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8/09/11

U.S. Department of Transportation

Docket Operations, West Building,

Ground Floor, Room W12-140,

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Petition for Exemption to 25.813(e) of Title 14, Code of Federal Regulations 

 “No door may be installed in any portion between passenger compartments.”

Dear Office of the Chief Counsel,

StandardAero Business Aviation Services, LLC (StandardAero) petitions for an FAA Exemption 

to 25.813(e) of Title 14, Code of Federal Regulations for the Embraer EJR 190-100 IGW (TCDS

A57NM) when it is modified to business, or private types of interior configurations, operated 

under 14 CFR parts 91 or 125.

General Information 

“The Embraer Model 190-100 IGW airplane is designed to the requirements of Part 25, for transport 

category airplanes. Those requirements are addressed basically to Transport Category airplanes 

that are used for the carriage of fare paying passengers from [the] general public and also must 

consider aircraft with passenger seating up to 500. The Part 25 regulations do not make any 

distinction between commercial airplanes used by airlines for fare paying passengers and airplanes 

specifically used for other operations like charter or private, not-for-hire. 

StandardAero believes that airplanes specifically designed for private use should be eligible for the 

acceptance by exemption of cabin features and facilities which do not comply with certain portions of 

Part 25. In this case a similar level of safety is provided and can be demonstrated. 

StandardAero further states that the following factors are unique to private use airplanes and provide 

compensating features that are not normally provided on a commercial airplane flight: 

• “The passenger configuration in private use airplanes is significantly less than that of a 

traditional commercial airline configuration; 

• “The passengers in private use airplanes are typically frequent fliers and familiar with the 

safety features of the specific airplane they are aboard; 

• “The interior arrangement is static, allowing flight and cabin crews to become very 

familiar with the configuration of the airplane, emergency equipment provided, and the 

location and operation of the emergency exits. They also have regular contact with the 

“repeated” passengers, which has a positive influence on communicating safety issues; 

• “Unlike an air carrier, the operator has control of and can restrict the population and/or 

selection of passengers. 
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Justification 

StandardAero also believes that many customers who purchase and operate Embraer airplanes 

consider privacy to be crucial. Therefore, it is important that portions of the cabin are configured with 

bedrooms and other privacy areas to accommodate very private meetings. The only plausible 

method of providing such privacy is through the use of doors that separate passenger 

compartments. When a privacy area is created within the passenger cabin, the doors separating the 

private area from the rest of the cabin will be located between passenger compartments. 

“The cabin of the Embraer Model ERJ 190-100 IGW is approximately 9 feet wide. It is necessary to 

divide the cabin full width laterally to produce a private area because a side corridor is impractical. 

“The proposed doors will be installed across a longitudinal aisle and translate laterally to open and 

close. 

StandardAero believes that the basic issues of a passenger finding and reaching an exit in an 

emergency are addressed by the above additional safety features and by the existing safety 

parameters inherent in the operation of private use airplanes. StandardAero also believes that even 

if some extreme condition should result in a door being closed or partially closed after an accident, 

there are simple means to get through the door to reach the exit(s). For this reason, the exemption, 

as requested, would provide a level of safety for passengers in the Embraer Model ERJ 190-100 

IGW that would be equal to that required for passengers of airplanes in commercial operation. 

“Public Interest”

Because the design features listed above provide adequate passenger protection, the granting of 

this petition would allow StandardAero to provide the type interior layouts expected in the class of 

airplane while simultaneously providing an adequate level of safety. Allowing the installation of more 

comfortable and useful cabin interiors, while maintaining an adequate level of passenger protection, 

is in the public interest. 

Justification to Bypass Notice of Exemption Petition in the Federal Register 

StandardAero’s petition for an exemption for the EJR 190-100 IGW is identical in substance to the 

FAA Exemption No. 9458 for the Embraer 190-100 ECJ. “Because this exemption petition is identical 

in substance to several exemptions that have been issued in the past, granting of this proposed 

exemption would not raise new issues or set any legal precedent. Accordingly StandardAero

requests that the FAA not delay granting of this exemption for publication of the petition summary in 

the Federal Register, as allowed by § 11.87. 

“StandardAero states that the doors will have the following additional safety features: 

1. Each interior door will be frangible, so that in the event that it is jammed in the 

deployed (i.e., spanning across the aisle) position, it will allow a 5

th 

percentile female 

to break the doors open in case of an emergency, creating a large enough opening 

that a 95

th 

percentile male can pass through. 

2. Each interior door will also be equipped with dual latching mechanisms to hold the 

door in the open position, such that the probability of unlatching due to distortion of 

the fuselage in an emergency landing will be minimized. Either latching means will be 

able to withstand the loads imposed upon it when the door is subjected to the ultimate 

inertia forces specified in 14 CFR §25.561. 

3. The “pocket door” will be at a right angle to the longitudinal axis of the airplane. 
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4. When the doors are deployed (i.e., spanning across the aisle), there will not be a 

latching mechanism that keeps the doors in that position, obstructing the aisle. This 

will allow occupants to open the door from either side without the use of any tools. 

5. An advisory CAS message “Door Pocket Not Open” will be provided for crew when an 

interior door is not open and latched for takeoff and landing. The doors will be 

placarded to be latched open during taxi, take-off and landing. 

6. The Airplane Flight Manual will provide procedures and limitations to ensure that the 

doors are in the proper position for taxi, takeoff and landing. 

Sincerely,

Bruce Basinger

StandardAero Engineering