UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION RENTON, WASHINGTON 98057-3356

In the matter ofthe petition of Exemption No. 17045

Gulfstream Aerospace Corporation Regulatory Docket No. FAA-2016-0079 for an exemption from§ 25.813(e) of Title 14, Code ofFederal Regulations

GRANT OF EXEMPTION By letter dated November 20, 2015, Mr. Robert Glasscock, Director ofODA Programs, Gulfstream Aerospace Corporation, P.O. Box 2206, Savannah, Georgia, 31402-2206, petitioned the Federal Aviation Administration (FAA) for an exemption from the requirements of § 25.813(e) ofTitle 14, Code ofFederal Regulations (14 CFR). This exemption, ifgranted, would permit the installation ofmid-cabin pocket doors in Gulfstream Model GVII-G500 airplanes and derivatives when operated for private-use only (not for hire, not for common carriage). The petitioner requests relieffrom the following regulation(s): Section 25.813(e) at Amendment 25-128

- No door may be installed between any passenger seatthat is occupiable for takeoffand landing and any passenger emergency exit, suchthat the door crosses any egress path (including aisles, crossaisles, and passageways). The petitioner supports its request with the following information: This section quotes the relevant information from the petitioner's request, with minor edits for clarity. The complete petition is available at the Department ofTransportation's Federal Docket Management System, on the Internet at http://regulations.gov, in DocketNo. FAA-2016-0079. Relieffrom Section 14 CFR25.813(e), Arndt. 25-128 Gulfstream Aerospace Corporation (Gulfstream) ofSavannah, Georgia, has submitted an applicationto the Atlanta Aircraft Certification Office for type certification ofa new,twin-engine, transport category airplane to be known as the Gulfstream Model GVIIG500 (project number TC-01-2010-0024). The cabin interior ofthe GVII-G500, and its derivatives, relies on installation ofmid-cabinpocket doors to divide different sections of the passenger cabin areas and provide certain amenities and configuration options that have become the standard for executive class airplanes. Section 25.813(e), at Amendment 25-128, states that no door may be installed between any passenger seatthat is occupiable for takeoffand landing and any passenger emergency exit, suchthat the door crosses any egress path (including aisles, cross-aisles and passageways). In accordance with the provisions of 14 CFR 11.81, Gulfstream requests an exemption to § 25.813(e) for installations ofthese mid-cabin pocket doors. Gulfstream proposes that specific design features ofthe GVII-G500, and its derivatives, and limiting this exemption to those aircraft that are operated as private-use only (aircraft may not be offered for common carriage or operated for hire) will provide an appropriate level of safety. The information provided herein outlines this rationale. Supporting Information Section 25.813(e) restricts the installation ofany interior door between a passenger seat and any emergency exit, effectively restricting the use ofall interior doors. Exemptions, as well as equivalent level ofsafety (ELOS) findings, have been granted by the FAA to the part 25 requirements allowing installation ofmid-cabin doors when the aircraft is limited to private-use only (aircraft may not be offered for common carriage or operated for hire). On June 8, 2009, the FAAreleased Special Federal Aviation Regulation (SFAR) 109, allowing the installation ofinterior doors when the aircraft is prohibited from operations involving the carriage ofpersons orproperty for compensation or hire beyond the remuneration afforded by 14 CFRpart 91, subpartF. Because Gulfstream operators transition betweenprivate-use only and on-demand operations (part 135), Gulfstream is requesting an exemption based on the requirements ofthe applicable sections ofSFAR 109 to allow the installation ofmid-cabin pocket doors whenthe aircraft is limited to private-use only (prohibited from operations involving the carriage ofpersons orproperty for compensation orhire beyond the remuneration afforded by part 91) and locking outthe door for common carriage or ondemand operations (part 135 operations). Forthe GVII-G500 airplane and its derivatives, Gulfstream believes that it is possible to provide a level ofsafety consistent with the intent ofthe part 25 regulations while allowing installation ofcertain interior doors. This will be accomplished by incorporating specific design features that provide an acceptable level ofsafety.

2Factors Supporting the Petition Underprivate-use only, passengers become exceptionally familiar with the operationof interior features and the locations ofthe exits ontheir Gulfstreamproduct. Unlike common carriage or on-demand operations, the crew ofa private-use Gulfstream aircraft has daily contact with theirpassengers. This has a positive influence on communicating safety issues. In addition, dedicated crews normally operateprivate-use aircraft. The combination ofthese factors and the design features listed belowprovide a level ofsafety envisioned by Amendment 25-128. The design features ofthe mid-cabinpocket doors installed on the GVII-G500 and its derivatives will ensure that the passengers' ability to effectively egress the airplane is not diminished perthe following criteria:

• The airplane flight manual supplement (AFMS) will include appropriate limitations to require a preflightpassengerbriefing describing the appropriate functions to be performed by the passengers and the relevant features ofthe airplane to ensure the safety ofthe passengers and crew.

• The airplane will not be offered for common carriage or operated for hire, orhire beyond the remuneration afforded by part 91. The operating limitations section of the AFMS will be revised to prohibit any operations involving the carriage of persons orproperty for compensation orhire.

• A placard stating that, "Operations involving the carriage ofpersons or property for compensation or hire are prohibited, unless the mid-cabin door is locked in an openposition," will be located in the areaofthe airworthiness certificate holder at the entrance to the flight deck.

• Each doorbetween any passenger seat, occupiable for taxi, takeoffand landing, and any emergency exit will have a means to signal to the flight crew, at the flight deck, that the door is in the openposition for taxi, takeoffand landing.

• Appropriate procedures/limitations will be established to ensure that any such door is in the open configuration for taxi, takeoffand landing.

• Each doorbetween any passenger seat and any exit will have dual means to retain it in the open position, each ofwhich is capable ofreacting the inertia loads specified in§ 25.561.

• Doors installed across a longitudinal aisle will translate laterally to open and close, e.g., pocket doors

.
• Each doorbetween any passenger seat and any exit will be frangible in either direction.

3• Each door between any passenger seat and any exit will be operable from either side, and ifa locking mechanism is installed, it will be capable ofbeing unlocked from either side without the use ofspecial tools. The mid-cabin pocket door will be equipped with a locking device to retainthe door in the stowedposition to be used should the aircraftbe offered for hire operations (such as on-demand operations under part 135). This locking device will physically secure the door in a stowed condition using a fastener which requires the use ofa special tool, preventingpassengers from removing the lockout feature and deploying the door. Effect ofthe Exemption on Safety The exemption requested will not adversely affect the level ofsafety provided for the GVII-G500 and any subsequent derivative models. The design ofthe proposed mid-cabin pocket door will ensure the same level ofsafety for cabin egress as is required for any emergency exit and clear egress path. Issue ofPublic Interest Gulfstream Aerospace Corporation designs, develops, manufactures, markets, and services the world's most technologically advanced executive class airplane to an international market. Gulfstream's leadership position in the global executive class airplane is due to the efforts ofits nearly ten thousand employees inthe manufacturing plants, completion centers, and services across North America. The corporation utilizes numerous products, such as avionics and environmental control systems, from scores of suppliers located throughout the United States. Gulfstream competes for newbusiness all overthe world. This exemption will have a direct impact on sales ofthe GVII-G500 and its derivatives

. The placement ofa mid-cabinpocket door is significantto the owner /operator ofthe airplane. The flexibility to partition the airplane into individual rooms, such as private rooms, is paramountto an acceptable interior and is being requested by prospective airplane operators who compare the GVII-G500 and its derivatives with products offoreign airplane manufacturers. The inability to provide such features will ultimately cause a reduction in prospective sales. The manufacture, completion, and support ofGulfstream airplanes aids in the stabilization ofthejob market as well as the growth ofthe American economy, which is in the interest ofthe public. Since customers desire to have these mid-cabin pocket doors, they may optfor an airplane designed to an earlier certification basis, in lieu ofthe GVII-G500 or its derivatives

. This will restrict advancements in safety introduced by Gulfstream with the GVII-G500 and its derivatives, not only inthe areas ofthe cabin safety, butthroughout the airplane. This is counterproductive to both Gulfstream and the FAA's goal of continuous improvement in overall safety. The advancement ofairplane safety is in the interest ofthe public.

4Operation Outside the United States In accordance with 14 CFR 11.81(h), Gulfstream requests that considerationbe givento extending this exemption for operation outside the United States. Gulfstream aircraft are routinely registered and operated outside ofthe United States and projections are the same for the GVII-G500 and its derivatives. Gulfstream believes that limiting this exemptionto use within the United States would put unfair restrictions onthe marketability ofthis aircraft. Waiver ofNotice and Public Procedure In accordance with 14 CFR 11.29 and 14 CFR 11.87, Gulfstream requests that the period for public comment and publication be waived. This exemption is identical to the applicable sections ofSFAR 109 except that it adds a lock-out feature to be utilized should the aircraft be offered for hire operations (such as on-demand operations under part 135). Similar exemptions ofthis nature have been granted numerous times for similar installations. Previously granted exemptions:

• ExemptionNo. 10338A, Embraer S.A

• ExemptionNo

. 10274, Gulfstream Aerospace

• ExemptionNo. 10396, Dassault Aviation Federal Register publication The FAA has determined that good cause exists for waiving the requirement for FederalRegister publication for public comment because the request is identical in all material respects to previously granted exemptions; the exemption, ifgranted, would not set a precedent; and any delay in acting onthis petition would be detrimental to Gulfstream Aerospace Corporation. The FAA's Analysis Gulfstream Aerospace Corporationhas requested an exemption from 14 CFR25.813(e) at Amendment 25-128. Paragraph (e) states: No door may be installed between any passenger seat that is occupiable for takeoffand landing and any passengeremergency exit, suchthat the door crosses any egress path (including aisles, crossaisles and passageways). Cabin interior doors have beenthe subject ofnumerous exemptionrequests. The FAAhas already granted an exemption from§ 25.813(e) for installation ofthe forward vestibule and acoustic doors in the Model GVII-G500 airplane viaExemptionNo. 11610 (DocketNo. FAA2015-0230). With the exception ofthat exemption and the forward vestibule and acoustic doors 5in the Gulfstream Model GVI permitted by Exemption No. 10188 (DocketNo. FAA-2010-0446), all exemptions from§ 25.813(e) at Amendment 25-116 or later have been limited to "private-use, not for hire, not for common carriage." Following accident experience in the 1960's, the FAA amended part 25 to prohibitthe installation ofdoors "betweenpassenger compartments" at Amendment 25-15. Atthe time of the amendment, dividing the first class and tourist class cabins with a solid door was common practice. We determined, in the course ofaccident investigations, that this door could be detrimental in evacuation ofpassengers, who tended not to recognize that there was an exit beyond the door, even ifit were the closest available. We intendedthe resulting regulatory change to preventthis occurrence. However, the regulation was worded such that doors could be installed betweenpassengers and exits, providedthat passengers are not on both sides ofthe door. For example, a door could be installed across the main passenger aisle at the end ofa cabin. The regulations required that the door be open for takeoffand landing. Either through omission or mechanical failure, such a door could becomejammedpriorto the need for an emergency evacuation,preventing ordelaying persons from evacuating, and resulting in fatalities or injuries that would not have occurred ifthe door were notpresent. The hazards associated with ajammed door are still present whether ornot passengers are on both sides ofthe door, and the recognition factor has not been mitigated. Either scenario could result in the same consequences - failure ofsome passengers to evacuate the airplane. Amendment 25-116 increased the level ofsafety overthat ofthe previous version ofthe rule by prohibiting doors between any passenger and any exit. Since raising the level ofsafety with Amendment 25-116, we have not made any ELOS findings for interior doors between passenger compartments on airplanes with a certification basis at that amendment level or later because the presence ofdoors, even with risk-mitigating features, is not equivalently safe to a rule that prohibits the presence ofdoors

. We explained this in the preamble to the final rule of Amendment 25-116 which also considered the adverse effects such doors could have on safety during an emergency evacuation. Title 49 ofthe United States Code (49 U.S.C. 44701(d)) directs the FAAto consider differences between air transportation and other air commerce. This provision establishes the principle that ourregulations should set a higher level ofsafety for air carriers compared to other types of operations whenever appropriate. We followed this principle when we made allowances for interior doors in private-use operations, along with several limitations, to ensure the interior doors do not adversely affect safety. The public demands greater certainty in safe outcomes for fare-paying passengers, so we have not made similar allowances for interior doors in operations otherthanprivate-use. The placement ofinterior doors is quite significantto owners and operators ofprivate-use airplanes. The flexibility to partition the airplane into individual compartments, such as private meeting rooms or bedrooms, is paramount to an acceptable interior. The FAA acknowledges the desirability ofthese features from the private-use operator'spoint ofview. Airplanes configured for private-use, not-for-hire, and not-for-common-carriage typically use any offive different door 6categories in the passenger cabins. This exemption is applicable to any ofthe following categories ofdoor: Category 1: A door in a room and the room is less than the full width ofthe airplane. An aisle is outside the room. This type ofroom may be occupied during takeoffand landing, and only the occupants ofthe room must use the door to reach an exit. Category 2: A door in a room that is the same as Category 1, except a single emergency exit or pair ofemergency exits is within the room. Category 3: A door, or doors, in a room and the room is the full width ofthe airplane. Passengers are seated on both sides (fore and aft) ofthe door(s), and the main aisle leads out of, orpasses through, the room. The room does not have emergency exits. This type ofroom may be occupied during takeoffand landing. Category 4: A door in a room and the room is the full width ofthe airplane. Passengers are seated on both sides (fore and aft) ofthe door, and a pair ofemergency exits is at one end ofthe room. This type ofroom may be occupied during takeoffand landing. Category 5: A door in a room that may be the full width ofthe airplane. This type ofroom is not occupied during takeoffand landing

. This room is only occupied during flight. Passengers are not seated on both sides ofthe door during taxi, takeoff , and landing. Passengers seated in taxi, takeoff , and landing seats must not need to pass through this door to get to any emergency exits. Because not all interior doors between passenger compartments are equivalent, the FAA imposes different limitations on the different categories appropriate to produce an adequate level ofsafety for private-use operations. To ensure the appropriate level ofsafety, doors in Category 2, 3, or 4, installed across the main cabin aisle, must open and close in a transverse direction. That is, the direction ofmotion ofthe door must be at a right angle to the longitudinal axis ofthe airplane. A "pocket door" is one example ofsuch a design. This minimizes the chance that the inertia forces ofan accident could force the door closed. Each interior door must have an emergency passage feature (EPF) to allowpassage ofthe occupants orrescue personnel ifthe door becomesjammedin the closed position in flight or during taxi, takeoff, or landing. This EPF may be through frangibility ora removable emergency panel or equivalent. The EPF is intended to ensure that ifa door isjammedclosed, occupants can escape in either direction and emergency equipment can be moved. The EPF may be demonstrated in either ofthe following ways:

• A 5th_percentile female can break through the door, creating a large enough opening that a 95 1h-percentile (or larger) male canpass through. See Advisory 7Circular 25-17A, Transport Airplane Cabin Interiors Crashworthiness Handbook, paragraph43b(2). • A 5th-percentile female canbreak a hinge onthe door or a hinge on a smaller door within the door such that the door can swing, so as to allow a 95 1h-percentile (or larger) male to pass through the opening with the door swung open. This evaluation mustbe made with any cabin furnishing or equipment installed that could limit the swing arc ofthe door and placed in the most adverse position. In using this approach, one must considerthe possibility that the door is physically jammed in the closed position by distortion ofthe fuselage or furnishings. This possibility must be considered even ifthe door normally translates into the open and closedpositions. With eithermethod, the 51h-percentile female test subject should be subjected to a typical preflight briefing and then may only use the information on the placard for determining how to operate the EPF. The demonstration should be conducted with representative cabin furnishings and equipment that could limit the door opening. The applicant must then showthat a 95th

_ percentile male subject can exit through the EPF opening created by the 5th_percentile female test subject. Any door in a room that is occupiable for takeoffand landing must have redundant means to latch doors open for takeoffand landing. Each latching device must have the capability of retaining the door in the takeoffand landing position under the inertia forces of§ 25.561. Any door in a room that contains one or more emergency exits orthat crosses the main aisle (Category 2, 3 or4) must be in the open position during taxi, takeoffand landing, regardless of whether occupants are in the room. Other doors (Category 1) must be open during taxi, takeoff and landing only ifoccupants are in the room. Doors in rooms not occupiable for takeoffand landing (Category 5) should be closed during takeoffand landing to minimize the possibility that passengers will become disoriented and enter the room looking for an exit during an emergency. With respect to the possibility that a doorremains closed when it should not, we determined that a higher level ofawareness is required to address this issue. Inspection by flight attendants prior to takeoffand landing is not sufficient to verify that interior doors are in a required openposition. Therefore, some type ofremote indication is necessary. We accept the petitioner's proposal to provide a means to signal the flightcrew that these doors are in the openposition during taxi, takeoff, and landing for doors that fall into Categories 1, 2, 3, and 4. Doors in Category 5 do not need to comply with this requirement. For Category 5 doors, placards located on ornear the door that indicate that the door must be closed for taxi, takeoff, and landing are acceptable. Gulfstream requested the exemption also be applicable to "derivatives" ofthe Model GVII-G500 airplane. This exemption applies to Gulfstream Model GVII-G500 airplanes. Should Gulfstream apply later for a change to the type certificate to include another model incorporating the same or similar design feature, this exemption would apply to that model as well.

8The FAA considers that granting this petition is in the public interest for the reasons stated by the petitioner and because the FAA is directed to take into account the type ofoperation when establishing standards under Title 49 ofthe United States Code (49 U.S.C. 44701(d))

. The F

### AA's decision In consideration ofthe foregoing, I find that a grant ofexemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701 delegated to me by the Administrator, I grant Gulfstream Aerospace Corporation an exemption from 14 CFR25.813(e). The exemption is granted to the extent necessary to allowthe installation of mid-cabin interior doors on Gulfstream Model GVII-G500 airplanes operated for private-use (not for hire, not for common carriage). This exemption is subjectto the following conditions and limitations. Items 1, 2, 5, 6, and 7 below must be documented as operating limitations in the limitations section ofthe AFM. 1. Except as noted in item 2, the airplane must not be operated for hire or offered for common carriage. This provision does not preclude the operator from receiving remuneration to the extent consistent with 14 CFRparts 125 and 91, subpart F, as applicable. 2. In order for the airplane to be operated in part 135 service, the mid-cabin door must be secured in an open (stowed) condition using a fastener whichrequires the use ofa tool and a maintenance action to release it. 3. Doors betweenpassenger compartments must have a dual means to retain them in the open position. Each means must be capable ofwithstanding the inertia loads specified in § 25.561. Doors in Category 5 do not need to comply with this requirement because they are required to be closed for taxi, takeoff, and landing. 4. The doors must be placarded to be open and latched for taxi, takeoff, and landing. 5. Doors that fall into Category 1must be in the open position during taxi, takeoff , and landing, ifoccupied. 6. Doors that fall into Categories 2, 3, or 4 must be in the open position during taxi, takeoff, and landing, regardless ofoccupancy ofthe room. 7. Doors that fall into Category 5 mustbe in the closed position during taxi, takeoff, and landing. 8. A means to alert the flightcrew that an interior door is not in the properly open (stowed) position for taxi, takeoff, and landing must be installed.
99. Appropriate procedures mustbe established to prohibit taxi, takeoff , and landing in the event a door between any passenger seat, which is occupiable for takeoffand landing, and any passenger emergency exit is not in the properposition. Doors in Category 5 do not need to comply with this requirement. For Category 5 doors,placards located on or near the door that indicate the door must be closed (deployed) for taxi,takeoff , and landing is acceptable. 10. The doors must have an emergency passage feature (EPF) to allowpassage ofthe occupants or rescue personnel ifthe doorbecomesjammed

. The EPF must be easily broken or removed by the occupant when the door isjammed and a placard must be installed on each side ofthe doorproviding instruction on the operation ofthe EPF. The applicant must demonstrate a 5th-percentile female can breakthrough or remove the EPF from both sides ofthe door and that a 95th-percentile male subject can exit through the EPF opening. 11. Doors in Categories 2, 3, or 4 installed across the main aisle must translate laterally to open and close.

Issued in Renton, Washington, on 

## JUL 2 92016 

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Victor Wicklund Acting Manager, Transport Airplane Directorate Aircraft Certification Service

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