December 17, 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue 

SE West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Associated 

AirCenter 

A OC:e Company 

AAC-CERT-14-126 

Page 1 of 8 

Subject: Petition for Exemption - Relief from Title 14 CFR Parts §25. 785(h)(2) 

Flight Attendant direct view, §25.7850) firm handholds along each aisle, 

§25.813(e) interior doors between passenger compartments, §25.815 

Minimum Aisle Width, and §25.853(d) maximum heat release rates for 

large panel interior materials. 

Reference: (1) Boeing Company, Model 787-8, S/N 40695 

(2) B787-8 Floorplan drawing 

Dear Office of the Chief Counsel: 

Enclosed please find Associated Air Center's (AAC) Petition for Exemption. This 

exemption is for the Boeing 787-8, serial number 40695. Most of the text used in this 

request has been taken from (1) Grant of Exemption obtained by AAC in Exemption No. 

8460 for Boeing Model 747-400, (2) Partial Grant of Exemption obtained by AAC in 

Exemption No. 10809 for Boeing Model 747-8, (3) Partial Grant of Exemption obtained 

by L-3 Communications in Exemption No. 10686 for Boeing Model 747-8, (4) Grant of 

Exemption obtained by The Boeing Company in Exemption No. 10879 for Boeing Model 

787-8 and -9 airplanes, (5) Grant of Exemption obtained by The Boeing Company in 

Exemption No. 10868 for Boeing Model 787-9. 

Associated Air Center requests the requirement for Federal Register publication be 

waived since good cause has been demonstrated by the previous grants for exemption. 

These prior Exemptions, on the same regulations, have allowed interested persons to -· .~r...~:'- ~h-:~ __ _...._.... __ ... _ ;:)UUIIIIL lllvll LoUIIIIIIIJIIl;:). 

8321 Lemmon Ave 

Dallas, TX 75209 

214 350 4111 

214 351 2375 
AAC-CERT-14-126 

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Associated Air Center requests that the same relief with the same provisions be 

extended to include this 8787-8, S/N 40695, subject of our request for Exemption (refer 

to attached reference (2) floorplan). 

We respectfully await the Federal Aviation Administration's approval. 

In case additional information is required to process this application for Exemption, 

please do not hesitate to contact me at (972) 559-7062, or by email at jose.moravargas@associated .aero. 

Sincerely, 

Jose Mora-Vargas 

Certification Director 

Associated Air Center 
EXEMPTION REQUEST 

8787-8 5/N 40695 

Applicable Regulations 

AAC-CERT-14-126 

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14 CFR Part §25.785(h)(2) Amendment 25-88. Flight Attendant direct view. 

14 CFR Part §25.785(j) Amendment 25-88. Firm handholds along each aisle. 

14 CFR Part §25.813(e) Amendment 25-128. Interior doors between passenger 

compartments and emergency exits. 

14 CFR Part §25.815 Amendment 25-38. Requires minimum aisle width in the 

passenger compartment. 

14 CFR Part §25.853(d) Amendment 25-116. Maximum heat release rates for large 

panel interior materials and large non-metallic seat panels. 

Background 

Associated Air Center requests that the relief provided for the airplanes covered by 

previously granted Exemptions, relative to the subject requirements be expanded to 

include the Boeing 787-8, S/N 40695: 

1. Exemption No. 8460, Docket No. FAA-2004-18913, Grant of Exemption 

from §§25.785(d) and §§25.813(e) for Boeing Model 747-400 airplane. 

2. Exemption No. 10809, Docket No. FAA-2013-0277, Partial Grant of 

Exemption from §§25.785(h)(2), §§25.785(j), §§25.813(e), §§25.815, and 

§§25.853(d) for Boeing Model 747-8 airplane. 

3. Exemption No. 10686, Docket No. FAA-2012-0707, Partial Grant of 

Exemption from §§25. 785(h)(2), §§25. 785(j), §§25. 791 (a), §§25. 795, 

§§25.813(e), §§25.815, and §§25.853(d) for Boeing Model 747-8 airplane. 

4. Exemption No. 10879, Docket No. FAA-2013-0015, Grant of Exemption 

from §§25.813(e) for Boeing Model787-8 and -9 airplane. 

5. Exemption No. 10868, Docket No. FAA-2013-0101, Grant of Exemption 

from §§25.853(d) for Boeing Model 787-9 airplane. 

Discussion 

The Federal Aviation Regulations (FARs) do not consider the situation of private use not 

for hire transport category airplanes, in the 14CFR Part 25 requirements. Those 

requirements are predicated on airline common carrier, commercial passenger 

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Center believes that the design of an airplane for private use, and the associated 

operation of the airplane in private use, should justify an exemption, based on the fact 
AAC-CERT-14-126 

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that 14CFR Part 25 regulations do not currently cover or consider such a design and 

operation. 

The FAA position of previous Exemptions listed above for the Boeing Models 747-4, 

747-8, 787-8, and 787-9 not requiring flight attendant direct view, firm handhold along 

each aisle, interior doors permitted with provisions, reduced aisle width during non 

critical flight phases, and reduced interior flammability requirements should also be 

granted to the Boeing Model 787-8 Serial Number 40695. These airplanes have the 

same or approximately the same cross section (wide body). These type airplanes can 

be considered the larger private use airplanes. Customers have purchased these large 

airplanes for the spacious and impressive atmosphere they desire. 

14 CFR 25.785 (h) (2): Flight attendant direct view. 

The requirement for flight attendant seats to be located to provide a direct view of the 

passenger cabin is not practical for compliance with executive type interior to be 

installed on the Boeing 787-8 airplane. The complexity of the interior arrangement, 

coupled with the need to retain proximity to emergency exits is impractical to 

demonstrate compliance. Reference Exemption No. 10809 & 10686 for compliance 

method to the requirements identified in these Exemptions. 

14 CFR 25.785 (j): Firm handholds along each aisle 

The requirement for a firm handhold along aisles cannot be met for certain areas in the 

passenger cabin due to wide open spaces between individual seat backs which typically 

provide an adequate handhold. This is prevalent in conference/dinning rooms, lounges, 

offices, bedrooms and lavatories. With the cabin spaciousness, there is a readily 

identifiable "aisle" throughout. Any feature hanging down from the ceiling would 

diminish the appearance of the high quality interior and is not acceptable to the 

customer. Reference Exemption No. 8460, 10809, & 10686 for compliance method to 

the requirements identified in these Exemptions. 

14 CFR 25.813 (e): Prohibits installation of interior doors between passenger 

compartments and emergency exits. 

Private areas or conference/meeting/dinning rooms will often need to span the whole 

cabin or a portion of the cabin in order to be practical. For such arrangements, privacy 

can only be provided by means of doors, and therefore, an exemption is needed to 

allow full use of airplane capabilities without compromising safety for those onboard. 

Interior doors between passenger compartments and between the exits will be 

compliant with the requirements previously identified in Exemptions No. 8460, 10809, 

10686 and 10879. 

14 CFR 25.815: Prohibits aisle width reduction during all phases of flight. 

Unlike typical commercial aircraft, private use airplanes (i.e. not for hire or common 

carriage) have seals that can be moved or rotated during flight operations. The seating 

can be reconfigured to accommodate meetings and other arrangements. Some of these 

arrangements can reduce the aisle widths below those specified in 14 CFR 25.815. 

Advisory Circular (AC) 25-17 A contains a "private use" provision which provided aisle 
AAC-CERT-14-126 

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width reduction acceptability only during en-route flight and only if clear instructions are 

provided requiring that the seats be positioned for taxi, takeoff and landing in an 

arrangement that meets the required aisle width. AAC proposes to be compliant with the 

criteria established in AC 25-17A for private use aircraft. Reference Exemption No. 

1 0809 & 10686 for compliance method to the requirements identified in these 

Exemptions. 

14 CFR 25.853 (d): Limits maximum heat release rates for large panel cabin 

interior materials and large non-metallic seat panels. 

Executive interiors often have specific needs for the use of exotic or extremely 

comfortable materials to be used in the cabin. These materials can not satisfy the 

flammability requirements of CFR 25.853 (d) requiring that cabin materials meet specific 

flammability standards for passenger capacities of 20 or more. AAC proposes to meet 

the requirements of previously granted Exemptions that stated: "When materials are 

installed that do not comply with the requirements of appendix F, parts IV and V, it must 

be shown that the passengers and crewmembers can be evacuated in 45 seconds of 

less, under the conditions described in part 25, appendix J. This also includes the 

requirements of special conditions 25-370-SC, which addresses seats with nontraditional, large, non-metallic panels on the airplane. Reference Exemption No. 10809, 

1 0686, & 10868 for compliance criteria to the requirements identified in these 

Exemptions. 

Basis for Exemption 

As stated in Exemptions No. 8460, 10809, 10686, 10879 and 10868, the FAA is aware 

that the precedent has been established for other private use wide body airplanes to be 

exempted from the subject requirements. 

Exemption Will Be In The American Public Interest 

Approval of this request for certain exemptions for the Boeing Model 787-8 when 

configured for executive application, and operated under FAR Part 91 or Part 125, is in 

the public interest of the people of the United States of America. 

1. Given the proliferation of Executive Configured Transport Category Airplanes 

currently taking place, and anticipated in the near future, approval of these 

exemptions will enable the United States manufacturers of Transport Category 

Airplanes to effectively compete in this expanding market. 

2. Additional sales of United States manufactured airplanes outside of the traditional 

airline market, and completion of many of them at United States owned and 

operated Aircraft Completion Facilities, will serve to increase the profitability of these 

manufacturers and their supplying/supporting companies. 

3. Stability and improved financial performance of these United States companies 

gives greater job stability to the workers employed by the companies, causing a 

stabilizing influence to the United States economy, due to the consumer spending 

activities associated with stable workers. 
AAC-CERT-14-126 

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4. Improved financial performance of United States owned and operated corporations 

and increased work force stability translates to continued and improved local, state 

and federal tax revenues which in turn adds to the stability of the total United States 

economy. 

5. Improved financial performance allows United States corporations to continue to 

invest in Research and Development allowing the United States to maintain or 

improve its competitive position in the world economy. 

6. A large number of these types of airplanes will probably be sold to "offshore" clients, 

improving the United States balance of trade. 

7. Since the passengers aboard these airplanes will not be revenue paying customers 

of the airlines, there can be no degradation to airline passenger safety, and therefore 

no detrimental impact on the public at large. 

Conclusion 

As reference to the previously noted partial/granted Exemptions, the FAA's conclusion 

on each of those Exemptions is pasted below: 

1. Exemption No. 8460 stated that "the FAA found that a grant of exemption was in 

the public interest and would not adversely affect safety. Therefore, pursuant to 

the authority contained in § 49 U.S.C. §§ 40113 and 44701 the Administrator 

granted Associated Air Center an exemption from the requirements of Title 14 

CFR Part 25.785 (d) and 25.813(e) for a Boeing Model 747-400. 

2. Exemption No. 10809 stated that "the FAA found that a partial grant of 

exemption was in the public interest. Therefore, pursuant to the authority 

contained in 49 U.S.C. 40113 and 44701, the administrator granted Associated 

Air Center an exemption from the requirements of Title 14 CFR Part 

25.785(h)(2), 25.785(j), 25.813(e), 25.815, and 25.853(d) and special conditions 

25-368-SC with provisions for a Boeing Model 747-8. 

3. Exemption No. 10686 stated that "the FAA found that a partial grant of 

exemption was in the public interest. Therefore, pursuant to the authority 

contained in 49 U.S.C. 40113 and 44701 the Administrator granted L-3 

Communications Integrated Systems, L.P., an exemption from the 

requirements of Title 14 CFR Parts 25. 785(h)(2), 25. 785(j), 25.791 (a), 25.795, 

25.813(e), 25.815, and 25.853(d), and Special Condition 25-368-SC, with 

provisions for a Boeing Model 747-8. 

4. Exemption No. 10868 stated that, "the FAA found that a grant of exemption was 

in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 

§§ 40113 and 44701 the Administrator granted The Boeing Company, an 

Exemption from the requirements of Title 14 CFR Part 25.853(d) and Condition 1 

of Special Condition No. 25-370-SC for Boeing 787-9. 
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5. Exemption No. 10879 stated that "the FAA found that a grant of exemption was 

in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 

40113 and 44701 the Administrator granted The Boeing Company, an 

exemption from the requirements of Title 14 CFR Part 25.813(e) at amendment 

25-116 with provisions for Boeing 787-8 and -9 airplanes. 

Associated Air Center seeks similar relief with the same provisions for the Boeing Model 

787-8, S/N 40695 airplane. Granted Exemptions as described in Exemptions listed 

above, were subject to the following provisions: 

>- The airplane must not be operated for hire or offered for common carriage. This 

provision does not preclude the operator from receiving remuneration to the 

extent consistent with 14 CR parts 125 and 91, subpart F, as applicable. 

>- A majority of flight-attendant seats must be oriented to face the passenger cabin. 

>- Each door between passenger compartments must be frangible (only manually 

operated pocket doors are installed - no electrical doors). 

Doors that fall into Category 1 must be in the open position during taxi, takeoff, 

and landing when the room is occupied. 

Doors that fall into Categories 2, 3, or 4 must be in the open position during taxi, 

takeoff and landing, regardless of occupancy of the room. 

Doors that fall into Category 5 must be in the closed position during taxi, takeoff, 

and landing. 

Appropriate procedures must be established to both signal the flight crew in the 

event a door between passenger compartments is not in the proper position, and 

prohibit TT&L. Doors in Category 5 do not need to comply with this requirement. 

For Category 5 doors, installing placards located on or near the door, and 

indicating that the door must be closed for TT&L is acceptable. 

Doors between passenger compartments must have dual means to retain them 

in the open position. Each means must be capable of withstanding the inertia 

loads specified in § 25.561. Doors in Category 5 do not need to comply with this 

requirement because they are required to be closed for TT&L. 

When materials are installed that do not comply with the requirements of 14CFR 

Part 25-Appendix F, parts IV and V, it must be shown that the passengers and 

crewmembers can be evacuated in 45 seconds or less, under the conditions 

described in part 25, appendix J. This also includes the requirements of special 

conditions 25-370-SC, which addresses seats with non-traditional, large, nonmetallic panels on the airplane. 

>- A means to signal the flight crew must be in place in the event of a fire in an 

isolated passenger compartment, and the detection system must meet the 

requirements of§ 25.858(a) through (d). 

>- Compliance is required with § 25.815, except that aisle width may be reduced to 

Oinches between any cabin furnishing (e.g seat, table, or divider) during in-flight 

operations only, provided that all areas of the cabin remain easily accessible in 
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the event of an emergency (e.g., in-flight fire or decompression) with interior 

furnishings in the most adverse positions. Accessibility must be demonstrated to 

the FAA by test or analysis supported by test data, or, in circumstances agreed 

to by the FAA, by inspection. 

Aisle width requirements of § 25.815 must be maintained during Taxi, Takeoff 

and Landing. 

Any cabin furnishing (e.g seat, table, or divider) that can be positioned to intrude 

into the aisle must be clearly placarded to be in the proper location (i.e not 

intruding into the minimum required aisle) during Taxi, Takeoff and Landing. 
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