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US Department of Transportation 

Docket Operations

West Building, Room W12-140 

1200 New Jersey Avenue, SE

Washington, DC 20590-0001

October 23, 2015

Re: Petition for Exemption, 14 CFR 25.817, Project ST1935DRB-T, Installation of a VIP Interior 

on a Boeing 777-200 Series Aircraft 

In accordance with 14 CFR Part 11, VT DRB Aviation Consultants, Inc. hereby petitions for an 

exemption from 14 CFR § 25.817 (Amendment 25-15) as it relates to the above referenced certification 

project. For the reasons detailed below, VT DRB Aviation Consultants requests an immediate 

exemption from this rule.

Aisle with Four Seats Abreast

The owner/ operator of the aircraft desires to have a dining room with a dining table (see Figure 1) 

that seats four on each side, which equates to an aisle with 4 seats abreast. The petitioner proposes 

that the 4 seats abreast are placed on only one side of the aisle (emergency exit path) of the row, 

which leaves less seats abreast along that row than a passenger plane with 3 seats abreast on each 

side of the aisle in any one row. Thus, the modification does not impact the passenger’s ability to 

egress; there are no seats or monuments directly in front of the said seats to impede passengers from 

gaining access to the aisle leading to emergency exits.

Airplane Model

This petition is submitted in support of the installation of a VIP interior on a Boeing 777-200 (reference 

single-use Supplemental Type Certificate (STC) project number ST1935DRB-T). The applicable Type 

Certificate Data Sheet is T00001SE, Revision 37, with a certification basis of Part 25 of the FAR 

effective February 1, 1965, as amended by Amendments 25-1 through 25-82. 

References

 Type Certificate Data Sheet is T00001SE, Revision 37, Boeing 777

 FAA STC project number ST1935DRB-T
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Figure 1 – Boeing 777 Mid-Cabin Interior Floor Plan Showing TT&L Seats and Egress Path

DINING TABLE SEATING 

FOUR (4) ON EACH 

SIDE–EGRESS PATH IS 

UNIMPEDED.
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Good Cause Exists to Issue the Exemption without Notice and Comment

VT DRB Aviation Consultants requests that the FAA issue the exemption without publication for 

comment in the Federal Register.

Section 14 CFR § 11.87 lists four factors considered by the agency in deciding whether a petitioner 

has shown good cause for the FAA not to delay action on the petition. Those factors are set forth 

below in bold italics along with the company's response in plain text:

(a) Whether granting the petition would set a precedent: 

Although there are no exemptions listed by part in the FAA's exemption data base against 14 CFR § 

25.817, it is expected that the aisle shown in Figure 1 would not set a precedent since it is clearly 

shown that there is less passenger egress impedance than in standard Boeing 777 passenger jet 

configurations, where there would be three (3) seats abreast on each side.

(b) Whether the relief requested is identical to exemptions previously granted: 

No previously granted exemptions from 14 CFR § 25.817 are listed by part in the FAA's exemption 

data base. 

(c) Whether delaying action would adversely affect VT DRB Aviation Consultants: 

The initial release of the type data for the VIP Interior Completion defined by Project ST1935DRB-T is 

scheduled for the end of January, 2016. Therefore any delays to the type design past the first of the 

year would negatively impact process/ financing/ customer satisfaction.

(d) Whether the petition was filed in a timely manner: 

The petition is timely filed. 

In light of the above considerations, VT DRB Aviation Consultants submits that good cause exists not 

to delay action on this request.

International operations

The operator of this U.S.-registered aircraft who has contracted with VT DRB Aviation Consultants

for the installation of a VIP interior routinely flies to Europe, Eastern Europe, etc. The dining table 

(see Figure 1) that seats four on each side is expected to remain a part of this aircraft interior in the 

same geographic regions. Therefore, in accordance with 14 CFR § 11.83, VT DRB Aviation 

Consultants requests this exemption apply to both domestic and international operations.

As the State of Registry for the aircraft on which the modification will be installed, the FAA will 

continue to be responsible for the airworthiness and continued airworthiness of this aircraft 

wherever it operates.
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Extent of Relief and Safety

VT DRB Aviation Consultants proposes relief from 14 CFR § 25.817 (an aisle with three seats abreast) 

in lieu of an aisle with four seats abreast on only one side of the aisle (see Figure 1). It is shown that 

this the modification does not impact the passenger’s ability to egress; there are no seats or 

monuments directly in front of the said seats to impede passengers from gaining access to the escape 

path.

Safety is the primary concern of the VIP interior installation. Safety requirements of the original type 

certification of the aircraft will be complied with, as defined by the aircraft type certificate data sheet 

(T00001SE).

Public Benefit

Granting this petition for exemption is clearly in the interest of transport category airplane modifiers 

given the proliferation of transport category VIP interior configurations such as this one (see Figure 

1). Approval of this exemption will enable manufacturers who employ workers in the USA to effectively 

compete in this expanding market that has a preference for longer dining tables. Additionally, sales of 

VIP configured interiors outside of the traditional airline market will serve to increase manufacturers ’

profitability and that of their suppliers/ vendors, which equates to improved financial performance in 

the USA and the USA’s partners abroad.

VT DRB Aviation Consultants respectfully requests that this petition be granted.

Applicant information

The petitioner supports its request with the following, summary information:

The name of the applicant is:

VT DRB Aviation Consultants, Inc.

The primary contact for this application is:

Darryl Seow

VT DRB Aviation Consultants

27326 US Highway 281 North

San Antonio, TX 78260

Ph: (210)888-9430 x210

E-mail: darryl.seow@vt-drb.com