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June 8, 2011

U.S. Department of Transportation

Docket Management Facility

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12-140

Washington, DC 20590

SUBJECT: Petition for Exemption from 14 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 A340-211 airplane.

Ref: GDC ODA STC Project no. GDC-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. 

The airplane will be configured for a much lower passenger 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 applicable. 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 prepared a petition for 

exemption to the following regulations:

14 CFR 25.785(h)(1), Amendment 25-64 - Flight attendant seats must be located 

to provide direct view of the cabin area.
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14 CFR 25.813(e), Amendment 25-46 - No door may be installed in any partition 

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 transport 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.

While the greatest majority of these regulations represent a common sense inclusion for 

any aircraft regardless of it’s intended use, a few are obviously intended to regulate 

situations that are specific to an airline, or for hire operation. When 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 the type of operation and the intended 

use of this 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-hire” 

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 foreign national operational standard. In accordance with 14 CFR Part 

11.81(h), we request to exercise the privilege of this exemption outside the United 

States since the operator of the airplane is located in Saudi Arabia.
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The interior configuration being installed in this airplane 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 style seat in the 

communication center (located at the center of the aircraft aft of the center seats in the 

guest seating area), but 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 1L 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 375 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 buying 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 during 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 “location of the flight attendant seats near the floor level exits in this case 

is more important than 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 14 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.
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There will be a swing door between the master bedroom and private lounge, and a 

swing door installed on the 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.

Doors 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 position, 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 passenger(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 aisles 

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 provide 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 identifiable “aisle” in the main 

majlis and dining lounge. Any construction hanging from the 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)

With the sudden growth in the VIP or executive transport airplane market together with
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the simultaneous 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, some 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 private 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 traditional 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 

the 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 frangible.

 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.

 Mechanical pocket doors will be placarded to be open for taxi, take-off and 

landing, with the following exceptions: if passenger(s) are not located in the 

private lounge the door to the passageway will be closed, and the pocket doors 
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leading into the RH/LH aft lounges from the center passageway will be placarded 

to be closed during taxi, take-off and 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 specified 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 

serious 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 flight. 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 familiar 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 airline
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operations. The 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 in 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 the 

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:

 It allows efficient and safe carriage of Head of State and executives in the sought 

for environment that would otherwise not be possible,

 There is no degradation 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 allow the US to maintain or improve it’s 

competitive position in the world economy,
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 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 5273

Email steven.kincaid@goredesign.com

cc: Julie Moon, ASW-190, Special Certification Office

Enclosure: Floor Plan
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AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS

607 N .Frank Luke Drive -San Antonio TX 782 26-USA-210.496.5614 -FAX 210. 923-3328

www.goredesign.com

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AIRCRAFT INTERIOR DESIGN, ENGINEERING & COMPLETIONS

607 N .Frank Luke Drive -San Antonio TX 782 26-USA-210.496.5614 -FAX 210. 923-3328

www.goredesign.com

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