A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e - S a n A n t o n i o T X 7 8 2 2 6 - U S A - 2 1 0 . 4 9 6 . 5 6 1 4 - F A X 2 1 0 . 9 2 3 - 3 3 2 8 www.go redesign.c om 1 May 13, 2013 U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Floor Room W12 - 140 Washington, DC 2059 0 SUBJECT: Petition for Exemption from 14 CFR §25.56 2(a) and 25.785(b) on an Airbus Model A34 0 -211 airplane. Ref: GDC ODA STC Project no. GDC - P 515 - STC BACKGROUND: Gore Design Completion, ltd. (GDC) has been contracted for the completion of an executive business interior for an Airbus Model A340 -211 airp lane. The FAA Organization Management Team (OMT) has accepted our STC application and assigned as 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 Am endments 25 -65, 25 -66, and 25 - 77. There are good technical arguments to support special consideration for private use airplanes: the aircraft are not for public hire and they are configured to carry a fraction of the passenge rs carried in airline service. For these reasons, Gore Design Completion, ltd. has prepared a petition for exemption from 14 CFR §25.562(a) and 25.785(b) according to Policy Statement PS -ANM -25 - 03 - R1 , Technical Criteria for Approving Side - Facing Seats. 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 air plane manufacturers provide the appropriate design features to meet the standards necessary to protect the traveling p ublic. 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.A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e - S a n A n t o n i o T X 7 8 2 2 6 - U S A - 2 1 0 . 4 9 6 . 5 6 1 4 - F A X 2 1 0 . 9 2 3 - 3 3 2 8 www.go redesign.c om 2 While the greate st majority of these regulations represent a common sense inclusion for any aircraft regard less of the intended use, a few are obviously intended to regulate situations that are speci fic 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 inappropriate, or 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 is suance 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. The interior configuration being installed in this airplan e will provide seating for seventy seven (77 ) passengers and ten (10) cabin crew. The maximum certified passenger count for this airplane is 375 seats. The passenger count of the subject airplane represents 24% of the capac ity allowed for this airplane. STC application for this modification was made March 4, 2010 and project GDC - P515 - STC was assigned . At that time an issue paper was started to address special conditions on single place seats that are side -facing in the t axi, takeoff, and landing configuration per FAA Policy Memorandum ANM - 03 - 115 - 30 that was current at the time . The applicant position was at stage 3 on January 17, 2012, but no conclusion was ever reached by the project ACO. Regulation s 14 CFR 25.562(a) and 25.785(b) Side -facing seats are considered a novel design for tr ansport category airplanes that include Amendment 25 - 64 in their certification bases, and were not considered when those airworthiness standards were promulgated. Hence, the existing regulations do not provide adequate or appropriate safety standards for occupants of multiple - placeA I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e - S a n A n t o n i o T X 7 8 2 2 6 - U S A - 2 1 0 . 4 9 6 . 5 6 1 4 - F A X 2 1 0 . 9 2 3 - 3 3 2 8 www.go redesign.c om 3 side -facing seats because they do not consider the differences in the dynamic forces that would apply to a side -facing occupant. GDC will demonstrate compliance with the proposed injury criteria which are stated in the FAA policy memo ANM - 03 - 115 - 30 dated May 6, 2005. OCCUPANT SAFETY CONSIDERATIONS : 14 CFR 25.562(a) and 25.785(a)

 Existing Criteria : All injury- protection criteria of § 25.562(c)(2 ) through (c)(6) apply to the occupants of side -facing seats . The Head Injury Crit erion (HIC) assessments are required only for head contact with the seat and/or adjacent structures.

 Thoracic Trauma : If the torso of an ATD at the forward - most seat place impacts the seat and/or adjacent structure during testing, compliance with Thoracic Trauma Index (TTI) injury criterion must be substantiated by dynamic test or by rational analysis based on previous test(s) of a similar seat installation. TTI data must be acquired with a Side Impact Dum my (SID), as defined by 49 CFR part 572, s ubpart F, or an equivalent ATD or a more appropriate ATD , and must be processed as defined in Federal Motor Vehicle Safety Standard (FMVSS) part 571.214, section S6.13.5. The TTI must be less than 85, as defined in 49 CFR part 572, s ubpart F. Torso contact during rebound is acceptable and need not be measured.

 Pelvis : If the pelvis of an ATD at any seat place impacts seat and/or adjacent structure during te sting, pelvic lateral - acceleration - injury criteria must be substantiated by dynamic test or by rational analysis based on previous test(s) of a similar seat installation. Pelvic lateral acceleration must not exceed 130g. Pelvic acceleration data must be processed as defined in FMVSS part 571.214, section S6.13.5.

 Body-to -Wall/Furnishing Contact : If the seat is installed aft of a structure —such as an interior wall or furnishing that may contact the pelvis, upper arm, chest, or head of an occupant seated next to the structure —the structure , or a con servative representation of the structure and its stiffness , must be included in the tests. It is recommended, but not required, that the contact surface of the actual structure be covered with at least two inches of energy absorbingA I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e - S a n A n t o n i o T X 7 8 2 2 6 - U S A - 2 1 0 . 4 9 6 . 5 6 1 4 - F A X 2 1 0 . 9 2 3 - 3 3 2 8 www.go redesign.c om 4 protective padding (fo am or equivalent) such as Ensolite.

 Shoulder- Strap Loads : Where upper-torso straps (shoulder straps) are used for sofa occupants, the tension loads in individual straps must not exceed 1,750 pounds. If dual straps are used for restraining the upper torso, the total strap tension loads must not exceed 2,000 pounds.

 Occupant Retention : All side -facing seats require end closures or other means to prevent the ATD’s pelvis from translating beyond the end of the seat at any time during testing. Test Parameters: (1 ) All seat positions need to be occupied by ATDs for the longitudinal tests. (2 ) A minimum of one longitudinal test, conducted in accordance wit h the conditions specified in § 25.562(b)(2), is required to assess the injury criteria as follows. Note that if a seat is installed aft of structure ( such as an interior wall or furnishing) that does not have a homogeneou s surface, an additional test or tests may be required to demonstrate that the injury criteria are met for the area which an occupant could contact. For example, different yaw angles could result in different injury considerations and may require separate tests to evaluate.

 For configurations without structure (such as a wall or bulkhead) installed directly forward of the forward - seat place, Hybrid II ATDs or equivalent must be in all seat places.

 For configurations with structure (such as a wall or bulkhead) installed directly forward of the forward - seat place, a Side Impact Dummy or equivalent ATD , or more appropriate ATD , must be in the forward - seat place and a Hybrid II ATD or equivalent must be in all other seat places.

 The test may be conducted with or without a deformed floor.

 The test must be conducted with either no yaw or 10 degrees of yaw for evaluating occupant injury. Deviatin g from the no -yaw condition must not result in the critical area of contact not beingA I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e - S a n A n t o n i o T X 7 8 2 2 6 - U S A - 2 1 0 . 4 9 6 . 5 6 1 4 - F A X 2 1 0 . 9 2 3 - 3 3 2 8 www.go redesign.c om 5 evaluated. Allowing the test to be conducted at 10 degrees of yaw will permit many occupant - injury tests to be considered in conjunction with the structural test . Note th at this condition does not provide relief from the requirement that torso - restraint straps, where installed, must remain on the occupant’s shoulder during the impact condition of § 25.562(b)(2). Vertical test: For the vertical test, conducted in accordanc e with the conditions specified in § 25.562(b)(1), Hybrid II ATDs or equivalent must be used in all seat positions of the side -facing divans . PUBLIC INTEREST : As in the cases of numerous already established Exemptions, granting this petition for exempti on 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 that would otherwise not be possible ,  There is no degra dation of safety involved wit h 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 complet ion 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 improv ed 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 its competitive position in the world economy,

 A l arge number of these types of sales can be predicted to be to “offshore” clients, improving the US balance of trade deficit.A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e - S a n A n t o n i o T X 7 8 2 2 6 - U S A - 2 1 0 . 4 9 6 . 5 6 1 4 - F A X 2 1 0 . 9 2 3 - 3 3 2 8 www.go redesign.c om 6 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,

Mark Creager Certification Manager Gore Design Completion, Ltd. Phone 210 -496 - 5614 Ext 52 22 Cell 210 - 616 - 1825 Email mark.creager@goredesign.com cc: Bill Vickers , ASW - 190, Special Certification Office