UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

Exemption No. 11162 

Bombardier Aerospace Regulatory Docket No. F AA-2014-0932 

for an exemption from§ 25.809(a) of 

Title 14, Code ofFederal Regulations 

GRANT OF EXEMPTION 

By letter dated October 30, 2014, Mr. Tim Bilic, Airworthiness Section Chief-Global 7000/8000, 

Bombardier Aerospace, 400 Cote-Vertu Road West, Dorval, Quebec, Canada, H4S 1 Y9, 

petitioned the Federal Aviation Administration (FAA) for an exemption from the requirements of 

§ 25.809(a) of Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted 

would permit partial relief from the outside-viewing requirements for overwing emergency exits 

on Bombardier Global 7000/8000 Model BD-700-2A 12 and BD-700-2A 13 airplanes. 

The petitioner requests relief from the following regulation(s): 

Section 25.809(a), at Amendment 25-116, requires, in pertinent part, that each 

emergency exit be provided with a means to permit viewing of the likely areas of evacuee 

ground contact prior to opening the exit during all lighting conditions with the landing 

gear extended as well as in all conditions of landing gear collapse. 

The petitioner supports its request with the following information: 

This section quotes the relevant information from the petitioner's request, with minor edits for 

clarity. The complete petition is available at the Department of Transportation's Federal Docket 

Management System, on the Internet at http://regulations.gov, in Docket No. FAA-2014-0932. 

The Extent of Relief We Seek 

Bombardier requests an exemption from compliance with 14 CFR § 25.809(a) with 

respect to the requirement to view the ground contact area under all lighting and landing 

gear conditions for over-wing passenger exits. This request is identical in all material 
respects to previously granted exemptions and does not set a precedent (see FAA 

Exemption No. 10840 for Bombardier CSeries, and FAA Exemption No. 10757 for 

Embraer EMB-550). 

The Reason We Seek Relief 

The Global 7000/8000 emergency exits will be subject to the standards of 14 CFR 

§ 25.809(a) which require a means to view the area of occupant ground contact from each 

emergency exit prior to opening the door. The evacuation means from the Global 

7000/8000 over-wing emergency exit (OWEE) is to slide or jump off the trailing edge of 

the wing and, while the OWEE window allows for outside viewing to assess the 

conditions prior to opening the exit, the likely area of evacuee ground contact is 

obstructed by the wing and is not viewable from the OWEE. 

How Our Request Would Benefit the Public as a Whole 

Granting this petition is in the public interest because it: 

a) A voids expenditure of resources to meet some aspects of the present regulation 

which will be changed in the future due to recognized implementation difficulties. 

b) Allows the Global 7000/8000 airplane models BD-700-2A12 and BD-700-2Al3 

to meet EASA, FAA, and TCCA anticipated future harmonized regulation 

preventing competitive disadvantage due to additional design/manufacturing 

complexity and increased weight. 

c) A voids additional airline operation costs associated with: 

• The maintenance/spare parts for a more complex viewing system, and 

• The fuel consumption/emissions produced by additional weight of such 

system. 

Reasons Why the Exemption Would Not Adversely Affect Safety 

Granting this petition does not affect safety because: 

a) As stated under the section titled Summary and Background of the 14 CFR final 

rule publication, the objective of the changes was not to address a known safety 

issue, but to update the regulation to catch-up with industry state-of-the-art and 

design practices (Code of Federal Regulations Final Rule, Docket No. FAA-2004-

19412, titled "Miscellaneous Cabin Safety Changes," issued on 2004-1 0-15). 

b) The design of the Global 7000/8000 airplane models BD-700-2A 12 and BD-700-

2A 13 is consistent with industry present state-of-the-art and design practice. 

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c) The Global 7000/8000 airplane models BD-700-2A12 and BD-700-2Al3 will 

comply with all other aspects of A WM 525-809(a). 

Exemption Request Summary 

The Bombardier Global 7000 and Global 8000 are ultra-long-range, executive interior 

business jets, with maximum certified passenger capacity of 19. The exit configuration in 

these aircraft consists of a Type 1 main passenger door on the left side of the fuselage and 

a Type 3 emergency exit located over the right wing. Bombardier Inc., has encountered 

difficulties complying with the requirement of 14 CFR § 25.809(a) for the Global 

7000/8000 airplane models BD-700-2A12 and BD-700-2Al3, with respect to the viewing 

of the ground contact area under all lighting and landing gear conditions for the overwing exit. As is the case with similar, low-wing aircraft, the view of the likely area of 

evacuee ground contact is obstructed by the wing when in position to open the exit, and, 

therefore, compliance with the requirement for viewing of the ground contact area under 

all lighting and landing gear conditions is not possible. 

Bombardier requests an exemption from compliance with 14 CFR § 25.809(a) with 

respect to the requirement to view the ground contact area under all lighting and landing 

gear conditions for over-wing passenger exits. This request is identical in all material 

respects to previously granted exemptions and, as concluded by the FAA in reference to 

the exemption granted to the Bombardier CSeries airplane with respect to 

14 CFR 25.809(a), there is no adverse impact on safety if an occupant cannot 

simultaneously see conditions immediately outside the exit door and the ground-contact 

point under all lighting and landing-gear conditions. 

The Global 7000/8000 airplane models BD-700-2Al2 and BD-700-2A13 will 

nonetheless comply with anticipated, harmonized requirements now incorporated in 

EASA CS 25.809(a) at Amendment 25/12. 

Federal Register publication 

The FAA has determined that good cause exists for waiving the requirement for Federal Register 

publication for public comment because the request is identical in all material respects to 

previously granted exemptions; the exemption, if granted, would not set a precedent; and any 

delay in acting on this petition would be detrimental to Bombardier Aerospace. 

The FAA's Analysis 

The FAA has determined that there is not an adverse impact on safety if an occupant cannot 

simultaneously see conditions immediately outside the exit door and the ground-contact point 

under all lighting and landing gear conditions. The impact of the regulation, as codified, went 

beyond what was envisioned in the rulemaking process for the overwing exits on some airplanes. 

On many overwing exits, the location where the evacuee makes first contact on the ground is a 

considerable distance from the point from which they exit the passenger cabin. The distance the 

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evacuee moves either forward or aft on the upper wing surface, and then down to the ground 

either by escape slide, or by jumping off the wing, or sliding down the leading or trailing edge of 

the wing, makes it impossible to see the ground contact point from inside the airplane because of 

the distance or the wing itself blocking the view. Some commenters to the notice of proposed 

rulemaking (Notice No. 96-9) made this point, and the FAA response was: 

With respect to the potential for the exit to be somewhat remote from the point where the 

evacuees would contact the ground, the FAA agrees that this may be the case. The intent 

of the requirement is to enable a person to ascertain whether to open an exit, and whether 

it is safe to evacuate through the exit, based on an assessment of the outside conditions. 

To the extent that the means used for determination of the former does not also allow an 

assessment of the ground, the FAA agrees that an additional viewing means may be 

necessary, and that the additional means may be somewhat remote from the exit. We 

have therefore reworded the amendment to allow for the dual purpose of the viewing 

means, and to distinguish the required locations ofthe two. 

Our intent in this rule was that it is not necessary for a person to be able to view the ground 

contact point while in position to open an overwing exit. The rule itself refers to the groundcontact view separately from the view of conditions outside the exit, but the intent of the rule was 

not clearly expressed in the rule language. The FAA worked with the European Aviation Safety 

Agency (EASA) to improve the rule language based on our experience applying this rule. EASA 

incorporated the improved language in their certification specifications (CS) at amendment 

25/12, dated July 13, 2012. CS 25.809(a)(3) states: 

For non-over-wing passenger emergency exits, a means must also be provided to permit 

viewing of the likely areas of evacuee ground contact when the exit is closed with the 

landing gears extended or in any condition of collapse. Furthermore, the likely areas of 

evacuee ground contact must be viewable with the exit closed during all ambient lighting 

conditions when all landing gears are extended. 

The FAA is considering rulemaking to harmonize this requirement with EASA. 

The proposed configuration provides a level of safety consistent with the intent of the rule. The 

window does allow for outside viewing to assess the outside conditions prior to opening the exit. 

The evacuee can then open the exit and step out onto the wing and move along the wing to assess 

the conditions where they would make first contact with the ground. At that point, if the 

conditions were not acceptable, evacuees would search for another location from which to exit 

off of the wing. To enforce literal compliance that is more stringent than our original intent for 

the rule would result in an unnecessary burden on the petitioner. 

The FAA's decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. §§ 40113 and 44701 delegated to me 

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by the Administrator, I grant Bombardier Aerospace an exemption from 14 CFR § 25.809(a) at 

amendment 25-116. The exemption is granted to the extent necessary to allow Bombardier 

Aerospace to partially comply with the outside-viewing requirements for the overwing exits. 

Specifically, the exemption provides relief from the requirement that overwing exits permit 

viewing of the likely areas of evacuee ground contact when the exits are closed. This exemption 

allows viewing the first point of contact with the ground after the exit has been opened and the 

evacuee is on the upper surface of the wing, under all lighting and landing-gear conditions, on the 

Bombardier Global 7000/8000 Model BD-700-2A12 and BD-700-2A13 airplanes. Bombardier 

Aerospace must demonstrate compliance with all other requirements of 14 CFR 25.809(a) at 

amendment 25-116 for these airplanes. 

Issued in Renton, Washington, on JAN ·3 0 2015 

-fl-rc!'.~ · 

Jeffrey E. Duven 

Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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