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Presented to:

The United States of America Department of Transportation

Federal Aviation Administration
Ali Bahrami, Manager Transport Directorate

1601 Lind Avenue SW Renton, Washington 98055

- 4056

Petitioner:
William J Ertle, II, ODA Operations Manager

, STC ODA Administrator

- Alternate PATS Aircraft, LLC

21652 Nanticoke Avenue Georgetown, DE 19947 (302) 253

- 6180 williamertle@decraneaerospace.com

Date : 5 April

, 20 10

Subject : Petition for Exemption under FAR 11.63 from Title 14, Code of Federal Regulatio ns section 25.785 (j) “firm handhold” in the passenger cabin for the Boeing Model 737

- 700IGW (Boeing Bus iness Jets), serial number 37660

.

References : 1) ODA

- 955292

- NE Project No. ODA

- GED

- P0 03 2) FAA Exemption No. 8110 3) FAA Exemption No. 7710. 4) FAA Exemption No. 7923 5) FAA Exemption No. 7609 6) FAA Exemption No. 8624 7) FAA Exemption No. 8786 8) FAA Exemption No. 9464 9) FAA Exemption No. 9683 10) 6108

- 2500

- 600

, Floor Plan ( LOPA ) for Executive Interior (see attachment 1)

PATS Aircraft, LLC (ODA Unit) is a totally owned subsidiar y of DeCrane Aerospace(ODA Holder) , herein referred to as PATS, is submitting this petition to request relief from the firm handhold along each aisle requirem ent for Boeing

Model 737

- 7 00 IGW equipped with an executive interior as de fined in the

attached LOP A . The airplane is designated for private use under the operating rules of FAR Part 91, and Part 1252 of 6

Petition for Exemption

– Firm Ha nd Hold Date: 5 April, 2010 Project: ODA

- GED

- P0 03 Aircraft: Boeing 737

- 700IGW S/N 37660 PATS Airc raft LLC

General Background :

The Boeing Business Jet is intended to be a Executive / VIP aircraft and under

U.S. registration, T he STC certification is sought under ODA project No. ODA

GED

- P0 03

. PATS is contracted to install and certify an executive inte rior in the

BBJ with two interior configurations per customer specifications. The first configuration is identified as “Long Range” floor plan: and the second is the “High Capacity” floor plan. L ayout, drawing 6108

- 2500

- 600 defines both configurations

and some areas where it would be difficult to provide firm handhold per FAR 25.785(j). The request for Exemption is for both configurations of this interior. The Interior arrangement is typical for VIP private corporate business airplane.

Exemption Requested :

That Bo eing 737

- 7 00 IGW, S/N 37660 , when configured for private use and operated under FAR Parts 91, or Part 125 to be exempted from FAR 25.785(j), which requires a firm handhold along each aisle. The areas of this interior that

are non

- compliant are:

Fir st Class Lounge Area Business Class Seating Area

Justification :

Customers are purchasing center

- aisle air transport jet aircraft (larger than the typical corporate business jets) for personal transportation because they wish to create a spacious and imp ressive atmosphere they are accustomed to. The requirement for firm handhold along aisles cannot be met for certain areas in the passenger cabin due to the wide cabin and the open spaces between individual seats. In fact, due to the special cabin layout, a isles are not readily identifiable in certain areas. Any construction hanging down from the ceiling would not be acceptable to the customers.

The “firm handhold” situation was not addressed in the BBJ Exemption 6820 &

6820A granted by the FAA to the Boein g Company for all Boeing Business 737

- 700IGW Jets.

However these exemption did established the justification for an exemption from FAR Part 25 based on the fact the FAR Part 25 does not currently cover or consider such design and operation for private us e. FAR Part 25 requirements are predicated on airline common carrier

- commercial passenger operations carrying fare

- paying passengers from the general public.

The operation of this aircraft is limited to private use by an individual, a company,

or a gove rnment and does not include scheduled flights, fare

- paying public

passengers or cargo

- for

- hire commercial service.3 of 6

Petition for Exemption

– Firm Hand Hold Date: 5 April, 2010 Project: ODA

- GED

- P0 03 Aircraft: Boeing 737

- 700IGW S/N 37660 PA TS Aircraft LLC

Occupant Safety Considerations :

The risk for occupants due to the lack of readily accessible firm handhold per 25.785(j) in certain areas is acceptable for the following reasons:

1) All furniture in the passenger cabin has rounded corners a nd edges to avoid serious injuries to occupants. 2) The seat and divans are heavily upholstered and would not cause serious injury when contacted by occupants. 3) Passageways and doorframes integrated into the cabin layout would provide
means to occupants to sta bilize themselves during turbulence. 4) In Lavatories , occupants can readily use the tall monument to steady

themselves. 5) In the Comfort Bed Area , occupant can use the doorframe and bulkheads to steady themselves and the bed is heavily upholstered and will not cause injuries when contacted. 6) In the First Class Lounge occupants can use bulkheads, seats backs, valance panels and divan arms to steady themselves in case of turbulent flight. 7) In the Business Seating area seat backs , bulkheads, divan arms that are
read ily within reach with one or two step s

. 8) There will be instructions for occupants to remain seated with their seat belts fastened in case of turbulence during flight. 9) Occupants are intimately familiar with the interior arrangement.

Public Interest :

Sales of center

- aisle air transport jets, such as the Boeing Business Jets 737

- 700IGW and 737

- 800, would suffer without granting this exemption. The highly desirable executive interior configuration with private rooms and spacious

environment could not be certif ied without this exemption. Granting this exemption would allow heads of state and executives to conduct their business and create more jobs for the public. Granting the exemption would also be in the interest of international

harmonization because a numbe r of foreign authorities have already accepted configurations as proposed in this petition for exemption. Granting this exemption would be in the public interest because US aircraft manufacturers could sell more large aircraft outside the airline market. The benefits are enormous to the US economy.4 of 6

Petition for Exemption

– Firm Hand Hold Date: 5 April, 2010 Project: ODA

- GED

- P0 03 Aircraft: Boeing 737

- 700IGW S/N 37660 PATS Aircraft LLC

Publication of Petition :

PATS respectfully re quest that the petition be processed and that the publication and the comment procedures be waived in accordance with 14 CFR 11.29 and 11.87 for the following reasons: This type of exemption has been granted before for Boeing Business Jets (737

- 700IGW & 73 7

- 800) and is routinely granted for “Private, Not for Hire” aircraft with Executive or Head of State Interiors (ref. Petitions listed).

The issue is non controversial Granting the petition would not set a precedent

Conclusions :

The Federal Aviation Regul ations do not consider the situation of private use Transport Category airplane. PATS opinion is that the design of an airplane interior for private use, and the associated operation of the airplane in private use, should justify the exemption. In addition

, PATS has proposed alternative features that provide the occupants an acceptable level of safety for the intended use of the airplane.

The airplane is scheduled for delivery back to the customer with an approved

executive interior 7 July 201 0

. We are loo king forward to your favorable response as soon as possible.

Thank you for your time and consideration to this request.

Respectfully Submitted

William J. Ertle II5 of 6

Petition for Exemption

– Firm Hand Hold Date: 5 April, 2010 Projec t: ODA

- GED

- P0 03 Aircraft: Boeing 737

- 700IGW S/N 37660 PATS Aircraft LLC



### Attachment 16 of 6

Petition for Exemption

– Firm Hand Hold Date: 5 April, 2010 Project: ODA

- GED

- P0 03 Aircraft: Boeing 737

- 700IGW S/N 37660 PATS Aircraft LLC



### Attachment 1 (continued)