A GBNBRAL DYNAMICS COMPANY

April 19, 2010

A&C-10-129

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE. Washington, DC 20590

Subject: Request for Exemption from Section 25.813{e) of Title 14, Emergency

Exit Access

FAA Project No.: TC8700AT-T

Attachment: Petition for Exemption

- Installation of Interior Doors, Model GVI

Dear Sirs:

In accordance with 14 CFR Part 11, Gulfstream Aerospace Corporation requests consideration

of the enclosed petition for exemption. This petition is being submitted to relieve the Gulfstream

GVI model aircraft from full compliance with 14 CFR 25.813(e) at amendment 116, Emergency

exit access, to allow for installation of interior doors in certain locations.

If you have any questions or need additional information please contact Natalie Mault at (912)

965-5466 (via email atnatalie.mault@gulfstream.com) or the undersigned.

Sincerely.

Robert Glasscock

Product Development Team Lead

GVI Airworthiness and Certification

Gulfstream Aerospace Corporation

P.O. Box 2206, MIS R-03 Savannah, GA 31402-2206 robert.glasscock@gulfstream.com (912) 965-6817

cc: N. Berryman, ACE-102A (via email)

P. Hatton, EASA (via email)

M. Gordon, ANM-113 (via email)

P.O. Box 2206 • Savannah, GA 31402·2206 USA. Telephone (912) 965-3000 • gulfstream.comPetition for Permanent Exemption Gulfstream Aerospace Corporation
Installation of Interior Doors

Model GVI

Relief from section 14 CFR Part 25.813(e) Amdt. 25- 116

Gulfstream Aerospace Corporation (Gulfstream) of Sa vannah, Georgia has submitted an application
to the FAA’s Atlanta Aircraft Certification Office for type certification of a new, twin-engine, trans port category aircraft to be known as the Gulfstream mod el GVI. FAA Project Number TC8700AT-T has been assigned to this effort. The GVI cabin interi or relies on the installation of various doors to provide certain amenities and configuration options that have become the standard for Executive
Class aircraft.

14 CFR 25.813(e), Amendment 25-116 – States in part that no door may be installed bet ween any passenger seat that is occupiable for take off and landing and any passenger emergency exit, such that the door crosses any egress path (including ai sles, crossaisles and passageways).

The GVI design incorporates two doors between the p assenger seating areas and the main entry door. See Figure 1, Acoustic and Forward Vestibule Door Arrangement. One door will be an acoustic door provided between the forward vestibule and the main entry door. Its purpose is to maintain an acceptable acoustic level in the passenger cabin an d pilot compartment and will be standard equipment. The second door will be a forward vesti bule door and is offered on certain interior configurations. An example of one such configurati on is depicted below. Its purpose is to provide:

1) Isolation of the crew rest facilities in accord ance with guidance per AC 121-31;

2) Separation between passenger and crew areas inc luding the galley, crew rest, and cockpit.



## Figure 1 - Acoustic and Forward Vestibule Door Arra ngementIn accordance with the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 14 CFR

25.813(e) for installations of these cabin interior doors. This will allow the GVI aircraft to provid e a safe, quiet operating environment for the crew and passengers, and meet the requirements for crew rest areas. Gulfstream proposes that specific desi gn features, combined with the unique configuration of the GVI, will provide an overall level of safety beyond that intended when the FAA promulgated
Amendment 25-116. Based on these features Gulfstre am proposes that this exemption be applicable to both private use aircraft (14 CFR part 91) and t hose used for hire (14 CFR part 135). The information provided herein will outline this ratio nale.

Supportive information

At Amendment 25-1, 14 CFR 25.813(e) was revised to restrict installation of doors between passenger compartments. This did not restrict the installation of doors forward or aft of passenger compartments. As such it continued to be common pr actice for business class aircraft to install doors which isolate the passenger seating areas from crew work areas. These doors lower noise levels in the passenger cabin and create effective work envir onments. 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 restric t the installation of any interior door between a passenger seat and any emergency exit, effectively restricting the use of all interior doors. In addi tion, the FAA revised 14 CFR 121.310(f)(6), to prohibit t hese doors in airplanes manufactured after November 27, 2006, and operated under 14 CFR part 1 21. However, at that time the FAA chose not to amend 14 CFR part 135 or 14 CFR part 91. As a r esult, aircraft certified prior to Amendment 25- 116, and operating under other than 14 CFR part 121 , are permitted to incorporate these types of
door installations.

When Amendment 25-116 was issued, the FAA noted tha t this change was incorporated due to concerns over passengers’ ability to 1) recognize t hat an exit exists beyond an interior door forward or aft of the passenger compartment; and 2) reach the exit beyond the door in the event of failure of the interior door to open.

For the GVI aircraft, Gulfstream believes that it i s 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 doors

. This will be accomplished by incorporating specific design features that provide an acceptable level o f safety. These features will ensure the design will not diminish a passengers’ ability to 1) effective ly identify the exit and 2) egress the aircraft.

Factors supporting the Petition

The following design features of the GVI interior d oors and passenger cabin will ensure that the passenger’s ability to effectively identify the exi t is not diminished:

 The doors will be designed to automatically open ( stow) based on the airplane being configured for landing and will remain open until the airplane has returned to an airborne flight configuration.
The installation of the interior doors will therefo re not adversely affect passenger recognition of th e Main Entry Door (MED).

 The doors will only be installed forward of the pa ssenger seating area and between passenger seats and the MED. The MED is the only door availa ble to enter the aircraft and its location is inherently established for all passengers upon boar ding. Emergency exit locator and marking signs and emerg ency lighting in accordance with 14 CFR

25.811 and 25.812 will be provided.

 The over wing emergency exits are optimally locate d in the passenger compartment, in clear and obvious view, and are in an area of high passenger density. These exits will also be indicated via locator signs and markers, as well as emergency esc ape path lighting. This heightened passenger awareness and ease of identification will increase the likelihood of passengers utilizing the over wing exits provided in the cabin versus de faulting to the entry door. Reference Figure 2, GVI Emergency Egress Routes.

The following design features of the GVI interior d oors and passenger cabin will ensure that the passenger’s ability to effectively egress the aircr aft is not diminished by ensuring that the doors wi ll be open for taxi, takeoff and landing, without requiri ng passenger or crew action.

 The doors will be designed to automatically open ( stow) when the airplane has been configured for landing (gear down or flaps down).

 The operation of the door to the closed (deployed) position will require manual activation. The doors will be designed so that they can only be clo sed (deployed) when the gear and flaps are fully retracted (airborne configuration), or for gr ound maintenance activity.

 The doors will be designed so that for any failure of the closing/latching mechanism, the doors will default to the open (stowed) position.

 In accordance with Gulfstream’s approach to compli ance with 14 CFR 25.1309, the failure to egress through any individual emergency exit is cla ssified as Major. Gulfstream will demonstrate that the probability of failure to egress through t he Main Entry Door (MED), including the probability of failure of both interior doors, will meet the criteria for a failure scenario classifie d as Major. This will include conducting a quantitative analysis that shows the probability of this
scenario to be less than 10 -5 per flight hour. This hazard criticality is based on 14 CFR 25.783(b)(2).

 The doors will have a hold-open feature that will be shown to react all emergency landing loads specified under 14 CFR 25.561(b).

 The doors will be placarded to be open and latched for taxi, takeoff, and landing (TT&L). Manual operation to the open (stowed) position is the prim ary means by which the doors should be open and stowed for TT&L. The automatic opening feature will ensure clear egress paths in the event that manual operation has not occurred.

 An Amber CAS message will alert the pilots if an i nterior door is not in the properly open (stowed) position for TT&L.

 With the doors in the open (stowed) position, the critical forward emergency landing loads will not cause either door to deploy and block access to the main entry door.

 The over wing emergency exits have been designed s o that they can all be deployed at the same time to provide multiple, redundant egress paths fo r escape from the passenger compartment. Each of the four over wing emergency exits require single file egress and have been sized to provide substantial egress area. This reduces the problems caused by passenger panic and congestion typical in single, larger exits. Smooth , effective egress of passengers through the existing over wing exits will also increase the lik elihood of passengers utilizing the over wing exits as opposed to seeking alternate escape routes furth er away (MED). Reference Figure 2, GVI Emergency Egress Routes. Both doors will be designed to be frangible from ei ther side of the door. In case of an emergency,

this design will allow a 5th percentile female to c reate an aperture large enough to allow for a 95th percentile male to escape.

Additional GVI Design Considerations:

 The main entry door is also the flight crew emerge ncy exit. In the event of an emergency evacuation, a trained crew member will be responsib le to ensure egress is maintained through this passageway to the MED.

 Gulfstream will demonstrate that the over wing exi t pair will be equivalent to the size and number of exits required by 14 CFR 25.807(g). The GVI air craft will comply with 14 CFR 25.807(g) for required number of emergency exits through the over wing exits. Gulfstream intends to demonstrate that the MED is an emergency exit in ex cess of the minimum required on the left
hand side of the aircraft.

 Through an Equivalent Level of Safety finding to 1 4 CFR 25.813(c)(2), Gulfstream will address FAA Policy number ANM-115-08-02, and intends to dem onstrate that the GVI exit pair will provide equivalent egress capability to that of a required Type III.

 Compliance with 14 CFR 25.807(i) for ditching will be shown through the use of the over-wing emergency exits as required by 14 CFR 25.807(g). T he forward entry door will not be utilized under this scenario for emergency evacuation and ap plicable placards will be provided. The Airplane Flight Manual will define proper procedure s for exiting the aircraft in these conditions.

 Many of the passengers typically utilizing Executi ve Class aircraft are frequent passengers who are familiar with the operation of the interior fea tures and locations of emergency exits.



## Figure 2 - GVI Emergency Egress RoutesEffect of the Exemption on Safety

Acceptance of the proposed GVI design will ensure t hat a level of safety consistent with the intent of the regulation has been provided. The design of th e proposed interior doors will ensure the same level of safety for cabin egress as is required for any emergency exit and will provide a clear egress path. This combined with other characteristics of the GVI such as redundancy of emergency exits, large area over wing exits and optimal location of emergency exits, will provide a level of safety exceeding that currently prescribed under 14 CFR pa rt 25.

Although the current operational requirements under Parts 91 and 135 for this type of aircraft have no t been amended to correspond to the Part 25 restricti on, Gulfstream 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 Gulfstream for the GVI raises the current level of safety to that envisioned by Amendment 25-116 to part 25.

Issue of Public Interest

Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the world's most technologically advanced business jet aircraft to an international market. Gulfstream’s leadership position in the global business jet mark et is due to the efforts of its nearly eight thousa nd employees in the manufacturing plants, completion c enters, and service centers across North America. The corporation utilizes numerous product s, such as avionics and environmental control systems, from scores of suppliers located through o ut the United States. Gulfstream competes for new business all over the world. Although the curr ent world economy has slowed in comparison to previous years, the corporate aircraft market is ex pected to grow. This exemption will directly impac t the cabin and flight deck acoustics and the effecti veness of flight crew rest facility design, thereby having a direct effect on GVI sales. The ability t o provide additional acoustic barrier from external noise for the flight deck and cabin are being reque sted by prospective aircraft operators who compare the GVI with products of European and other foreign aircraft manufacturers. The inability to provide such features will ultimately cause a reduction in perspective sales. The manufacture, completion, and support of Gulfstream aircraft would aid in the stabilization of the job market as well as the gro wth of the American economy, which is in the interest o f the public.

Since customers desire to have these interior doors , they may opt for aircraft designed to an earlier certification basis, in lieu of the GVI. This will restrict advancements in safety introduced by Gulfstream with the GVI, not only in the areas of c abin safety, but throughout the airplane. This is counterproductive to both Gulfstream and the FAA’s goal of continuous improvement in overall aircraft safety. The advancement of aircraft safety is in t he 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 doe s not restrict these types of door installations.

Regardless of EASA requirements, per 14 CFR 11.81(h ) Gulfstream requests consideration be given to extending this exemption for operation outside o f the United States. Gulfstream aircraft are routinely registered and operated outside of the Un ited States and projections are the same for the Model GVI. Granting this extension of privileges wi ll allow for operations based within foreign countries, including EU member countries, having bi lateral agreements with the United States accepting FAA 14 CFR part 25 as their airworthiness standards for transport category aircraft. Gulfstream believes that limiting this exemption to use within the U.S. would put unfair restrictions on the marketability of this aircraft.

Conclusion

Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.813(e) that would
allow for installation of certain interior doors on the GVI aircraft. In addition, Gulfstream believe s that an exemption is in the public interest and will pro vide a level of passenger safety consistent with th e current Part 25 regulations.