HEADQUARTERS 

BOMBARDIER AEROSPACE 

400 COTE-VERTU ROAD WEST 

DORY AL, QUEBEC CANADA H4S I Y9 

TEL. 514-855-5000 

FAX. 514-855-7401 

WWW.BOMBARDIER.COM 

October 301

\ 2014 

BD700/M170/A-110082 

Mr. Gaetano Sciortino 

Manager, New York Aircraft Certification Office 

Federal Aviation Administration 

1600 Stewart A venue 

Westbury, New York 

U.S.A. 11590 

Attention: Mr. Ray Reinhardt, Project Manager 

BOMBARDIER 

the evolution 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 of the 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 Bombardier CSeries. 

(3) Title 14 Code of Federal 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 14CFR § 

11.81 (reference 3). Should you require additional information, please contact Rodrigo Ortigoza 

at ( 416) 3 73-7492 or via e-mail at rodrigo.ortigoza@aero. bombardier. com. 

Page 1 of2 
Yours 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 of the 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 • Digitally signed by ~ra r~ t Partridge Grant Partndge o"'",G""" '""'•'· '·"",G''b''· ernait .. grant.partndge~aero. ~~bardier.com, c: CA 

Dilte:2014.10.3014:53.38-D4 00 

Digitally signed by Rodrigo Ort.goza 

Airworthiness Focal R. Ortigoza R d • o t• ON =RodrigoOrt go~o ou. 0 rlgo r IQOZa •moilo<odngo.onigou@<O"o.bomb;,.di••.com. coCA 

Date: 201 4.10.30 14:49:41 -o4'00' 

Airworthiness-Manage -k,"' (.

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">;ef:. 

T. Bilic ~~---·~~· 

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3D Ccla,1 \ / 

Page Lof2 _ 
EXEMPTION REQUEST 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 

REQUEST 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 of the 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 or jump off the trailing edge of the 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 of resources to meet some aspects of the 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) A voids 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 of the 14 CFR final rule 

publication, the objective of the 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 of the 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 of A WM 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 uL3 
EXEMPTION 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 of the ground cont&ct area under 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 of the 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 if an 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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