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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, 2010

Subject:

Petition for Exemption under FAR 11.63 from Title 14, Code of Federal 

Regulations section 25.785 (j) “firm handhold” in the passenger cabin for the 

Boeing Model 737-700IGW (Boeing Business Jets), serial number 37660.

References:

1) ODA-955292-NE Project No. ODA-GED-P003

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 subsidiary of DeCrane 

Aerospace(ODA Holder), herein referred to as PATS, is submitting this petition to 

request relief from the firm handhold along each aisle requirement for Boeing 

Model 737-700IGW equipped with an executive interior as defined in the 

attached LOPA. The airplane is designated for private use under the operating 

rules of FAR Part 91, and Part 125
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Petition for Exemption – Firm Hand Hold Date: 5 April, 2010

Project: ODA-GED-P003

Aircraft: Boeing 737-700IGW S/N 37660 PATS Aircraft LLC

General Background:

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

U.S. registration, The STC certification is sought under ODA project No. ODAGED-P003. PATS is contracted to install and certify an executive interior 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. Layout, 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 Boeing 737-700IGW, 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:

First 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 impressive 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, aisles 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 Boeing 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 use. 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 government and does not include scheduled flights, fare-paying public 

passengers or cargo-for-hire commercial service.
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Petition for Exemption – Firm Hand Hold Date: 5 April, 2010

Project: ODA-GED-P003

Aircraft: Boeing 737-700IGW S/N 37660 PATS 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 and 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 stabilize 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 

readily within reach with one or two steps.

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 certified 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 number 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.
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Petition for Exemption – Firm Hand Hold Date: 5 April, 2010

Project: ODA-GED-P003

Aircraft: Boeing 737-700IGW S/N 37660 PATS Aircraft LLC

Publication of Petition:

PATS respectfully request 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 & 737-800) 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 Regulations 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 2010. We are looking forward to your favorable response 

as soon as possible. 

Thank you for your time and consideration to this request.

Respectfully Submitted

William J. Ertle II
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Petition for Exemption – Firm Hand Hold Date: 5 April, 2010

Project: ODA-GED-P003

Aircraft: Boeing 737-700IGW S/N 37660 PATS Aircraft LLC

Attachment 1
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Petition for Exemption – Firm Hand Hold Date: 5 April, 2010

Project: ODA-GED-P003

Aircraft: Boeing 737-700IGW S/N 37660 PATS Aircraft LLC

Attachment 1 (continued)