www.acs-nai.com 

/ACS-NAI 

Engineering, Certification & Manufacturing 

Date: 23 September 2011 

Document Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

RoomW12-140 

Washington, DC 20590 

ACS-NAI Ltd. 

25 Dunlop Avenue 

Winnipeg, Manitoba 

Canada R2X 2V2 

Teleplione; 1 (204) 783-

5402 

Fax: 1 (204) 783-5436 

http://www.acs-nai.com 

Subject: Petition for FAA Exemption corresponding to TCCA Exemption 

NCR/RCN #147-2008 

Reference: FAA Project Number ST7044NY-T 

Dear Sir or Madam: 

A petition for an exemption to Federal Aviation Regulations (FAR) 25.813(e) to permit the 

installation of doors in partitions between passenger compartments in CL-600-2B19 aircraft 

used for corporate transport is being requested. 

A copy of this petition has already been submitted to the Project Engineer (Mr. Christopher 

Alfano) and will be submitted to Mr. Alan Sinclair of the Transport Airplane Directorate (TAD). 

As requested by the Project Engineer, enclosed is a copy of the petition for your records. 

Should you require any additional information, please do not hesitate to contact me. 

Yours very truly. 

Adam Coolidge, E.I.T. 

Certification Specialist, ACS-NAI 

Tel: 204-783-5402 

Fax: 204-783-5402 

acoolidge@acs-nai.com 

AC/dh 

End. 

cc. Alan Sinclair 

ACS-NAI: : 25 Dunlo p Avenue :: Winnipeg , MB, Canod a R2X 2V2 :: 204-783-540 2 

Corporole Heodquorlers :• 534 9 S. Emmer Drive :: New Berlin, Wl 531 51 USA :: 262 67 9 617 0 :: 888 679 617 0 
www.acs-nai.com 

/ACS-iNAI 

Engineering, Certification & Manufacturing 

Date: 13 September 2011 

Christopher Alfano 

Department of Transportation 

Federal Aviation Administration 

New York Aircraft Certification Office ANE-170 

1600 Stewart Avenue, Suite 410, Westbury NY 11590 

ACS-NAI Ltd. 

25 Dunlop Avenue 

Winnipeg, Manitoba 

Canada R2X 2V2 

Telephone: 1 (204) 783-5402 

Fax: 1 (204)783-5436 

http://www.acs-nai.com 

Subject: Petition for FAA Exemption corresponding to TCCA Exemption 

NCR/RCN #147-2008 

Reference: FAA Project Number ST7044NY-T 

Dear Mr. Alfano, 

Per your email dated August 25, 2011, this letter is our petition for an FAA Exemption 

corresponding to TCCA Exemption NCR/RCN #147-2008 for the installation of a mid-cabin 

door. 

ACS-NAI Ltd. requests an exemption to Federal Aviation Regulations (FAR) 25.813(e) to permit 

the installation of doors in partitions between passenger compartments in CL-600-2B19 aircraft 

used for corporate transport. In support of this request, ACS-NAI Ltd. is attaching a copy of 

TCCA Exemption NCR/RCN #147-2008 granting an exemption from the requirements of 

25.813(e). 

The CL-600-2B19 aircraft is designed to the requirements of FAR part 25, for Transport 

Category Aircraft. These rules are addressed to Transport Category airplanes that are used for 

the carriage of fare paying passengers from the general public and consider aircraft with 

passenger seating configurations of several hundred. The CL-600-2B19 aircraft configured with 

a corporate interior is Type Certified for a maximum of 19 passengers. FAR part 25 does not 

provide segregation for intended use of the aircraft, such as commercial air transport or 

corporate use. 

The mid-cabin door installed for corporate interior configurations provides an increased level of 

comfort and privacy for the "office in the sky" concept. ACS-NAI Ltd. contends that aircraft 

interiors specifically designed for corporate operations should be eligible for an exemption of 

FAR part 25 requirements provided a level of safety is provided and can be demonstrated. 

...2 

ACS-NAI:: 25 Dunlop Avenue :: Winnipeg, MB, Canada R2X 2V2 :: 204-783-5402 

Co-porole Heodquorlers . 534 9 S Emmer Drive :: New Berlin, Wl 531 51 USA :: 262 679 617 0 • 888 679 617 0 
www.acs-nai.com 

/ACS-iNAI 

Engineering, Certification & Manufacturing 

-2-

Design Safety Features: 

1. The cabin of the CL-600-2B19 is approximately 8-feet wide. In order to provide a private 

area for use as an office or bedroom, it is necessary to divide the cabin width laterally. A 

side corridor is not practical for the interior arrangement on CL-600-2B19 aircraft. The 

doors to be installed will be sliding pocket doors with retracting footers. The sliding 

pocket door will be frangible to ensure it can be broken open during an emergency 

landing condition and to have blow-out capabilities to provide adequate decompression 

capabilities. 

2. The proposed doors will have a placard installed on both sides requiring the door to be 

secured within the bulkhead (ie. door open) for taxi, take-off and landing. 

3. The proposed doors will be equipped with dual means to latch the door within the 

bulkhead to minimize the probability of the door deploying into the egress path during an 

emergency landing condition. Either means will be capable of supporting the inertia 

loads specified in FAR 25.561. 

4. A lighted annunciator will be installed in the cockpit instrument panel to alert the flight 

crew when the door is closed (ie. across the egress path) and the airplane flaps are not 

zero degrees or the gear is down and locked. Due to the design philosophy of the 

cockpit and the configuration of the EICAS software for the CL-600-2B19, posting a 

"cabin door" message on the EICAS is not possible. The TCCA Exemption permits this 

signal as the annunciator is "effected in an equivalent manner" to posting on the EICAS. 

5. A description of the doors, passenger briefing requirements, limitations and procedures 

will be contained in the applicable Airplane Flight Manual Supplement and/or Flight Crew 

Operating Manual Supplement. 

Effect of the Exemption: 

The effect of the exemption considering the design safety features will ensure that there is a 

clear path through a cabin partition to an emergency exit. Should the cabin door be fully or 

partially ctosed following an emergency landing, there will still be simple means to get through 

the door to reach an exit. The frangibility feature will be tested using a 5'^ percentile female and 

the resulting opening will be demonstrated to be large enough for a 95*^ percentile male to 

escape. These safety features would provide a level of safety for the passengers in a CL-600-

2819 aircraft equal to that required for airiine aircraft and other corporate aircraft such as the 

BD-700-1A10and BD-700-1A11. 

...3 

ACS-NAI : 

Corporate Headpuorlers 

25 Dunlop Avenue :: Winnipeg, MB, Canada R2X 2V2 :; 204-783-5402 

: 534 9 S. Emmer Drive :: New Berlin, Wl 531 51 USA :• 262 679617 0 : 679 617 0 
www.ac5-nal.com 

ACS-iNAI 

Engineering, Certification & Manufacturing 

-3-

Issue of Public Interest: 

Cabin doors have been installed in corporate aircraft such as the BD-700-1A10 and BD-700-

1A11. Interior cabin doors are commonly installed on corporate aircraft at the request of the 

members of the public that use these aircraft. The installation of these cabin doors have been 

shown to be adequately safe for corporate aircraft operations. 

It is our position that the above stated design safety features, the effect of the exemption and 

the issue of public interest provide an acceptable level of safety for passengers in a CL-600-

2B19 with an interior cabin door installed. Compliance has been established against TCCA 

Exemption NCR/RCN #147-2008 for the installation of an interior cabin door. 

We request to forgo the period for public consultation for the mid-cabin door exemption petition 

due to similarity with other FAA Exemption requirements for the installation of an interior cabin 

door. 

Should you require any additional information, please do not hesitate to contact me. 

Yours very truly. 

Ian Stewart 

ACS-NAI Ltd. DE-5 

Transport Canada DAO 98-C-01 

Tel: 204-783-5402 

Fax: 204-783-5436 

istewart@acs-nai.com 

AC/is 

End. 

ACS-NAI : 

Corporate Headciuorlers 

25 Dunlop Avenue ;: Winnipeg, MB, Canoda R2X 2V2 :: 204-783-5402 

: 534 9 S Emmer Drive :: New Berlm Wl 53 ' 51 USA •• 262 679 617 0 : 679 617 0 
www.acs-nai.com 

ACS-NAI 

Engineering, Certification & Manufacturing 

TCCA Exemption NCR/RCN #147-2008: 

ACS-NAI: : 25 Dunlop Avenue :: Winnipeg , MB, Canad a R2X 2V2 :: 204-783-540 2 

Corporole Heodquorlers .. 534 9 5. Emmer Drive •. New Berlin, Wl 531 51 USA : 262 679 617 0 :: 888 679 617 0 
www.acs-nar.com 

ACS-NAI 

Engineering, Certification & Manufacturing 

1^1 Transport Trar^ports 

CanaiU Canada 

RDIMS* 447633? V2 

MfKRt"!M*l 47.200s 

EXEMPTIOM FROM SECTION 513.07 OF TIIF, CASADIANAllATION 

REGVLATIOSS AND PARAGRAPH 513.07(1 Kb) OF THK AlgWORTHI?>iESS 

MAm-AL 

Pureuant io subsection 5.9<2) of the Aeronautics Act, and atler taking into account that (he 

exemption is in the public .intere&i and is not likely Io affect aviation safety. I hereby exempt 

Aero Coaiulting Services Ltd . (hereinafler "ACS^ ) 25 Dnnlop Avenue, 'WiBBipcg, 

MaDltob«t R2X 2V2 from the requirements set out in para^aph S]3.07(]Xb) of Uie 

Airworthiness Manual made pursuant to section 513.07 of the Canadian Aviation 

RtfculaUon^ <CARs) only with respect to the requirements of paragraph 25-813(e) of the 

l.Mited States of Amenca Federal Aviation Regulations (F.\R) part 25. 

Paragraph 25.S13(e) o f FAR pari 25 requires ttiai no door be installed in any partition 

between passenger compaitmcnts in transport category aeroplanes. 

The deiails of the above provisions arc provided in Appendix A to this exemption. 

PURPOSE 

The purpose of this exemption is to allow aay CL-600-2B19 (Challeager 850) aeroplaac to 

be configared with a door In a pnrtltlon befween pMsenxer compartments, such that the 

emergency exit access requirements of the applicable standards contained in the AVr'M are 

not met, for the purpose of private operator passenger transportation pursuant to CAR 604 or 

"on-demand" air trannpon service pursuant to CAR 704. and to Issue the corrcipaiidtng 

Linuled SupplcnMutaJ Type Certificates (I^TCs ) or SupplenrnUl Type Ccrtifieatn 

(STO ) to ACS, 

APPLICATION 

fhi s exemption applies to ACS only aspartof IbcbasisorccrtifkationforanSTCor LSTC 

applied for by ACS that approves the installation of a door in a partition between passenger 

companments on any CL-600-2B19 aeroplane (Type-Certificate No. A-131) with a 

maximum of 19 passengers for the piupose o f private operator passenger transportation 

pursuant to CAR 604 or on-demand air transport service pursuant to CAR 704. 

CONDITIONS 

The granting o f thi5 exemption is subject to ACS to comply with the following conditions: 

1. When operated under CAR 704. the "on-dcmarMl" client shall not sub-chaner the 

aeroplane to a third party or charge or accept remuneration fiDin any third party for 

air transportation services: 

Canada 

ACS-NAI: : 2 5 Dunlop Avenue :: Winnipeg , MB, Canad a R2X 2V2 :: 204-783-540 2 

Corporole Headqjorters •• 534 9 S. Em:..e>-Di»ve : New Beilin, Wl 531 51 USA • 262 679 617 0 • 88 8 679 617 0 
www.acs-nai.com 

ACS-NAI 

Engineering, Certification & Manufacturing 

NCR-RCN P l47-2f>ri8 

2. Nt> more than oneparlitiun uf thepiisscngcr sealintf area that incorporates a door shall 

be permitted, 

3. The door between passenger compartments shall traiLslate laterally to optm and close: 

4. Tlie door between passenger compartment shall be frangible; 

5. Tlie diTor ht:t\^'een passenger compartments and. if applic^iblc, any other door between 

a passenger compartment and emergency exits shall have dual means to retain ti in 

the open posititrn, each of which is capable of reacting the inertia loads specified in 

section 25.561 of FAR pan 25; 

6. The door betv^een passenger compartments and, if applicable, any other door between 

a passenger comparlmenl and emergtaicy exits shall have a means to signal the flight 

crew in a timely manner when the door(s) is (are) not latched open for tafcc-ofTand 

landing. This feature shall be integrated with the existing Engine Indicating and Crevi' 

Aleftmg System (EICAS) or otheruise effected in an equivalent manner; 

7. Appropriate procedures-^imitations shall be established to ensure that talte-ofT and 

landing is prohibited when any such door is not in the proper take-off and landing 

configuration; 

B. The door betv.een passenger compartments andt if applicable, any other door between 

a passenger compartment and emergency exits shall be operable from either tide and 

if a locking mechanism is installed, it shall be capable of being unlocked from either 

.(iide without the aid of special tools; and 

9. Where the door is to be installed in specified egress paths, a Supplement to the 

Aeroplane Flight Manual (AFM) shall be furnished containing: 

a. instruction on the door operation, including its frangibility feature; 

b. a limitation specifying that the aciDplane is limited to private operator 

passenger tran-sporialion pursuant to CAR 60* or "on-demand" air 

transpon ser\'ice pursuant to CAR 704 and complies with the applicable 

operational regulations^ standards, policies and authorities; and 

c. instruction regarding the briefing ofpassengcrs in accordance with the 

applicable operational requirements in the Business Aviation -

Operstiomil Safety Standards System (BA-OSSS) as published by the 

Canadian Business Aviation Association <CBAA) or CAR 704.34. The 

briefing shall include the information required at item 9a. above. 

2 of 4 

ACS-NAI : 

Corporole Hecidquariers 

25 Dunlop Avenue :: Winnipeg , MB, Canad a R2X 2V2 :: 204-783-540 2 

: 534 9 S. Emmer Drive • New Berlin, Wl 531 51 USA .: 262 679 617 0 : 679 617 0 
www.acs-nai.com 

ACS-NAI 

Engineering, Certification & Manufacturing 

NCR.R.CN8 l'170flOS 

VALIDIT Y 

This exemption is in effect until the earliest o f the following: 

a. the date on which any one of the conditions set out in this exemption is breached; or 

b. the dale on ^hic h this exemption is cancelled in writing by ihe Minister where he is 

o f the opinion thai Ihc exrmpticHi is no longer in the public interest or that it is likely 

to afTect aviation safety. 

Dated at Ottawa, Ontario, Canada this Z i day of Kd N Jtv>A»^2(X)S. oa behalf of (Ne 

Minlsic r of Ti^Mport , iBfrastnictiire n d CommuBhlcs. 

ManinJ . Rley 

Director. National Aircraft Certification 

Ci^il Avialion 

Attachment: Appendix A 

3 of 4 

ACS-NAI: : 25 Dunlop Avenue :: Winnipeg , MB, Canad a R2X 2V2 :: 204-783-540 2 

Corporole HeodquaHers ; 534 9 S Emmer Drive • New Berlin. Wl 531 51 USA • 262 67 9 617 0 • 888 679 617 0 
www.acs-nai.com 

ACS-NAI 

Engineering, Certification & Manufacturing 

APPKNDIX A 

REiWLATORY REQllREMESTS 

CANADIAN A yiA TION REGl'lA TiOSS 

Part V - Airworthiness 

Subpart I? -Approval of Modification and Repair Designs 

Section 51.1.07 - Applicable Standards 

513.07(1) Subject to subsections {l\Xo(\ I), an applicant for a supplemental type certificate, 

a litTiited supplemenul type certificate or a change to these certificates shall show that the 

changed aeronautical product meeL*; 

(a) the standards of ain^'orthmess that are in force on Ihc date of application for the 

proposed change... 

(3) Tke cbaJiged acroaautical product may comply with «a earlier imcDdineBt of a 

standard required under subsection <1) if the Minister determiiws that the proposed change is 

not significant in the context of alt previous relevant design changes and the related 

amendments of the applicable standards recorded in the type certificale data sheets... 

AIRWORTHINESS MANUAL 

Chapter $13 - Approval of ModiHcation and Repair Designs 

ScctioB 513.07 - Applicable Standards 

(1) Fursuanlio section 5l3.()7ofthc CAR.v the standards of airworthiness that apply to a 

chanjjc in type dcsif^ are: 

(b) Ihe equivalent standards from Pari V of theCARs - iftheexistini; certification basis 

consists of standards that are no longer accepted in Canada for a new type - oalen the 

Mtitlster allows continued compliance with the existing certification basis. 

FEDERAL AVIATIONREGCLAnONS 

Part 25 Airuorthincss Standards; Transport Category Airplanes 

Subpart D - Design and Construction - Ilmergcncy Provisions 

Scctfoo 25.813 - Emergency' exit acccis (at Amcadmeat Z5~46> 

§ 25,KI3(c)No doot may be installed in any partition betvvcen passcni^er compatiments. 

4of4 

ACS-NAI:: 25 Dunlop Avenue :: Wmnipeg, MB, Conado R2X 2V2 :: 204-783-5402 

Corporate Heodquatiers •.-. 53'J9 S. Earner Dnve .-. New Berlin, Wl 531 51 USA •• 262 6796170 •.: 888 6796170