U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

SUBJECT: Petition for Exemption — 14 CFR Part 25, Section 25.813(e) Amendment 25-116

for Learjet Model LJ-200-1A1O

REF: FAA Project Number TC4960W1-T

Partial Grant of Exemption 10670 to 14 CFR Part 25, Section 25.813(e)

Amendment 25-116 for Learjet Model LJ-200-IA1O December11, 2012

Public Docket: FAA-2009-1077

Dear Sir or Madam:

In accordance with 14 CFR Part 11, Learjet Inc. submits this petition for exemption from 14 CFR

Part 25, Section 25.813(e) Amendment 25-116, emergency exit access, for the Learjet Model

LJ-200-1A1O. Relief to this requirement would permit the installation of partition doors in the

cabin of the new Learjet Model LJ-200-1A1O.

An application for a new Type Certificate (TC) has been submitted by Learjet Inc. for this new

model and FAA Project No. TC4960W1-T has been assigned to this effort. The certification basis

for the Learjet Model LJ-200-1A1O is 14 CFR Part 25, Amendment 25-1 through 25-1 27.

The basis of this petition has already been established by the FAA in the granting of exemptionsas shown in the following documents:

• FAA Exemption No. 10188, issued December 27, 2010— Gulfstream Aerospace Corp.

for the Model GVI

• FAA Exemption No. 8767, issued August 14, 2006 — Cessna Aircraft Company

for the Model 750 (Citation X)

• FAA Exemption No. 8621, issued October 3, 2005 — Cessna Aircraft Company

for the Model 560XL (Citation XL)

• FAA Exemption No. 8123, issued September 3, 2003 — Midcoast Aviation Inc.

for the Dassault Aviation Mystere — Falcon 900 and Falcon 900EX
This exemption request addresses the performance standards for the interior doors for both Part

91 and Part 135 operations.

Robert Cahn

Certification Manager, New Product Development

Learjet Inc.

One Learjet Way

Wichita, KS 67209-2942robert.cahnäaero.bombardier.comTel: (316) 946-8968
passageway

s).

Discussion

When 14 CFR Part 25, Section 25.813(e) Amdt. 25-1 was issued to restrict installation of doors

between passenger compartments it did not restrict the installation of doors forward or aft ofpassenger compartments. As such it continued to be common practice for business class

aircraft to install doors which isolated the passenger seating areas from crew work areas. These

doors lowered noise levels in the passenger cabin and created effective work environments on

these business aircraft. On October 27, 2004, Amendments 25-116 and 121-306, titled

“Miscellaneous Cabin Safety Changes’ were published in the Federal Register. This revised 14

CFR 25.813(e) to restrict the installation of any interior door between a passenger seat and anyemergency exit, effectively restricting the use of all interior doors. In addition, the FAA revised

14 CFR 121 .310(f)(6), to prohibit these doors in airplanes manufactured after November 27,

2006, and operated under 14 CFR part 121. However, at that time the FAA chose not to amend

14 CFR Part 135 or 14 CFR Part 91. As a result, aircraft certified prior to Amendment 25-116,

and operating under other than 14 CFR Part 121, are permitted to incorporate these types ofdoor installations.When Amendment 25-116 was issued, the FAA noted that this change was incorporated due to

concerns over passengers’ ability to recognize that an exit exists beyond an interior door

forward or aft of the passenger compartment; and reach the exit beyond the door in the event of

failure of the interior door to open or being jammed.

For the Learjet Model LJ-200-1A1O executive business aircraft, Learjet Inc. believes that it is

possible to provide

a level of safety consistent with the intent of the 14 CFR Part 25 regulations

while allowing for installation of certain interior pocket doors. This will be accomplished by

incorporating specific design features to ensure the passengers’ ability to effectively identify the

exit and egress the aircraft is not diminished.

Learjet Inc. is proposing specific design requirements to provide this level of safety appropriate

to the operations of executive business aircraft, both private (14 CFR Part 91) and for hire

(common carriage) (14 CFR Part 135) equipped with partitions and doors.

The Learjet Model LJ-200-1A1O executive business aircraft will be designed to the requirements

of 14 CFR Part 25, Transport category. These rules basically address airplanes that are usedfor the carriage of fare paying passengers or the general public. Additionally, the rules consideraircraft with a passenger seating of up to 500. The new Learjet Model LJ-200-1A1O will have a

maximum seating capacity of ten (10) passengers, and will be equipped exclusively for

executive business aircraft use. The difference between the commercial transport categoryaircraft used in airline operation and aircraft specifically used for executive business operationsare not segregated in the 14 CFR Part 25 rules. Learjet contends that airplanes specificallydesigned for executive business operations, whether private or for hire (common carriage)

should be eligible for the acceptance by exemption of cabin features which do not comply withthe full requirements of 14 CFR Part 25 provided that they demonstrate and provide similar

levels of safety.
14 CFR Part 135 operations.

The new Learjet Model LJ-200-1A10 will have a maximum seating capacity of ten (10)

passengers and two (2) crew members. The standard floor plan arrangement will consist of four

(4) club seating arrangement in the main passenger cabin (see Figure 1).

Over Wing Type Ill

Emergency Exit

Figure 1 — Standard Floor Plan Arrangement

Optional floor plan arrangements will also be available, they will consist of a three (3) club

seating arrangements and a three (3) place side-facing divan (See Figure 2). Installed in the aftsection of the main passenger cabin, as part of both the standard and optional seating

arrangements, will be a manually operated single “pocket” door stowed in the LH Aft Lavatory

Partition that will separate the main passenger cabin from the aft lavatory. The aft lavatory area

will consist of a vanity cabinet on the LH side and a toilet enclosure on the RH side with

provisions for an optional belted seat.

Entryype I Ei

Single Pocket Door — Aft Lavatory I

Optional Single Pocket Door -Mid-Cabin

Over Wing Type Ill
Figure 2 — Example of Optional Seating Configuration

As a customer selected option, a manually operated single mid-cabin “pocket” door will be

installed just aft of the RH forward galley. The optional mid-cabin door will only be available for

use if the aircraft is operating under Part 91 operations. When the aircraft operates under Part

135 operations (for hire or for common-carriage), this door will be required to be removed or

mechanically disabled in the stowed position.

The main entry door, a Type 1 exit, will be located on the LH side of the aircraft, approximately

three feet aft of the cockpit. From inside the aircraft, a single handle, located on the forward

side of the door, is rotated upward releasing the locking mechanism allowing the door to open

outward. A set of stairs are integrated into the door along with hand rails on the aft side to assistoccupants in entering and exiting the aircraft.

Installed on the RH side, just outboard of the toilet enclosure in the aft lavatory, will be a Type Ill

emergency exit. Opening of the Type Ill emergency exit from inside the aircraft will consist of

rotating a handle up and forward which will allow the door to move upward to clear the lower

latches and thus swing outward and forward along the fuselage. The door will remain attached

to the door opening structure and will not be a removable plug style door like other aircraft in its

class. Additionally, the Type Ill emergency exit door will have a latching mechanism to retain it

in the open position.

There are several technical arguments to support special consideration for this size of aircraft

with a passenger count of ten (10) or less; which is significantly less than the amount carried in

airline service. One of which is the distance between the Type I and Type Ill emergency exits ofapproximately 18.5 feet and separated by one single aisle. Passengers leaving their seats will

either move forward or aft to reach an emergency exit. Bulkhead Exit signs will be installed on

both the forward LH partition and the RH aft partition, providing occupants awareness that the

exits are located beyond the bulkheads. In addition, opening of the Type III emergency exit

from inside the aircraft will be much easier in that, in the event of an emergency, an occupant

will not have to decide what to do with a door that is at least 20 inches wide by 36 inches high

weighing between 45 to 50 lbs. All they will have to do is rotate the handle up and forward, push

the door outward and forward along the fuselage where it will lock into the open position. The

opening of the Type I door from inside the aircraft will only require the rotation of the handle

— I’

Entry/Type I Exit

Single Pocket Door — Aft Lavatory — Optional Single Pocket Door - Mid-Cabin
from receiving remuneration to the extent consistent with 14 CFR parts 125 and 91, subpart F,

as applicable. These design features are similar to exemptions previously granted for private

aircraft operations and the limitations will be documented in the limitations section of the AFM:

• The door will open and close in a transverse direction. That is, the direction of motion of

the door will be at a right angle to the longitudinal axis of the airplane. A “pocket door” is

one example of such a design. This will tend to minimize the chance that the inertia

forces of an accident could force the door closed.

• The door will have a redundant means to latch the door open (stowed) position for taxi,

take-off and landing. Each latching means will be shown to retain the door in the open

(stowed) position under all emergency landing loads specified under 14 CFR 25.561(b).

• The doors between the passenger compartments and emergency exits will be frangible.

Frangibility is intended to ensure that if a door is jammed closed, occupants can escape

in either direction and emergency equipment can be moved. Two (2) tests will be

conducted to show the effectiveness of the frangible door. One will show that a 5thpercentile female will be able to egress forward out of the lavatory. A second test will

show that a 5th percentile female will be able to egress aft towards the Type Ill over-wing

exit. Both tests will show that a g5th percentile male will be able to follow through theopening that the percentile female had created. Guidance from Advisory Circular 25-

17A, Transport Airplane Cabin Interiors Crashworthiness Handbook, paragraph 43b(2)

will be followed.

• No hazards will be present after breaking thru frangible door.• A placard describing the frangibility procedure will be installed in a conspicuous location

on both sides of the door.

• A placard requiring the door to be in the open position will be installed in a conspicuous

position on both sides of the door

• An Amber CAS message will alert the pilots if either of the interior doors are not in the

properly open (stowed) position when the landing gear is down or the flaps are not fully

retracted for taxi, takeoff, and landing.

• The doors will be equipped with an override function allowing an occupant to open either

door from the cabin side.

For Part 135 operations, only the aft lavatory door will be a functional door. The mid-cabin door

will either be removed or mechanically locked in the stowed position, preventing it from being

used. In addition to the requirements listed above, the following design features will be included

in the lavatory door and the limitations will be documented in the limitations section of the AFM:

• Operation will be limited to Part 135 operations and below. No Part 121 operations will

be permitted

• The installation will be limited to the lavatory door.
o The test will include the 5th percentile female passing through the lavatory door

utilizing its frangibility features and opening the Type Ill exit; all within 10

seconds.

o The type Ill exit is defined as open when it meets the requirements defined in §

25.809(i).

o The resultant opening that the female makes will be shown to be big enough at a

minimum for the g5th percentile male to evacuate. Guidance from AdvisoryCircular 25-1 7A, Transport Airplane Cabin Interiors Crashworthiness Handbook,paragraph 43b(2) will be followed.

o The pre-flight video briefing will be provided to the test subjects prior to running

test.

o The test will be conducted under emergency lighting conditions and normal

airplane attitude.

• A self-stowing Type Ill exit (or larger) will be installed in the aft lavatory compartment.

The Type lii exit will be designed such that when operated to the fully open position, the

hatch/door is automatically disposed so that it neither reduces the size of the exit

opening, the passageway leading to the exit, nor the unobstructed space specified in the

regulations to below the required minimum dimensions. In the fully open position it willnot obstruct egress from the exit via the escape route specified in § 25.810(c).

• A video briefing will demonstrate to the passengers the use of the door including its

frangible features. The AFM will require that the video is shown each flight.

• The door will be designed to be automatically open (stow) when the landing gear is

down or the flaps are not fully retracted. It will be designed so that it can only be closed

(deployed) when the gear and flaps are fully retracted (airborne configuration), or whenthe parking brake is engaged.

• The latches will be cycle tested to a minimum of 100,000 cycles to account for wear and

tear in service.

• In accordance with Learjet’s approach to compliance with 14 CFR 25.1309, the failure to

egress through any individual emergency exit is classified as Major. Learjet willdemonstrate that the probability of failure to egress through the Type Ill emergency exits

will meet the criteria for a failure scenario classified as Major. This will include

conducting a quantitative analysis that shows the probability of this scenario to be less

than i0 per flight hour. This hazard criticality is based on 14 CFR 25.783(b)(2).
Learjet recognizes that the exemptions previously granted have a stipulation that the aircraft

must not be operated for hire or offered for common carriage. However, Learjet has proposed anumber of additional safety features for the lavatory door so that occupants with limited

knowledge of the aircraft will clearly be able to deal with safety situations similar to occupants

with intimate knowledge. These safety features will ensure the same level of safety for

passenger egress as is required for any emergency exit and will provide a clear egress path.

Although the current operational requirements under Part 91 and Part 135 for this type of

aircraft have not been amended to correspond to Part 25 restriction, Learjet acknowledges that

the Part 25 change is an important enhancement to the level of safety offered by newly

manufactured aircraft. The design criteria proposed by Learjet raises the current level of safety

to that envisioned by Amendment 25-116 to Part 25.

Issue of Public Interest

Learjet iflC. has been manufacturing executive business aircraft for a wide variety of customers,

world wide for more than fifty (50) years. Its leadership in the business aviation is due in

a large

part to its innovative design and advanced technologies, providing customers with efficient, safe

and economical executive aircraft. Customer expectation and satisfaction is

a cornerstone in

the sale of business aircraft. Customers in this market segment have come to expect the ability

to segregate their cabin into private areas to conduct their business transactions. Lavatory

areas have an additional expectation of privacy that simple curtains do not provide. Limiting the

use of doors on the Learjet 200-lAb would negatively affect the marketability and sale of the

aircraft. This effect would be even greater if the lavatory door were not available for all

requested flight operations. Learjet provides thousands of jobs to the region. In addition, the

program utilizes numerous supplies from all over the United States, providing economic growth

and stabilization of the American job market. The loss of sales would impact not only Learjet,

but its entire supply chain. Additionally, since customers desire these doors and expect a level

of privacy in lavatory compartments, they may opt for aircraft designed to an earlier certification

basis, in lieu of the LJ-200-1A1O. This will restrict the advancements in safety introduced by the

LJ-200-1A1O airplane, not only in the areas of cabin safety, but thorough out the airplane. This

is counter to both Learjet’s and the FAA’s goal of continuous improvement in overall aircraft

safety. The advancement of aircraft safety is in the interest of the public.

Operation Outside of the United States

The European Aviation Safety Administration (EASA) Certification Standard (CS) 25.813

regulation is not currently harmonized with 14 CFR 25.813 and does not restrict these types of

door installations.

Regardless of EASA requirements, per 14 CFR 11.81(h) Learjet requests consideration be

given to extending this exemption for operation outside of the United States. Learjet aircraft are

routinely registered and operated outside of the United States and projections are the same for

the Learjet Model LJ-200-1A1O. Granting this extension of privileges will allow for operations
Learjet Model LJ-200-1A1O.