UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

Exemption No. 13504 

Gulfstream Aerospace Corporation Regulatory Docket No. FAA-2015-3595 

for an exemption from§ 25.809(a) of 

Title 14, Code ofFederal Regulations 

GRANT OF EXEMPTION 

By letter dated August 14,2015, Mr. Robert Glasscock, Director ofODA Programs, Gulfstream 

Aerospace Corporation, PO Box 2206, Savannah, Georgia, 31402-2206, petitioned the Federal 

Aviation Administration (FAA) for an exemption from the requirements of§ 25.809(a) of 

Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted, would permit relief 

from the requirement to provide a means of viewing the likely areas of evacuee ground contact 

prior to opening the door for the overwing emergency exits on Gulfstream GVII-G500 airplanes. 

The petitioner requests relief from the following regulation: 

Section 25.809(a), at Amendment 25-116, requires, in pertinent part, that each 

emergency exit be provided with a means to permit viewing of the likely areas of evacuee 

ground contact prior to opening the exit. 

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 of Transportation's Federal Docket 

Management System, on the Internet at http://regulations.gov, in Docket No. F AA-2015-3595. 

Background 

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 GVIIG500. 
Title 14 CFR 25.809(a), Amendment 25-116, states that each emergency exit, including 

each flightcrew emergency exit, must be a moveable door or hatch in the external walls of 

the fuselage, allowing an unobstructed opening to the outside. In addition, each 

emergency exit must have means to permit viewing of the conditions outside the exit 

when the exit is closed. The viewing means may be on or adjacent to the exit, provided 

no obstructions exist between the exit and the viewing means. Means must also be 

provided to permit viewing of the likely areas of evacuee ground contact. The likely 

areas of evacuee ground contact must be viewable during all lighting conditions with the 

landing gear extended as well as in all conditions of landing gear collapse. 

The GVII-G500 emergency exit configuration consists of the Type I Main Entry Door, 

along with two pairs of overwing emergency exits which will be demonstrated to provide 

equivalent or better egress flow rate as a single Type III overwing exit. These overwing 

emergency exits are identical in size and shape to those certified on the GVI. The GVIIG500 will have a maximum seating capacity of 19 passengers and the overwing exits are 

centrally located in the passenger cabin. The exits house large oval windows which 

provide a full panoramic view of the wing surface as well as the ground area just beyond 

the point of occupant first contact. 

Partial relief is being sought for the GVII-G500 and its derivatives, from the requirements 

of§ 25.809(a) for the overwing exits since this outside viewing means does not permit 

viewing of the likely area of the evacuee ground contact prior to exit opening. Relief is 

necessary since literal compliance with the rule would, at a minimum, require extensive 

design changes to the airplane (such as movement of the exits forward or complete 

redesign of the exit configuration) to provide the view of the exact ground location as 

currently prescribed. Furthermore, due to the height ofthe wing versus the height of the 

doors, a truly compliant configuration may ultimately not be physically obtainable. 

Supportive Information 

Notice of Proposed Rulemaking (Notice No. 96-9) was published in the Federal Register 

on July 24, 1996 (61 FR 38552). The notice proposed to upgrade several cabin safety 

requirements including outside viewing means. The FAA's response to the commenters 

was that the impact of§ 25.809(a) went beyond what was envisioned in the rulemaking 

process for the overwing exits on some airplanes. 

The intent of the requirement was to enable a person to ascertain whether to open an exit, 

and whether it was safe to evacuate through the exit, based on the assessment of the 

outside conditions. To the extent that the means used for the determination ofthe former 

did not also allow an assessment of the ground, it was agreed that an additional viewing 

means might be necessary, and that the additional means might be somewhat remote from 

the exit. Therefore, the amendment was reworded to allow for dual purpose of the 

viewing means, and to distinguish the required locations of the two. The intent of the rule 

was that it was not necessary for a person to be able to view the ground-contact point 

while in position to open an overwing exit. The rule itself refers to the ground-contact 

view separately from the view of conditions outside the exit, but the intent of the rule was 

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not clearly expressed in the rule language. The European Aviation Safety Agency 

(EASA) incorporated the improved language in their certification specification (CS) at 

Amendment 25/12, dated July 13, 2012. CS 25.809(a)(3) states, "For non-over-wing 

passenger emergency exits, a means must also be provided to permit viewing of the likely 

areas of evacuee ground contact when the exit is closed with the landing gears extended 

or in any condition of collapse. Furthermore, the likely areas of evacuee ground contact 

must be viewable with the exit closed during all ambient lighting conditions when all 

landing gears are extended." 

Factors Supporting the Petition 

Based on the design and location of the elliptical windows, Gulfstream believes that the 

ability to perform a fully effective visual assessment of outside aircraft conditions and 

evacuation route with the overwing exits closed is provided. The arrangement of the 

large elliptical windows at the overwing exits provides a field of view of approximately 

140°. A view of the full surface of the wing as well as the ground area surrounding the 

wing, including areas just feet from the location of likely occupant ground contact is 

provided. With this large panoramic view, an occupant can directly see the wing surface 

to ensure no hazards are present but will also be provided a view of enough of the ground 

area to make a logical assessment as to the conditions at the point of contact prior to 

opening the exit. 

Once the evacuee steps onto the surface of the wing, they will be then able to follow the 

appropriate escape route and view the ground where they would likely make contact to 

confirm no hazards exist. Evacuees will be capable of viewing the escape route and 

ground during all lighting conditions. The exterior egress lighting is integral to the 

emergency lighting system. 

Effect of the Exemption on Safety 

Granting this exemption would not affect safety because: 

1. The proposed configuration provides a level of safety consistent with the intent of 

the rule and provides an effective means to assess outside conditions prior to 

opening overwing exits. The GVII-0500 model aircraft design is consistent with 

industry present state-of-the-art and design practice. 

2. The GVII-0500 and its derivatives will comply with anticipated future 

harmonized requirements as written in the EASA CRD to NPA 2010-11 and now 

incorporated in EASA CS 25.809(a) at Arndt. 12. 

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 

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due to the efforts of its nearly 10,000 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 throughout the United States. Gulfstream competes for new business all over the 

world. Granting this exemption would benefit the public as a whole, because it: 

1. Minimizes significant cost impacts and avoids investing time and efforts to 

develop a design that would meet some aspects of the present regulation which 

will be changed in the future. 

2. Allows the Gulfstream GVII-G500 model designs to meet EASA and FAA 

anticipated future harmonized regulation preventing competitive disadvantage due 

to additional design/manufacturing complexity and increased weight. 

Operation Outside the United States 

The EASA certification standard 25.809(a) is not currently harmonized with 

14 CFR 25.809(a). 

Regardless ofEASA 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 GVII-G500. Granting this extension of 

privileges will allow for operations based within foreign 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 US would put unfair restrictions on the marketability of this aircraft. 

Federal Register publication 

The FAA has determined that good cause exists for waiving the requirement for Federal Register 

publication for public comment because the request is identical in all material respects to 

previously granted exemptions; the exemption, if granted, would not set a precedent; and any 

delay in acting on this petition would be detrimental to Gulfstream Aerospace Corporation. 

The FAA's Analysis 

The FAA has reviewed the information provided by Gulfstream Aerospace Corporation and has 

concluded that granting this exemption is in the public interest for the reasons stated by the 

applicant and the reasons discussed below. The FAA has determined that there is no adverse 

impact on safety if an occupant cannot simultaneously see conditions immediately outside the 

overwing emergency exit door and the ground-contact point. As stated by the petitioner, the 

impact of the regulation, as codified, went beyond what was envisioned in the rulemaking 

process for the overwing exits on some airplanes. 

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On many overwing exits, the location where the evacuee makes first contact on the ground is a 

considerable distance from the point from which they exit the passenger cabin. The distance the 

evacuee moves either forward or aft on the wing upper surface, and then down to the ground 

either by escape slide, or by jumping off of the wing, or sliding down the leading or trailing edge 

of the wing, makes it impossible to see the ground contact point from inside the airplane because 

of the distance or the wing itself blocking the view. Some commenters to the Notice of Proposed 

Rulemaking (Notice No. 96-9) made this point, and the FAA response was: 

With respect to the potential for the exit to be somewhat remote from the point where the 

evacuees would contact the ground, the FAA agrees that this may be the case. The intent 

of the requirement is to enable a person to ascertain whether to open an exit, and whether 

it is safe to evacuate through the exit, based on an assessment of the outside conditions. 

To the extent that the means used for determination of the former does not also allow an 

assessment of the ground, the FAA agrees that an additional viewing means may be 

necessary, and that the additional means may be somewhat remote from the exit. We 

have therefore reworded the amendment to allow for the dual purpose of the viewing 

means, and to distinguish the required locations of the two. 

Our intent in this rule was that it is not necessary for a person to be able to view the ground 

contact point while in position to open an overwing exit. The rule itself refers to the groundcontact view separately from the view of conditions outside the exit, but the intent of the rule was 

not clearly expressed in the rule language. The FAA worked with the European Aviation Safety 

Agency (EASA) to improve the rule language based on our experience applying this rule. EASA 

incorporated the improved language in their Certification Specifications (CS) at amendment 

25/12, dated July 13, 2012. CS 25.809(a)(3) states: 

For non-over-wing passenger emergency exits, a means must also be provided to permit 

viewing of the likely areas of evacuee ground contact when the exit is closed with the 

landing gears extended or in any condition of collapse. Furthermore, the likely areas of 

evacuee ground contact must be viewable with the exit closed during all ambient lighting 

conditions when all landing gears are extended. 

The FAA is considering rulemaking to harmonize this requirement with EASA. 

The proposed configuration provides a level of safety consistent with the intent of the rule. The 

petition proposes that the large elliptical window allows for outside viewing to assess the outside 

conditions prior to opening the exit. The evacuee can then open the exit and step out onto the 

wing and move along the wing to assess the conditions where they would make first contact to 

the ground. At that point, if the conditions were not acceptable, evacuees would search for 

another location from which to exit off of the wing. To enforce literal compliance that is more 

stringent than our original intent for the rule would result in an unnecessary burden on the 

petitioner. 

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The FAA's decision 

In consideration of the foregoing, I find that a grant of exemption 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 CFR 25.809(a) at Amendment 25-116. The exemption is granted to the extent necessary to 

allow Gulfstream Aerospace Corporation to partially comply with the outside-viewing 

requirements for the overwing emergency exits on Model GVII-G500 airplanes. Specifically, the 

exemption provides relief from the requirement that overwing exits permit viewing of the likely 

areas of evacuee ground contact when the exits are closed. This exemption allows viewing the 

first point of contact with the ground after the overwing exit has been opened and the evacuee is 

on the upper surface of the wing on Gulfstream Model GVII-0500 airplanes. Gulfstream must 

demonstrate compliance with all other requirements of§ 25.809(a) at Amendment 25-116 for 

this airplane. 

Issued in Renton, Washington, on NOV 0 5 2015 

Dionne Palermo 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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