### 1 8/09/11

U.S. Department of Transportation Docket Operations, W est Building, Ground Floor, Room W 12
- 140, 1200 New Jersey Avenue, SE Wa shington, DC 20590
RE: Petition for Exemption to 25.8 1 3( 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 25.8 1 3( 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 Pa rt 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
-fo r- hire. StandardAero believes that a irplanes 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 demonstra ted. 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” pas sengers, wh ich 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 provid ing such privacy is through the use of doors that separate passenger compartments. Wh en 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 longitu dinal 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 inh erent 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 de sign 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. **J ustification to By**  **pass Notice of Exemption Petition in the Federal Register** StandardAero’s pet ition for an exemption for the EJR 190
- 100 IGWis 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 percenti le 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 th at 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 1 4 CFR §25.561. 3. The “pocket door” will be at a right angle to the longitudinal axis of the airplane.

### 3 4. Wh en 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 i s not open and latched for take off 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