) airplane interiors were not considered when promulgating 

§ 25.817. According to the petitioner's certification plan, the airplane will have a maximum of 

52 passengers and 7 crewmembers, and will be operated as private use, not for hire, and not for 

common carriage. The passengers will have a greater familiarity with the airplane interior 

configuration than passengers on standard commercial flights. For these reasons, the overall 

evacuation capability is improved, compared to a high passenger density airline configuration 

that could be several hundred passengers. The proposed dining room configuration, with 

opposed four abreast seating on one side of the aisle and no seating on the other side of the aisle, 

provides an acceptable level of safety. 

The FAA's decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701 delegated to me by 

the Administrator, I grant VT DRB Aviation Consultants an exemption from 14 CFR 25.817 to 

the extent necessary to allow the installation of a dining room that seats four on each side of a 

dining table, all of which is located on one side of the aisle. 

This exemption is subject to the following operating limitation and conditions. Operating 

limitation 1 must be documented in the limitations section of the airplane flight manual. 

1. 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 CFR parts 125 and 91, subpart F, as applicable. The total maximum 

occupancy of the airplane is limited to 59 persons, including flight crewmembers. 

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2. No seats or monuments may be installed directly in front of the dining room seats that 

impede passengers from gaining access to the escape path. 

3. Only one instance is allowed of a configuration with four seats abreast on the forward and 

aft sides of the dining table on one side of the aisle. No seats are allowed on the other 

side of the aisle from this seat configuration. 

Issued in Renton, Washington, on AUG OB 2016 

Michael Kaszycki 

Assistant Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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