AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

1 June 8 , 2011 U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Floor Room W1 2
- 140 Washington, DC 2059 0 SUBJECT: Petition for Exemption from 1 4 CFR 25.785(h) ( 1 ) flight attendant direct view , 14 CFR 25.813(e) doors between passenger compartments , 14 CFR 25.785(d ) firm handhold, and 14 CFR 25.853( a ) (1) maximum heat release rates for large panel cabin interior materials on an Airbus Model A34 0
-211 airplane. Ref: GDC ODA STC Project no. GD C
- P515
- STC BACKGROUND: Gore Design Completion, ltd. (GDC) has been contracted for the completion of an executive business interior for an Airbus Model A340
-211 airplane . The FAA Organization Management Team (OMT) has reviewed and accepted our ODA Project Number GDC
- P515
- STC for this project

. The certification basis for the Airbus A340
-211 is Part 25, Amendment 25
- 1 through 25
-63 inclusive plus Amendments 25
-65, 25
-66, and 25
- 77

. T he airplane will be configured for a much lower passenge r density compared to normal airline service. The airplane will not be operated for hire or offered for common carriage, although this will not preclude the operator from receiving remuneration to the extent consistent with 14 CFR parts 125 and 91, subpart F, as applicabl e. The operation of the aircraft will be of a restricted nature as compared to a commercial transport, and the flight and cabin crews will have familiarity with the interior configuration. For the reasons listed above, Gore Design Completion, Ltd. has pre pared a petition for exemption to the following regulations: 14 CFR 25.7 85(h)( 1 ) , Amendment 25
-64
- F light attendant seats must be located to provide direct view of the cabin area.AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

2 14 CFR 25.813 (e) , Amendment 25
-46
- No door may be installed in any parti tion between passenger compartments

. 14 CFR 25.785( d ) , Amendment 25
-64
- Requires a “firm handhold” along each aisle. 14 CFR 25.853( a ) (1) , Amendment 25
-66
- Limits maximum heat release rates for large panel cabin interior materials.
DISCUSSION: 14 CFR Part 25 governs design certification of t ransport category airplanes

. The primary intent of these regulations, as written, are to be certain that airplane manufacturers provide the appropriate design features to meet the standards necessary to protect the traveling public. Clearly, there is a requirement “in the public interest” and in the interest of safety to provide regulatory guidelines for certification. However, it is also very clear these regulations are intended to regulate the certification of
“ commercial” airplanes , which are “for hire” to the general public. Wh ile the greate st majority of these regulations represent a common sense inclusion for any aircraft regard less of it’s intended use, a few are obviously intended to regulate situations t hat are specific to an airline, or for hire operation. Wh en a transport category airplane is operated under 14 CFR Part 91 or Part 125, some of the Part 25 rules have acceptance criteria that are not compatible with th e type of operation and the intended use of th is airplane

. The FAA clearly recognizes these differences as evidenced by the issuance of Exemption numbers 6820A , 6822, 7120A, 7489 , and numerous others which eliminate many of the more onerous regulations when applied to “private use, not
-for
- h ire” operations under 14 CFR Part 91 and Part 125

. BASIS FOR EXEMPTION : The airplane that is the subject of this petition is an Airbus Model A340
-211 . It is privately owned and will be operated under Part 125 regulations or other equivalent non - US forei gn national operational standard. In accordance with 14 CFR P art 11.81(h), we request to exercise the privilege of this exemption outside the United State s since the operator of the airplane is located in Saudi Arabia

.AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

3 The interior configuration being in stalled in this airplan e will provide seating for seventy seven ( 77 ) passengers (see attached floor plan drawing)

– 5 passengers in the private lounge , 5 passengers in the mid cabin lounge , 1 passenger in the main entrance, 11 passengers in the main majlis , 12 passengers in the dining lounge , and 43 passengers in the guest seating area

. There is one aft facing flight attendant styl e seat in the communication center (located at the center of the aircraft aft of the center seats in the guest seating area ) , bu t it will not be usable for taxi, takeoff, and landing. The remaining seats in the cabin are to be occupied by crew only

– 2 Cabin Attendants in door 1 L area, 2 Cabin Attendants in the door 2L area, 1 Cabin Attendant each at door 3R and 3L , and 4 Cabin Attendants in the door 4 area. The maximum certified passenger count for this airplane is 3 75 seats

. The passenger count of the subject airplane represents 24 % of the capacity allowed for this airplane. Regulation 14 CFR 25.785 (h)( 1 ) Customers are buyin g these large airplanes as an extension of the office and are requiring privacy areas within the airplane sometimes spanning the whole cabin, such as board rooms, bedrooms, lavatories, and lounges rather than traditional airline type seating. An exemption to the flight attendant direct view requirement is therefore needed to allow the full use of the airplane capabilities. In addition, this requirement was incorporated into the FAA rules through amendment 25
- 51. Out of the comments submitted to the FAA d uring the NPRM comments period, two said that, if galley doors were used as emergency exits, the placement of an attendant seat near the exit preclude compliance with the requirement that the attendant be provided with direct view of the cabin area. To cover this situation, it was suggested that the requirement be conditioned to apply in so far as practicable and without compromising the proximity to required floor level exits. The FAA concurred and further stated in the preamble to the final rules that “l ocation of the flight attendant seats near the floor level exits in this case is more important tha n the requirement to have a direct view of the cabin”. The final rule was revised from the NPRM proposal to address this relative importance. Regulation 1 4 CFR 25.813(e) There will be eleven mechanical “pocket” type doors located as follows: between the passageway and the private lounge , between the passageway and the main entrance , a double pocket door between the main entrance and mid cabin lounge, between the main entrance and main majlis , between the dining lounge and VIP lav areas (2) , between the center passageway and the RH/LH aft lounges (2), and a double pocket door between the aft lounge and the guest seating area.AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

4 There will be a swing door between the master bedroom and private lounge , and a swing door installed on th e communication center (located at the center of the aircraft aft of the center seats in the guest seating area

. However, these doors are not located between passenger compartments and these doors do not apply to this exemption request. D oors between passenger compartments will have the following design features: dual latches (each of which are able to withstand the forces defined by 14 CFR 25.561) to secure the door in the open p osition, cockpit annunciation of the door position for taxi , take
-off and landing, and the doors will be frangible in the event that they should become stuck in the closed position. Logic will be provided in the door annunciation system such that if passen ger(s) are located in the private lounge the door to the hallway will be open for taxi, take
-off, and landing and when there are no passengers in the private lounge this door will be closed. The master bedroom door will be placarded to be closed for taxi , take
-off and landing and this door will be frangible. The communication room door will be placarded to be closed for take
-off and landing , and this door should open in the direction that would be automatically closed by the evacuation flow. Regulation 14 CFR 25.785( d ) Customers are buying airplanes because they wish to create a spacious and impressive atmosphere they are used to. The very wide body of the A340 satisfies these requirements. On the other hand, the requirement for firm hand hold along the a isles cannot be met for certain areas in the passenger cabin due to the wide open spaces, specifically, the main majlis and the dining/lounge room . On a typical “commercial” flight this requirement is met by the individual seat backs which typically provid e an adequate hand hold for a passenger to stabilize themselves in the aisle during turbulence. In fact due to the spaciousness of the interior there is no readily identifiab le “a isle” in the main majlis and dining lounge

. Any construction hanging from th e ceiling would ruin the appearance of the high quality interior, is not acceptable to the customer, and may add additional safety concerns. It has been acknowledged by the FAA, that the passengers on this type of airplane are typically the same people on most of the trips. Familiarity with the airplane layout and operation provides an addition benefit towards the level of safety. Regulation 14 CFR 25.853( a ) (1) Wi th the sudden growth in the VIP or executive transport airplane market together withAIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

5 the si multaneous introduction of more stringent interior material flammability standards, aircraft interior modifiers have been faced with a serious dilemma in resolving the styling requirements of the private aircraft owner/operator of these executive aircraft and the flammability requirements imposed by § 25.853. For the most part, modifiers have been able to simultaneously satisfy both the styling and interior material flammability requirements of § 25.853(a) and (c) with great effort and diligence; however, s ome of the materials required in these aircraft interiors cannot pass the 65/65 heat release requirement of § 25.853( a ) (1) no matter how diligent the designer is. It is not within the grasp of current technology to make certain natural materials conform to these standards and the owners of these airplanes define, in fact demand, the use of these materials. It should be understood that these aircraft must be outfitted in a style not unlike fine executive board rooms or luxurious residences to satisfy their p rivate users. OCCUPANT SAFETY CONSIDERATIONS : 14 CFR 25.785(h)( 1 ) The arrangement of the aircraft interior will provide that a majority of flight
-attendant seats will be oriented to face the passenger cabin. In the guest seating area, where a more tradi tional seating arrangement is used, the flight attendants will have a direct view of the cabin. Considering the smaller number of occupants in this aircraft , and the familiarity of the flight and cabin crews with the specific airplane, the passengers and t he interior arrangement, and the wording of the existing rule that places the emphasis for safety on the proximity of the exit to the attendant over the ability of the attendant to view the cabin area, there should be no degradation in the passenger safety as a result of this requested exemption. 14 CFR 25.813(e) The risk for occupants due to the use of doors between passenger compartments should be considered acceptable for the following reasons:

 All doors between passenger compartments will be frangibl e.

 The pocket doors installed between the aft lounge and the guest seating area will be placarded to be in the stowed position for taxi, takeoff and landing.

 M echanical pocket doors will be placarded to be open for taxi, take
-off and landing , with the following exceptions: if passen ger(s) are not located in the private lounge the door to the passageway will be closed , and the pocket doorsAIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

6 leading into the RH/LH aft lounges from the center passageway will be placarded to be closed during taxi, take
-off an d landing.

 The doors between passenger compartments will have dual means to retain them in the open position for taxi, take
-off and landing , each of which will be capable of withstanding the inertia loads s pecified in 14 CFR 25.561.

 The airplane will be operated under 14 CFR Part 125 and will be not be operated for hire or offered for common carriage.

 The AFMS will provide procedures and limitations to ensure that the doors are in the proper position for taxi, take
-off and landing. 14 CFR 25.785( d ) The risk for occupants due to the non availability of direct hand holds in certain areas of the airplane should be considered acceptable for the following reasons:

 All furniture in the passenger cabin has rounded corners and edges to avoid serio us injury in case of turbulence.

 The installed seat and divans are heavily upholstered and will not cause injuries when contacted.

 In the main majlis and dining lounge , occupants can use seat arms and seat backs to steady themselves in case of turbulence during flig ht . Tables and furniture are readily within reach with one or two steps.

 There will be a recommendation to passengers to remain seated with their seat belts fastened in case of turbulence during flight.

 Occupants are intimately familia r with the interior arrangement.

 The airplane will be operated under 14 CFR Part 125 and will not be operated for hire or offered for common carriage. 14 CFR 25.853( a ) (1) The vast majority of the rule was driven by the post
- crash fire experiences in airlineAIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

7 operations. Th e 65/65 heat release regulation was specifically developed to reduce the likelihood of the flash
-over phenomenon which was proven by tests to be a prime contributor to the rapid propagation of post
- crash cabin interior fires and the generation of blinding smoke. Rapid fire propagation combined with the relatively slow rate of passenger evacuation from densely packed air carrier airplanes has proven to be a deadly combination during actual airline accidents. Since it is clear that material selection is being controlled by aesthetics i n this application, we cannot exercise any real control over the actual heat release but the exposure time to this heat release is still within the designer’s control. Therefore , it is proposed as a first step in mitigating the fire hazard that an evacuation analysis be performed to show that all souls on board can be safely evacuated in less than 45 seconds. This would be possible because of excess emergency exits for the airplane passenger capacity, smooth evacuation routes , and the small number of seats in the cabin . In addition, GDC will install fire detectors in th e master bedroom, private lounge, and mid cabin lounge that would compensate for the potential for an increased in
-flight fire threat.
PUBLIC INTEREST : As in the cases of numerous already established Exemptions, granting this petition for exemption would be clearly in the public interest for the following reasons:

 I t allows efficient and safe carriage of Head of State and executives in the sought for environment t hat would otherwise not be possible ,

 There is no degra dation of safety involved with this request and therefore no detrimental impact to the public at large,

 Increased sales of these executive configured transport airplanes will ultimately result in some portion of those airplanes being completed at US owned or operated aircraft completion facilities, providing improved financial performance and work force stability for those organizations as well,

 Improved financial performance of US owned or operated corporations, and increased work force stability translates into continued and improved tax revenue for all governmental organization involved,

 Improved financial performance allows US corporations to continue to invest in new R & D research which will all ow the US to maintain or improve it’s competitive position in the world economy,AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com**

8  A large number of these types of sales can be predicted to be to “offshore” clients, improving the US balance of trade deficit.

PUBLIC COMMENT: In accordance with 14 CFR 11. 87, Gore Design Completions, ltd., requests that the period for public comment be waived because of numerous similar exemptions that have previously been granted. Sincerely,

Steve Kincaid ODA Administrator Gore Design Completion, ltd. Phone 210
-496
- 5614 Ext 527 3 Email steven.kincaid@goredesign.com
cc: Julie Moon, ASW
- 190, Special Certification Office Enclosure: Floor PlanAIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com** 9AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com** 10AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS 607 N .Frank Luke Drive - San Antonio TX 782 2 6 - USA - 210.496.5614 - FAX 210. 923 - 3328 **www.goredesign.com** 11