## Petition for Exemption from 14 CFR25.813(e).

Petitioner: 

### L-3 Communications Integrated Systems, L.P. 7601 MaehrRoad P.O. Box 154580 Waco, Texas 76715-4580 Attn: Loyd R. Hamilton ODA Administrator (254) 867-4277 Loyd.R.Hamilton@L-3com.com

L-3 Communications Integrated Systems, L.P., submits to the Federal Aviation Administration (FAA) this amended petition for exemption from the following section ofTitle 14, Code ofFederalRegulations (14 CFR) 25.813(e). The proposed exemption, ifgranted, would permit relieffrom the requirements ofinterior doors between passenger compartments. The proposed exemption is-specifically intended for application to executive interiors on Boeing Model 747-8 airplanes designated as "private use, not for hire, notfor common carriage." 

### Thepetitionerrequestsrelief(rom thefollowing regulations:

Section 25.813(e),Amendment 25-46 

### "No doormaybe installed in anypartitionbetweenpassenger compartments." and FAA Exemption 10686, Exemption for General Interior Requirements for 747-8 Aircraft used in private, notfor-hire use, specifically the Exemption related to 25.813(e) Doors between Passenger Compartments.

Discussion 

### L-3 Communications Integrated Systems has been contracted by customers for interior completions of VVIP/Government/Head-of-State business interiors in more than one Boeing Model 747-8 airplane. The FAA has accepted L-3's STC application on one program and has authorized L-3 ODA-750154-SW to conduct the program under Project Number P-12-001. The certification basis for the Boeing 747-8 is 14 CFR 25, Amendment 25-1 through 25-120 with reversions, later amendments, Exemptions, and Special Conditions as shown in FAA Type CertificateData Sheet A20WE. 14 CFR 25 governs Type Design certification requirements for transport category airplanes. The primary intent of the CFR, as applied to Transport Aircraft, is intended for US commercial or common-carriage applications. These regulations are to ensure that aircraft manufacturers provide the appropriate design features to meet the standards necessary to protect the traveling US public. These requirements define the normal public interest and safety level and provide regulatory guidelines to meet them. When the individual aircraft is to be used in private service (e.g., not for US hire or common carriage), it is appropriate to take into consideration the specific needs of a different population ofmore experiencedusers and the operations specific to those users. Historically, the FAA has made adjustments to specific requirements based upon specific design and operational factors. As stated above, numerous exemptions and other regulatory changes have been granted to meet specific aircraft designs and applications. In like manner, L-3 proposes to use mitigating design requirements and operational limitations to justify similar exemptions to 747-8 aircraft modified for VVIP/Government/Head-of-State, not-forhire-or-common-carriage service. 1

### L-3 Communications Integrated Systems successfully petitioned for an Exemption from a number of 14 CFR25 requirements. FAA Exemption 10686 was issued and among other items allows the use ofdoors thattranslate atright angles to thelongitudinal aisle ofthe aircraft. L-3'slatest customer's design contains a rotunda-type entryway that has multiple aisles to other parts ofthe aircraft. Those aisles are not necessarily longitudinal aisles but are aisles to other compartments. Relief is needed to allow the use of straight or curvedpocket-type doors thattranslate across the direction oftravel.

Basis for Exemption The aircraft that are the subjects of this petition are Boeing Model 747-8s modified for non-commerciaVnoncommon-carriage VVIP/Government use/Head-of-State service. They are typically in the service offoreign Headsof-State friendly to US interests and will be operated under 14 CFR91/14 CFR 125 regulations orequivalent foreign standard. For this reasonthe privileges ofthis proposed exemption will be exercised outside the United States. The interior configurations typically installed result in a very small passenger population vis-a-vis for-hire or common-carriage standards. These passengers are typically very experienced travelers. For this reason the crews and passengers who fly on this aircraft have a substantially higher familiarity with the aircraft and its systems than those envisionedbythe writers ofthe original CFR. The exemptionproposed herein arejustifiedbased upon the following facts:

• This aircraft is intended for VVIP/Government/Head-of-State use and is not appropriately configured for or intended for use for hire or common carriage. • Depending on the interior layout, these aircraft typically carry a low fraction of the originally TypeApproved passenger load. • The Petitioner proposes mitigating requirements and conditions that establish acceptable safety levels for the occupants consistent withprevious grants. With these justifications in mind, L-3 Communications Integrated Systems requests relief from and proposes a petition for exemption from the listedregulations.



### 14 CFR25.813(e): DoorsBetween Passenger Compartments 

### Discussion This discussion covers curved pocketing doors that separate passenger compartments throughout the aircraft and do not operate transversely to the longitudinal axis ofthe airplane. This discussion does not include doors or folding partitions that separate non-passenger compartments and, therefore, these doors do not apply to this amended exemption request. Curved pocketing doors between passenger compartments will have the following design features: independent means to couple (mechanically fasten) the wall panels to the door to account for crash loads specified in 14 CFR 25.561 orgust loads, whichever is more critical, using static pull test as the means ofcompliance and account for deformation oflocal structure to secure them in the open position; cockpit annunciation ofthe positive engagement ofthe means for taxi, take-off and landing; the means must have positive retention in the locked position; and the doors will be frangible to allow egress in the eventthat they should become stuck in the closed position. 

### Occupant SafetyConsiderations The risk for occupants due to the use of doors between passenger compartments should be considered acceptable for the following reasons: • Any curvedpocketing door betweenpassenger compartments will have an independent means to couple (mechanically fasten) the wall panels to the door to account for crash loads specified in 14

2CFR 25.561 or gust loads, whichever is more critical, using static pull test as the means of compliance and account for deformation oflocal structure to secure them in the openposition, • The means to couple (mechanically fasten) the wall panels to the door will have positive retention in the lockedposition, • Doors to compartments that are unoccupied during Taxi!Takeoffi'Landing operations will be closed. Door position will be indicated in the cockpit when the door is in the wrong position for take-off and landing and cockpit annunciation will be given ofthe positive engagement of the curvedpocketdoor coupling means for taxi, take-offand landing •All doors betweenpassenger compartments will be frangible, • The airplane will be operated under 14 CFR 91/14 CFR 125 or foreign equivalent and will not be operated forhire or offered for common carriage, • The AFMS will provide procedures and limitations to ensure that the doors are in the proper position for takeoffand landing. Requested Relief L-3 proposes to meet the following requirements for straight or curved pocket doors which cross the main cabin aisle and that open and close at an angle that is not transverse to the longitudinal axis ofthe aircraft:

o In lieu ofthe requirements ofSec. 25.813(e), curved interiorpocketing doors may be installed betweenpassenger seats and exits, provided the following requirements are met: • Each curvedpocketing doorbetween anypassenger seat and any exit will have an independent means to couple (mechanically fasten) the wall panels to the doorto account for crash loads specified in 14 CFR 25.561 orgust loads, whicheveris more critical, using static pull test as the means ofcompliance and account for deformation oflocal structure to secure them in the openposition. The means to couple (mechanically fasten) the wall panels to the door will have positive retention inthe lockedposition. • The direction ofmotion ofany curved door installed across an aisle must be across the direction ofmotion ofthe occupant, e.g., pocket doors are one example ofsuch a design. • Each doorbetween any passenger seat, occupiable for taxi, takeoff, and landing, and any emergency exit musthave a means to signal to the flightcrew, at the flightdeck, that the door is in the openposition for taxi, takeoffand landing. Also, cockpit annunciation will be given ofthe positive engagement ofthe curved pocket door coupling means for taxi, take-offand landing. • Appropriate procedures/limitations mustbe established inthe AFM to ensure that any such door is in the open configuration for takeoffand landing. • Each door between anypassenger seat and any exitmustbe frangible in either direction. A frangibility test will be performed on eachtype ofinter-compartment door installation in the aircraftusing a 5thpercentile female subject. • Each doorbetween any passenger seatand any exit mustbe operable from either side, and ifa locking mechanism is installed, it mustbe capable ofbeing unlocked from either side without the use ofspecial tools. o When the aircraft is equipped with interior doors under this Exemption:

Public Interest • The airplane flight manual (AFM) must include an appropriate limitation that the airplane must be staffed with at least the number of flight attendants required by 14 CFR 91.533(a) who meet the requirements of 14 CFR 91.533(b). • The AFM must include appropriate limitation(s) to require a preflight passenger briefing describing the appropriate functions to be performed by the passengers and the relevant features ofthe airplane to ensure the safety ofthe passengers and crew.

As in the cases ofnumerous already established Exemptions, granting this petition for exemption would be clearly in the public interest ofthe people ofthe United States ofAmerica for the following reasons:



### 31. Given the proliferation ofVVIP/Governmentuse/Head-of-State Configured TransportCategory Airplanes, and anticipated in the near future, approval ofthese exemptions will enable the United States manufacturers ofTransport CategoryAirplanes to effectively compete in this expanding market. 2. Additional sales ofUnited States VVIP/Govemment use/Head-of-State Configured interiors outside of the traditional airline market will serve to increase manufacturer'sprofitability and that oftheir supplying/supporting companies. 3. Stability and improved fmancial performance ofthese United States companies gives greaterjob stability to the workers employed bythe companies, causing a stabilizing influence to the greaterUnited States economy, due to the consumerpending activities associated with stable workers. 4. Improved financial performance ofUnited States owned and operated corporations, and increased workforce stability translates into continued and improved local, state, and federal tax revenue which in turn adds to the stability ofthe 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 orimprove its competitiveposition in the world economy. 6. A large number ofthese types ofairplanes willprobablybe sold to foreign clients, improving the United States balance oftrade. 7. This grant supports positive relations with the Heads-of-State offoreigncountries operating US-built aircraft. 8. Foreign Heads-of-State operating US-manufactured aircraft strengthens the preeminent globalposition ofthe United States aircraft manufacturing, completion, and regulatory industry. 9. These aircraft will be operated under 14 CFR91 or 14 CFR 125 orits foreign equivalent. These aircraft will notbe operated for hire or offered for common carriage, therefore there is no safetyimpact on the US flying public. 10. The exemptionrequest, ifgranted, allows the FAAto expend resources onthis subject only this one time, not for each interior arrangement, and thereafter to concentrateresources onthe FAA'shighest priorities, including Continuing Operational Safety.

Future Use and Application ofthe Exemption This Exemption is intended for use on current and future 747-8 interior programs by L-3 Communications and its subsidiaries. Use and applicability ofthe Exemption will be controlled in the Project Specific Certificationplanning submitted to the applicable FAA CertificationOffice. Exemptions to specific rules and associated mitigating requirements are to be individually applied. There is no requirement that all portions ofthis Exemption be applied simultaneously. When the approved exemption to a specific rule orrules is notusedthen full compliance to that rule orrules is required. In accordance with 14 CFR 11.81(h), we request to exercise theprivilege ofthis exemption outside the United States since the operator ofthe first airplane is located in a foreign country.

Public Comment In accordance with 14 CFR 11.87, L-3 requests that theperiodfor public commentbe waived.

SUMMARY OFLIMITATIONS AND ADDITIONAL REQUIREMENTS

Limitations applicable to exemptions petitioned for herein. When this Exemption is used for the regulations coveredbythis Exemption the following limitations are required:



### 4• The aircraft may not be offered for common carriage or operated for hire. The Operating Limitations section ofthe AFM mustbe revised to prohibit any operations involving the carriage ofpersons orproperty for compensation or hire. The operators may receive remuneration to the extent consistent with 14 CFR 125 and 14 CFR91 SubpartF. • A placard is required stating that "Operations involving the carriage of persons or property for compensation or hire are prohibited", must be located in the area ofthe Airworthiness Certificate holder at the entrance to the flightdeck. • In order for the airplane to be placed in 14 CFR 135 or 14 CFR 121 operations, the airplane must be broughtback into full compliance with the applicable operational part.

• Compliance 14 CFR 25.813(e) Doors BetweenPassenger Compartments will be as follows: o Inlieu ofthe requirements ofSec. 25.813(e), curved interiorpocketing doors may be installed betweenpassenger seats and exits, provided the following requirements are met: • Each curved pocketing doorbetween anypassenger seat and any exit will have an independent means to couple (mechanically fasten) the wall panels to the door to account for crash loads specified in 14 CFR 25.561 orgust loads, whichever is more critical, using static pull test as the means ofcompliance and account for deformation oflocal structure to secure them in the openposition. The means to couple (mechanically fasten) the wall panels to the door will havepositive retention in the lockedposition. • The direction ofmotion ofany curved door installed across an aisle must be across the direction ofmotion ofthe occupant, e.g., pocket doors are one example ofsuch a design. • Each doorbetween anypassenger seat, occupiable for taxi, takeoff, and landing, and any emergencyexit must have a means to signal to the flightcrew, at the flightdeck, that the door is in the openposition for taxi, takeoffand landing. Also, cockpit annunciation will be given ofthe positive engagement ofthe curvedpocket door coupling means for taxi, take-offand landing. • Appropriate procedures/limitations mustbe established inthe AFM to ensure that any suchdoor is in the open configuration for takeoffand landing. • Each doorbetween anypassenger seat and any exit mustbe frangible in eitherdirection. A frangibility test will be performed oneach type ofinter-compartment door installation in the aircraft using a 5thpercentile female subject. • Each doorbetween anypassenger seat and any exit mustbe operable from either side, and ifa locking mechanism is installed, it mustbe capable ofbeing unlocked from either side without the use ofspecial tools. o When the aircraft is equippedwith interior doors underthis Exemption: • The airplane flight manual (AFM) must include an appropriate limitationthat the airplane must be staffed with at least the number of flight attendants required by 14 CFR 91.533(a) who meetthe requirements of 14 CFR 91.533(b). • The AFM must include appropriate limitation(s) to require a preflight passenger briefing describing the appropriate functions to be performed by the passengers and the relevant features ofthe airplane to ensure the safety ofthe passengers and crew.

Submitted on December 15, 2015 

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Loyd R. Hamilton ODA-750154-SW Administrator



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