HEADQUARTERS BOMBARDIER AEROSPACE 400 COTE
-VERTU ROAD WE ST DORYAL, QUE BEC CANADA H4S I Y9 TEL. 514-855-5000 FAX . 514-855-740 1 WWW .BOMBARDIER.COM October 30 1 \ 2014 BD700/M170/A-110082 Mr. Gaetano Sciortino Manager, New York Aircraft Certification Office Federal Aviat ion Administration 1600 Stewart Avenue Westbury, New York U.S.A. 11590 Attention: Mr. Ray Reinhardt, Project Manager 

# BOMBARDIER the evolut ion of mobility

Subject: Global 7000/8000 airplane models BD-700-2A12 and BD-700-2A-13- Petition for Exemption per 14CFR 

### § 11.61(b) from 14CFR 

### § 25 . 809(a) with respect to Visibility ofthe Ground Area under Certain Conditions. References: (1) BA Letter BD700/M170/ A-1 /0062, titled "Global 7000/8000- Request for Equivalent Level of Safety against 14 CFR 25 . 809(a) for Viewing of the Evacuee Ground Contact Area from Over-wing Exits.", dated 2014- 02-28. (2) FAA Exemption No. 10840 for B ombardier CSeries. (3) Title 14 Code ofFederal Regulations (14CFR) 

### § 11.81, titled "What information must I include in my petition for an exemption?" , Docket No . 1999
- 6622, 65 FR 50863 , dated 2000-08-21.
Dear Mr. Sciortino, Pursuant to 14CFR 

### § 11.61(b), Bombardier Aerospace (BA) respectfully requests an Exemption from 14CFR § 25.809(a) for the Global 7000/8000 airplane models BD-700-2A12 and BD-700- 2A13, and withdraws the Equivalent Level of Safety request previously submitted on this subject (reference 1) . This petition is made with respect to viewing of evacuee ground contact area from the over-wing exit and is consistent with previously granted exemptions (reference 2). Enclosed with this letter is the Exemption Request Form completed in accordance with 14CF R 

### § 11.81 (reference 3). Should you require additional information, please contact Rodrigo Ortigoza at ( 416) 373-7492 or via e-mail at rodri go .orti goza@ aero.bombardier.com. Page 1 of2Yours truly,



### for Tim Bilic Airworthiness Section Chief, Global 7000/8000**Bo~ardi0r** ikmspace 

# BOMBARDIER the evolution of mobility

Page 2 of2

### Bombardier Airworthiness Coordination Sheet
Subject: 

### BA letter BD700/M170/A-1 /0082, titled "Global 7000/8000 airplane models BD700-2A12 and BD-700-2A-13
- Petition for Exemption per 14CFR § 

### 11.61(b) from 14CFR § 

### 25.809(a) with respect to Visibility ofthe Ground Area under Certain Conditions", dated 2014-10-28 . Reference: 

### 1. Global 7000/8000 Certification eRoom Action Item #3565.
DISCIPLINE NAME APPROVAL I 

### DATE 

### Occupant Safety (Interiors) G. Partridge • Digi tall y signed by

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### Grant Partndge o"'",G " "" '""'•'· '·"" , G''b' '· erna it .. **grant.partnd ge~aero.**  **~~bardie r.com,**  c : CA Dilte:20 14.10.3014 :53 .38-D4 00 Digitally si g ned by Rodrigo Ort.goza 

### Airworthiness Focal R. 

### Ortigoza 

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### rlgo r IQOZa •moilo<odngo.oni gou@<O"o .bomb;,.di••.com. co CA Date : 201 4. 10.30 14:49:41 -o4'00'

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### Airworthiness-Manager--- T. Bilic

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### Page Lof 2 _EXEMPTION RE Q UEST FORM REQUEST MADE BY: Bombardier Inc. 123 Garratt Blvd. Toronto, Ontario, Canada M3K 1 Y5 Contact Person: Chris Watkiss Email: chris.watkiss@aero.bombardier.com Tel: (416) 373-7632
REQ UEST MADE TO: Federal Aviation Administration (FAA) New York Aircraft Certification Office (NY ACO) 14CFR PROVISION: 14CFR 

### § 11.6l(b) SPECIFIC SECTIONS OF 14CFR FROM WHICH WE SEEK AN EXEMPTION: 14CFR § 25.809(a) (a) Each emergency exit, including each flightcrew emergency exit, must be a movable door or hatch in the external walls of the fuselage, allowing an unobstructed opening to the outside. In addition, each emergency exit must have means to permit viewing of the conditions outside the exit when the exit is closed. The viewing means may be on or adjacent to the exit provided no obstructions exist between the exit and the viewing means. Means must also be provided to permit viewing ofthe likely areas of evacuee ground contact. The likely areas of evacuee ground contact must be viewable during all lighting conditions with the landing gear extended as well as in all conditions of landing gear collapse.
THE EXTENT OF RELIEF WE SEEK: Bombardier requests an exemption from compliance with 14CFR 

### § 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. 1

1 See FAA Exemption No. 10840 for Bombardier CSeries, and FAA Exemption No. 10757 for Embraer EMB-550. Page 1 of3

### EXEMPTION REQUEST FORM
THE REASON WE SEEK RELIEF: The Global 7000 /8000 emergency exits will be subject to the standards of 14CFR 

### § 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 orjump off the trailing edge ofthe 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 the public interest because it: a) Avoids expenditure ofresources to meet some aspects ofthe present regulation which will be changed in the future due to recognized implementation difficulties. a) Allows the Global7000/8000 airplane models BD-700-2A12 and BD-700-2A13 to meet EASA, FAA and TCCA anticipated future ham1onized regulation preventing competitive disadvantage due to additional design/manufacturing complexity and increased weight. b) Avoids 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 ofthe 14 CFR final rule publication, the objective ofthe 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. 2 b) The design ofthe Global 7000/8000 airplane models BD-700-2A12 and BD-700-2Al3 is consistent with industry present state-of-the-art and design practice. c) The Global 7000/8000 airplane models BD-700-2A12 and BD-700-2Al3 will comply with all other aspects ofAWM 525.809(a).

2 Code of Federal Regulations (CFR) Final Rule. Docket No. FAA-2004-19412. Titled "Miscellaneous Cabin Safety Changes". Issued on 2004-10-15. Page 2 uL3EXEMPTION REQUEST FORM
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER: The Bombardier Global 7000 and Global 8000 are ultra-long-range, executive interior business jets, with a 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 14CFR 

### § 25.809(a) for the Global 7000/8000 airplane models BD-700-2A12 and BD-700-2A 13 with respect to the viewing ofthe ground cont&ct area un der all lighting 

### and landing gear conditions for the over-wing 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 ofthe ground contact area under all lighting and landing gear conditions is not possible. Bombardier requests an exemption from compliance with 14CFR § 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 14CFR 25.809(a), there is no adverse impact on safety ifan 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-700-2A12 and BD-700-2A13 will nonetheless comply with anticipated, harmonized requirements now incorporated in EASA CS 25.809(a) at Amendment 25112.

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