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.com 
Petition 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 Savannah, Georgia has submitted an application 

to the FAA’s Atlanta Aircraft Certification Office for type certification of a new, twin-engine, transport 

category aircraft to be known as the Gulfstream model GVI. FAA Project Number TC8700AT-T has 

been assigned to this effort. The GVI cabin interior 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 between 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 aisles, crossaisles and passageways). 

The GVI design incorporates two doors between the passenger 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 and pilot compartment and will be standard 

equipment. The second door will be a forward vestibule door and is offered on certain interior 

configurations. An example of one such configuration is depicted below. Its purpose is to provide: 

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

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

Figure 1 - Acoustic and Forward Vestibule Door Arrangement
In 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 provide a 

safe, quiet operating environment for the crew and passengers, and meet the requirements for crew 

rest areas. Gulfstream proposes that specific design 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 Gulfstream proposes that this exemption be applicable 

to both private use aircraft (14 CFR part 91) and those used for hire (14 CFR part 135). The 

information provided herein will outline this rationale. 

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 practice 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 environments. 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 any emergency 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 of 

door installations. 

When Amendment 25-116 was issued, the FAA noted that this change was incorporated due to 

concerns over passengers’ ability to 1) recognize that 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 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 doors. 

This will be accomplished by incorporating specific design features that provide an acceptable level of 

safety. These features will ensure the design will not diminish a passengers’ ability to 1) effectively 

identify the exit and 2) egress the aircraft. 

Factors supporting the Petition

The following design features of the GVI interior doors and passenger cabin will ensure that the 

passenger’s ability to effectively identify the exit 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 therefore not adversely affect passenger recognition of the 

Main Entry Door (MED). 

 The doors will only be installed forward of the passenger seating area and between passenger 

seats and the MED. The MED is the only door available to enter the aircraft and its location is 

inherently established for all passengers upon boarding. 
 Emergency exit locator and marking signs and emergency lighting in accordance with 14 CFR 

25.811 and 25.812 will be provided. 

 The over wing emergency exits are optimally located 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 escape 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 defaulting to the entry door. Reference Figure 2, 

GVI Emergency Egress Routes. 

The following design features of the GVI interior doors and passenger cabin will ensure that the 

passenger’s ability to effectively egress the aircraft is not diminished by ensuring that the doors will be 

open for taxi, takeoff and landing, without requiring 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 closed (deployed) when the gear and flaps are 

fully retracted (airborne configuration), or for ground 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 compliance with 14 CFR 25.1309, the failure to 

egress through any individual emergency exit is classified as Major. Gulfstream will demonstrate 

that the probability of failure to egress through the Main Entry Door (MED), including the 

probability of failure of both interior doors, 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 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 primary 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 interior 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 so that they can all be deployed at the same 

time to provide multiple, redundant egress paths for 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 likelihood of passengers utilizing the over wing exits

as opposed to seeking alternate escape routes further away (MED). Reference Figure 2, GVI 

Emergency Egress Routes. 
 Both doors will be designed to be frangible from either side of the door. In case of an emergency, 

this design will allow a 5th percentile female to create 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 emergency exit. In the event of an emergency 

evacuation, a trained crew member will be responsible to ensure egress is maintained through this 

passageway to the MED. 

 Gulfstream will demonstrate that the over wing exit pair will be equivalent to the size and number 

of exits required by 14 CFR 25.807(g). The GVI aircraft 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 excess of the minimum required on the left 

hand side of the aircraft. 

 Through an Equivalent Level of Safety finding to 14 CFR 25.813(c)(2), Gulfstream will address 

FAA Policy number ANM-115-08-02, and intends to demonstrate 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). The forward entry door will not be utilized 

under this scenario for emergency evacuation and applicable placards will be provided. The 

Airplane Flight Manual will define proper procedures for exiting the aircraft in these conditions. 

 Many of the passengers typically utilizing Executive Class aircraft are frequent passengers who 

are familiar with the operation of the interior features and locations of emergency exits. 

Figure 2 - GVI Emergency Egress Routes 
Effect of the Exemption on Safety

Acceptance of the proposed GVI design will ensure that a level of safety consistent with the intent of

the regulation has been provided. The design of the 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 part 25. 

Although the current operational requirements under Parts 91 and 135 for this type of aircraft have not 

been amended to correspond to the Part 25 restriction, 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 market is due to the efforts of its nearly eight thousand 

employees in the manufacturing plants, completion centers, and service centers across North 

America. The corporation utilizes numerous products, such as avionics and environmental control 

systems, from scores of suppliers located through out the United States. Gulfstream competes for 

new business all over the world. Although the current world economy has slowed in comparison to 

previous years, the corporate aircraft market is expected to grow. This exemption will directly impact 

the cabin and flight deck acoustics and the effectiveness of flight crew rest facility design, thereby

having a direct effect on GVI sales. The ability to provide additional acoustic barrier from external

noise for the flight deck and cabin are being requested 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 growth 

of the American economy, which is in the interest of 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 cabin 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 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) Gulfstream requests consideration be given 

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

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

Model GVI. Granting this extension of privileges will allow for operations based within foreign 

countries, including EU member countries, having bilateral 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 believes that 

an exemption is in the public interest and will provide a level of passenger safety consistent with the 

current Part 25 regulations.