Gulfstream 

A GENERAL DYNAMICS COMPANY 

In reply, reference letter number: G-ODA-13-656 

US Department of Transportation 

Docket Management Facility I Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

G-ODA-13-656 

September 05, 2013 

Subject: New Petition for FAA Exemption for Installation of Doors Between Passenger 

Seats and an Emergency Exit in the Gulfstream Aerospace LP model Gulfstream 

G280 Airplanes (14 CFR § 25.813(e) Arndt 25-116- Emergency Exit Access). 

Dear Ms. Sirs/Madame: 

In accordance with Title 14 CFR Part 11.63, Gulfstream Aerospace Corporation requests 

consideration of the enclosed petition for exemption. The petition is being submitted, on behalf 

of Gulfstream Aerospace Corporation, to relieve the Gulfstream model Gulfstream G280 aircraft 

from full compliance with 14 CFR § 25.813(e) Arndt. 25-116, Emergency exit access, to extend 

the allowance of an interior door between an exit and passenger seats during certain flight 

portions of 14 CFR part 91 and part 135 operations. 

If we may be of further assistance concerning this matter, contact Mitchell Cannon at (214) 902-

7787 (via email at mitchell.cannon@gulfstream.com) or the undersigned. 

Respectfully, 

tn-AJtu 

Mitchell Cannon 

~ 

ODA Site Program Administrator 

Gulfstream Aerospace Corporation 

HangarA/8, Level2 

7440 Aviation Place 

Dallas, TX 75235 

mitchell.cannon@gulfstream.com 

Telephone (214) 902-7787 or (912) 401-1145 

FAX- 214-357-2839. 

500 Gulfstream Drive • Savannah, GA 31408 • Telephone (912) 965-3000 • Gulfstream.com 
Enclosure to G-ODA-13-656 

September 05, 2013 

Page 1 of 7 

Relieffrom Title 14 CFR Part 25.813(e) Arndt. 25-116 

Gulfstream Aerospace Corporation 

Petition for Exemption 

Gulfstream G280 - Interior Door 

Gulfstream Aerospace Corporation (GAC) and Gulfstream Aerospace LP (GALP) have 

developed and type certified a new derivative model Gulfstream G280 airplane. The model 

Gulfstream G280 is FAA approved under Type Certificate A61 NM. This new airplane model 

was certified to 14 CFR Part 25, Amendments 25-1 through 25-120, and 122 in its entirety, 

which includes certification to the requirements of §25.813(e) at Amendment 25-116. A partial 

grant of exemption was granted by the FAA (reference exemption No. 10274 identified on 

TCDS) which allows installation of doors between passenger seats and emergency exits. This 

exemption is limited for use on private, not-for-hire, not-for-common-carriage operations. The 

exemption requires a lock-out procedure (via maintenance action) if the aircraft is to be 

operated under 14 CFR Part 135 regulations. GAC is submitting a new petition for exemption 

under the G280 Cabin Multiple STC ST04266AT-D. Gulfstream ODA STC Amendment project 

number SA-02-2013-0051 has been assigned to this effort. This petition will present newly 

proposed cabin and door compensating features, which GAC believes will address FAA 

concerns regarding applicability of the original partial exemption to aircraft operated under 14 

CFR part 135. GAC petitions the exemption be applicable to aircraft operated under 14 CFR 

part 135 and not be limited to private use operation. 

Background 

The model Gulfstream G280 airplane is equipped with multiple-passenger interior arrangements 

that include an interior door between passenger seats and emergency exits (see Figures 1 - 3 

for floorplans and exiUegress arrangement). All cabin interior configurations are less than 26 

feet in length and a with of approximately 7 feet. The G280 is most often used for executive air 

transportation under Parts 91 and 135 of the Federal Aviation Regulations. Due to the nature of 

the transportation involved many operators request the installation of privacy cabin doors when 

outfitting of the aircraft is accomplished. 

Title 14 Code of Federal Regulations (14 CFR) section 25.813(e), at Amendment 25-

116, states: "No door may be installed between any passenger seat that is occupiable for 

takeoff and landing and any passenger emergency exit, such that the door crosses any 

egress path (including aisles, cross aisles and passageways)". 

According to the FAA, section 25.813(e) exists to ensure that passengers do not become 

isolated in a passenger compartment during an emergency. The intended means of ensuring 

this is the prohibition against doors between passenger seats and emergency exits. However, 

an exemption to this rule has been granted by the FAA for the G280. The exemption was based 

on the fact that the G280 cabin interiors provide sufficient compensating features which ensured 

an acceptable level of safety as required by the rule. This exemption is limited to airplanes 

operated for private use not for hire not for common carriage, and requires that the door 

remains latched open during taxi, takeoff and landing. In addition, the door must be "frangible" 

in nature in order to allow for passenger egress during an emergency. The compensating 

features included in the G280 cabin interiors, which supported the original grant of exemption by 

the FAA, mainly are: 
Enclosure to G-ODA-13-656 Gulfstream Aerospace Corporation 

September 05, 2013 Petition for Exemption 

Page 2 of 7 Gulfstream G280 - Interior Door 

1. The door is of a sliding type and retracts laterally into a pocket compartment located aft 

of the Fwd RH galley assembly. The door does not divide the passenger compartment 

and, the occupants will always have direct access to the RH Aft overwing emergency 

exit (Type Ill). 

2. The door is frangible in both directions and has been tested to demonstrate a 51

h 

percentile female can easily swing the door open in case of an emergency, and the 

resulting aperture is large enough to allow for a 95th percentile male to escape. 

3. The door is placarded to be latched open during taxi, take-off, and landing. 

4. The door design includes dual internal latching mechanisms, which is capable of 

withstanding the inertia loads specified in 14 CFR § 25.561. 

5. The door features a "quarter turn" positive manual latch which virtually prevents the door 

from deploying into the aisle when the lock is engaged. This lock is in addition to the 

dual internal latch noted in Item 4 above, and can react static loads per 14 CFR § 

25.561. 

6. Bulkhead divider type emergency exit sign(s) are installed to ensure that the level of 

passenger guidance required to find an exit is provided. 

Pocket Door 

(Deployed Position - Non TT&L) 

Main £ntry 

(Emecgency EXIT) 

(Pox Seats # 1 through #8 

ore Approved for TT &L 

Figure 1 - Model G280 - 8 Passenger Cabin Interior Configuration 

Non- TT&l 

Toilet 
Enclosure to G-ODA-13-656 

September 05, 2013 

Page 3 of 7 

Pocket Door 

(Deployed Position - Non TT&L) 

Main Entry 

(Emergency EXIT) 

Gulfstream Aerospace Corporation 

Petition for Exemption 

Gulfstream G280 - Interior Door 

(Pox Seats # 1 through #9 

ore Approved for TT&L 

Non-TT&l 

Toilet 

Figure 2 - Model G280 - 9 Passenger Cabin Interior Configuration 

Pocket Door 

Main Entry 

(Emergency EXIT) 

(Pox Seats #1 through #10 

ore Approved for TT&L 

Figure 3 - Model G280 - 10 Passenger Cabin Interior Configuration 

Non-TT&L 

Toilet 
Enclosure to G-ODA-13-656 

September 05, 2013 

Page 4 of? 

Gulfstream Aerospace Corporation 

Petition for Exemption 

Gulfstream G280 - Interior Door 

Proposed Additional Compensating Features for Part 135 Operations 

FAA's position regarding doors that cross an egress path has been that the operation of the 

aircraft be limited to private use not for hire not for common carriage. However, there is 

precedence that the FAA has found acceptable to install doors between TT&L approved 

passenger seats and emergency exits in aircraft operated under Part 135 regulations (reference 

FAA Exemption No. 1 0188). Therefore, GAC is requesting a new exemption for the Model 

Gulfstream G280 pocket door installation, which would allow the use of the pocket door under 

14 CFR Part 135 regulations. GAC is of the opinion that in addition to the door design features 

listed above, other provisions can be made to the pocket door and cabin interior to address 

FAA's concerns regarding applicability of the exemption to aircraft operated under Part 135. 

The proposed additional provisions would be the basis for the new request and will include the 

following: 

a. The pocket door will be fitted with an electric actuator which automatically stows and 

locks the door in the TT&L position. In addition, there will be a switch in the cockpit 

which will allow the crew to retract the pocket door to the TT&L at their discretion 

b. The pocket door will always automatically stow and lock in the TT&L position any time 

the landing gear is deployed or the flaps are not fully retracted. The door will always 

remain open until the landing gear and flaps are both fully retracted. The pocket door 

deployment mechanism and actuator will be highly reliable and GAC will substantiate 

that the probability of failure to egress through the MED, including the probability of 

failure on the pocket door, will be less than 1 o-s per flight hours. This hazard criticality is 

based on 14CFR Part 25.783(b)(2). 

c. The electric actuator will normally be operated via power from the main cabin electric 

bus, and will use battery power as back-up during a main cabin power loss 

d. The door will be designed so that for any failure of the deploying mechanism, the door 

will default to the stowed/locked position. 

e. Manual operation will be the primary means by which the door is open and stowed in the 

TTL position. The automatic opening feature will ensure clear egress path in the event 

that manual stowing of the door has not occurred. 

f. A warning light/chime in the cockpit will alert the crew if the pocket door is not in the 

properly stowed position for TT&L. 

g. GAC would propose developing a step-by-step procedure to educate passengers on the 

pocket door emergency operation in the improbable event where the door has deployed 

during an emergency landing. Passenger instruction on the pocket door emergency 

operation will be achieved by requesting the crew (via the Aircraft Flight Manual 

Supplement, AFMS) to perform a pre-flight de-briefing regarding the Model G280 pocket 

door emergency procedures. These procedures would be coordinated and approved by 

the FAA. 

h. Close proximity of the G280 pocket door installation to the cockpit area easily allows the 

crew to visually verify position of the pocket door prior to taxiing, take-off and landing 

(reference Figure 4). 

i. The Model G280 cabin interior STC ST04266AT-D is certified to a maximum passenger 

occupancy of 10, which is very small as compared to most transport airplanes operated 

under Part 135 rules. As a result passenger awareness of both exits and the ability to 

quickly egress is greatly enhanced as compared to larger Part 135 aircraft. 

j. Passengers are inherently aware of the main entry door/exit location relative to the cabin 

area because they entered the aircraft via the main entry door/exit. 
Enclosure to G-ODA-13-656 

September 05, 2013 

Page 5 of 7 

Gulfstream Aerospace Corporation 

Petition for Exemption 

Gulfstream G280 -Interior Door 

Figure 4 - Pocket Door Latched/Stowed Condition 

Effect of the Exemption on Safety 

Acceptance of the proposed Gulfstream G280 design will ensure that a level of safety consistent 

with the intent of the regulation has been provided. The design and reliability of the proposed 

interior door and door mechanisms will ensure the same level of safety for cabin egress as is 

required for any emergency exit and will provide a clear egress path. Generally, passengers of 

chartered executive jet are likely to be more familiar with the exits, exit/egress operations and 

exit locations compared to passengers of larger scheduled aircraft. Additionally, the RH 

overwing Type Ill emergency exit opening is larger than required by the regulations. The 

emergency exit opening is 21.2 inches wide, 38.75 inches high with 4 inch corner radii; 

providing an exit opening area of 807.7 square inches. For the 10 passenger configuration, the 

emergency exit opening area is over 19% larger than the Type Ill exit size requirement per 14 

CFR § 25.807(a)(3). For the more common 8 and 9 passenger configurations, the exit opening 

area is 74% larger than the Type IV exit opening size per 14 CFR § 25.807(a)(4). The 

emergency exit opening is taller, wider and is substantially larger than the requirements. The 8 

and 9 passenger configurations are selected at a much higher rate than the 10 passenger 

configuration. And, if selected, the 10 passenger configuration is not likely to be filled with 

passengers for long durations. As the subject Cabin Interior STC (ST04266AT-D) has a 
Enclosure to G-ODA-13-656 

September 05, 2013 

Page 6 of 7 

Gulfstream Aerospace Corporation 

Petition for Exemption 

Gulfstream G280 - Interior Door 

maximum passenger configuration of 10 passengers, the 10 passenger configuration is at the 

very bottom of the scale for Type Ill exit door requirements as defined by 14 CFR § 25.807(g}, 

which is 10 to 19 passenger seats, providing margin as compared to the potentially higher 

passenger seat counts. This, combined with other characteristics of the G280 completed interior 

configurations, such as lower passenger seat counts (8, 9 and 10 passenger configurations), 

close proximity of passenger seat position to the emergency exit, no center row seating 

configurations, and the overwing emergency exit opening size (Type Ill) will provide a level of 

safety equal to or 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 G280 raises the 

current level of safety to that envisioned by Amendment 25-116 to part 25. 

Issue of Public Interest: 

Collectively, GAC and GALP 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 ten thousand employees in the manufacturing plants, completion centers, and service 

centers across North America and worldwide. GAC installs the executive interiors for the Model 

G280 airplanes that are operated worldwide. The owners of business jet aircraft very often 

prefer a configuration that includes compartment doors, which reduce cabin ambient noise and 

provide for privacy or a comfortable rest area when needed. 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 G280 with products of European manufacturer 

and other foreign aircraft completion centers. The inability to provide such features will 

ultimately cause a reduction in perspective sales. The 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. 

The importance of business aviation to the well-being of the United States economy cannot be 

overstated. Business aviation enables a company to maximize its two most important assets, 

time, and people. A business aircraft reduces not only flight time but total business travel time, 

allowing a higher degree of productivity through greater point-to-point service and the ability to 

better utilize the existing national airport network, in essence bringing the business closer to its 

intended customer. The office-like environment that exists on board the business aircraft allows 

the travel time of busy executives to be a more productive time. 

Although the current world economy has slowed in comparison to previous years, the corporate 

aircraft market has shown some positive growth and is expected to continue to grow. Therefore, 

the demand for these corporate aircraft and the benefits they present to business makes it 

essential that the petitioner be granted the regulatory relief requested. Failure to achieve this 

goal will result in a significant loss of income, both in domestic and foreign trade for the United 

States, the petitioner, and the intended business operators of these aircraft. The stabilizing 

effect that manufacture and support of corporate aircraft has on the job market is significant and 

definitely in the public interest. 
Enclosure to G-ODA-13-656 

September 05, 2013 

Page 7 of? 

Gulfstream Aerospace Corporation 

Petition for Exemption 

Gulfstream G280- Interior Door 

Since customers desire to have these interior doors, they may opt for aircraft designed to an 

earlier certification basis, in lieu of the model Gulfstream G280 airplane. This will restrict 

advancements in safety introduced by Gulfstream with the G280, 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. 

Waiver of Notice and Public Procedure 

Gulfstream respectfully requests that action on this petition should not be delayed by publication 

of a summary of our petition and associated comment period. We believe that the nature of this 

exemption does not set a precedent. The relief requested herein is effectively identical to 

exemptions previously granted on the Gulfstream model GVI, and delay of granting this 

exemption will unnecessarily delay final certification of the Amendment on the model Gulfstream 

G280 Cabin Interior STC. 

Operations Outside of the United States: 

The European Aviation Safety Administration (EASA) Certification Specification (CS) 25.813 is 

not currently harmonized with § 25.813 and does not restrict these types of door installations. 

Regardless of EASA requirements, in accordance with 14 CFR § 11.81 (h), GAC petitions 

consideration be given to extending this exemption for operation outside of the United States. 

GAC/GALP aircraft are routinely registered and operated outside of the United States and 

projections are the same for the model Gulfstream G280 airplane. Granting this extension of 

privileges will allow for operations based within foreign countries, including European Union 

member countries, having bilateral agreements with the United States accepting FAA 14 CFR 

Part 25 as equivalent to their airworthiness standards for transport category aircraft. GAC 

believes that limiting this exemption to use within the U.S. would put unfair restrictions on the 

marketability of the model Gulfstream G280 airplane. 

Conclusion: 

GAC believes the additional pocket door features, cabin/fuselage features and the 

aforementioned arguments support extending a new 14 CFR § 25.813(e) pocket door 

exemption to G280 aircraft for operations under Part 91 or Part 135. GAC further believes that 

the proposed exemption is in the public interest, and provides a level of occupant safety 

consistent with the current Federal Aviation Regulations.