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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 20590

SUBJECT: Petition for Exemption from 14 CFR §25.562(a) and 25.785(b) 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 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 Amendments 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 passengers 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 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.
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While the greatest majority of these regulations represent a common sense inclusion for

any aircraft regardless of the 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 inappropriate, or 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.

The interior configuration being installed in this airplane 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 capacity 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 taxi, 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.

Regulations 14 CFR 25.562(a) and 25.785(b)

Side-facing seats are considered a novel design for transport 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-place
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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 Criterion (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 Dummy (SID), as defined by 49 CFR part

572, subpart 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, subpart 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 testing, 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

conservative 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 absorbing
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protective padding (foam 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 with 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 homogeneous 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. Deviating from the no-yaw

condition must not result in the critical area of contact not being
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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 that 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 accordance 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

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 its

competitive position in the world economy,  A large number of these types of sales can be predicted to be to “offshore”

clients, improving the US balance of trade deficit.
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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 5222

Cell 210-616-1825

Email mark.creager@goredesign.com

cc: Bill Vickers, ASW-190, Special Certification Office