# Gulfstream

A GENERAL DYNAMICS COMPANY



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

US Department ofTransportation Docket Management Facility 

### I Docket Operations West Building Ground Floor, Room W12-140 1200 New JerseyAvenue, 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 ExitAccess).

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.

Ifwe may be offurther assistance concerning this matter, contact Mitchell Cannon at (214) 902- 7787 (via email at mitchell.cannon@gulfstream.com) orthe 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 GulfstreamDrive • Savannah, GA 31408 • Telephone (912) 965-3000 • Gulfstream.comEnclosure to G-ODA-13-656 September 05, 2013 Page 1of7

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 underType 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 grantofexemption was granted by the FAA (reference exemption No. 10274 identified on TCDS) which allows installation ofdoors between passengerseats 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) ifthe aircraft is to be operated under 14 CFR Part 135 regulations. GAC is submitting a new petition for exemption underthe G280 Cabin Multiple STC ST04266AT-D. Gulfstream ODA STC Amendment project numberSA-02-2013-0051 has been assigned to this effort. This petition will present newly proposed cabin and doorcompensating features, which GAC believes will address FAA
concerns regarding applicability ofthe original partial exemption to aircraft operated under 14 CFR part 135. GAC petitionsthe 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 interiordoor between passengerseats and emergency exits (see Figures 1 - 3 forfloorplans and exiUegress arrangement). All cabin interior configurations are lessthan 26 feet in length and a with ofapproximately 7feet. The G280 is most often used for executive air transportation under Parts 91 and 135 ofthe Federal Aviation Regulations. Due to the nature of the transportation involved many operators request the installation ofprivacy cabin doorswhen outfitting ofthe aircraft is accomplished.

Title 14 Code of Federal Regulations (14 CFR) section 25.813(e), atAmendment 25- 116, states: "No doormaybe installedbetween anypassengerseatthatis occupiable for takeoffandlanding and anypassengeremergency exit, such that the doorcrosses any egresspath (including aisles, cross aisles andpassageways)".
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 forthe 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 grantofexemption by the FAA, mainly are:

### Enclosure to G-ODA-13-656 Gulfstream Aerospace Corporation September 05, 2013 Petition for Exemption Page 2 of7 Gulfstream G280

- Interior Door
1. The door is ofa sliding type and retracts laterally into a pocket compartment located aft ofthe 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 51h 

### percentile female can easily swing the dooropen in case ofan 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 doordesign includes dual internal latching mechanisms, which is capable of withstanding the inertia loads specified in 14 CFR 

### § 25.561. 5. The doorfeatures a "quarterturn" 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 dividertype emergency exit sign(s) are installed to ensure thatthe 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 ToiletEnclosure to G-ODA-13-656 September 05, 2013 Page 3 of7

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 InteriorConfiguration Non-TT&L ToiletEnclosure to G-ODA-13-656 September 05, 2013 Page 4 of? GulfstreamAerospace 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 thatthe operation ofthe aircraft be limited to private use notfor hire notfor common carriage. However, there is precedence thatthe FAA hasfound acceptable to install doors between TT&L approved passengerseats and emergency exits in aircraft operated under Part 135 regulations (reference FAA Exemption No. 10188). Therefore, GAC is requesting a new exemption forthe Model Gulfstream G280 pocket door installation, which would allowthe use ofthe pocketdoor under 14 CFR Part 135 regulations. GAC is ofthe opinion that in addition to the doordesign features listed above, other provisions can be madeto the pocket doorand cabin interiorto address FAA's concerns regarding applicability ofthe exemption to aircraft operated under Part 135. The proposed additional provisions would be the basis forthe new request and will include the following:

a. The pocketdoorwill be fitted with an electric actuatorwhich automatically stows and locksthe door in the TT&L position. In addition, therewill be a switch in the cockpit which will allowthe crewto retract the pocket doorto the TT&L attheir discretion b. The pocket doorwill always automatically stow and lock in the TT&L position any time the landing gear is deployed ortheflaps are notfully retracted. The doorwill always remain open until the landing gearand flaps are both fully retracted. The pocket door deployment mechanism and actuatorwill be highly reliable and GACwill substantiate thatthe probability offailure to egressthrough the MED, including the probability of failure on the pocketdoor, will be lessthan 1

# o-s perflight hours. This hazard criticality is based on 14CFR Part 25.783(b)(2).
c. The electric actuatorwill normally be operated via powerfrom the main cabin electric bus, and will use battery poweras back-up during a main cabin power loss d. The doorwill be designed so that for any failure ofthe 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 automaticopening feature will ensure clearegress path in the event that manual stowing ofthe door has not occurred. f. A warning light/chime in the cockpitwill alertthe crew ifthe pocket door is not in the properly stowed position forTT&L. g. GAC would propose developing a step-by-step procedureto educate passengers on the pocket dooremergency operation in the improbable eventwhere the door has deployed during an emergency landing. Passenger instruction on the pocket dooremergency 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 dooremergency procedures. These procedureswould be coordinated and approved by the FAA. h. Close proximity ofthe G280 pocketdoor installation to the cockpit area easily allows the
crewto visually verify position ofthe pocket door priorto taxiing, take-offand 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 mosttransport airplanes operated under Part 135 rules. As a result passengerawareness ofboth exits and the ability to quickly egress is greatly enhanced as compared to larger Part 135 aircraft. j. Passengers are inherently aware ofthe main entry door/exit location relative to the cabin
area because they entered the aircraftvia the main entry door/exit.

### Enclosure to G-ODA-13-656 September 05, 2013 Page 5 of7 Gulfstream Aerospace Corporation Petition for Exemption Gulfstream G280-Interior Door

Figure 4 - Pocket Door Latched/Stowed Condition



### Effectofthe Exemption on Safety
Acceptance ofthe proposed Gulfstream G280 design will ensure that a level ofsafety consistent with the intent ofthe regulation has been provided. The design and reliability ofthe proposed interior doorand door mechanisms will ensure the same level ofsafety for cabin egress as is required for any emergency exit and will provide a clear egress path. Generally, passengers of chartered executivejet are likely to be more familiarwith the exits, exit/egress operations and exit locations compared to passengers of largerscheduled aircraft. Additionally, the RH overwing Type Ill emergency exit opening is largerthan 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 of807.7 square inches. Forthe 10 passenger configuration, the emergency exit opening area is over 19% largerthan the Type Ill exit size requirement per 14 CFR 

### § 25.807(a)(3). Forthe more common 8 and 9 passengerconfigurations, the exit opening area is 74% largerthan the Type IV exit opening size per 14 CFR 

### § 25.807(a)(4). The emergency exit opening is taller, wider and is substantially largerthan the requirements. The 8 and 9 passengerconfigurations are selected at a much higher rate than the 10 passenger configuration. And, ifselected, the 10 passengerconfiguration is not likely to be filled with passengersfor long durations. As the subject Cabin Interior STC (ST04266AT-D) has aEnclosure to G-ODA-13-656 September 05, 2013 Page 6 of7 Gulfstream Aerospace Corporation Petition for Exemption Gulfstream G280

- Interior Door maximum passengerconfiguration of 10 passengers, the 10 passengerconfiguration is at the very bottom ofthe scale forType Ill exit door requirements as defined by 14 CFR 

### § 25.807(g}, which is 10to 19 passenger seats, providing margin as compared to the potentially higher passengerseat counts. This, combined with othercharacteristics ofthe G280 completed interior configurations, such as lower passenger seat counts (8, 9 and 10 passengerconfigurations), close proximity ofpassenger 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 orexceeding that currently prescribed under 14 CFR part 25. Although the current operational requirements under Parts 91 and 135forthis type ofaircraft have not been amended to correspond to the Part 25 restriction, Gulfstream acknowledgesthat the Part 25 change is an important enhancementto the level ofsafety offered by newly manufactured aircraft. The design criteria proposed by Gulfstream forthe G280 raises the current level ofsafety to that envisioned by Amendment 25-116 to part 25.

Issue of Public Interest:
Collectively, GAC and GALP designs, develops, manufactures, markets and servicesthe world's mosttechnologically advanced businessjet aircraftto an international market. Gulfstream's leadership position in the global businessjet market is dueto the efforts ofits nearlyten thousand employees in the manufacturing plants, completion centers, and service centers across North America and worldwide. GAC installsthe executive interiors forthe Model G280 airplanes that are operated worldwide. The owners ofbusinessjet aircraftvery often prefer a configuration that includes compartment doors, which reduce cabin ambient noise and provide for privacy ora comfortable rest area when needed. The ability to provide additional acoustic barrierfrom external noise forthe flight deck and cabin are being requested by prospective aircraft operators who compare the G280with products of European manufacturer and otherforeign aircraft completion centers. The inabilityto provide such features will ultimately cause a reduction in perspective sales. The completion and support ofGulfstream aircraftwould aid in the stabilization ofthejob market as well as the growth ofthe American economy, which is in the interest ofthe public.

The importance ofbusiness aviation to the well-being ofthe 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 businesstravel time, allowing a higherdegree ofproductivity through greater point-to-point service and the ability to better utilize the existing national airport network, in essence bringing the business closerto its intended customer. The office-like environmentthat exists on board the business aircraft allows the travel time ofbusy executivesto be a more productivetime.
Although the currentworld economy has slowed in comparison to previousyears, the corporate aircraft market has shown some positive growth and is expected to continue to grow. Therefore, the demand forthese corporate aircraft and the benefitsthey presentto business makes it essential that the petitioner be granted the regulatory relief requested. Failure to achieve this goalwill result in a significant loss ofincome, both in domesticand foreign trade forthe United States, the petitioner, and the intended business operators ofthese aircraft. The stabilizing effectthat manufacture and support ofcorporate aircraft has on thejob market is significant and definitely in the public interest.Enclosure to G-ODA-13-656 September 05, 2013 Page 7 of? GulfstreamAerospace Corporation Petition for Exemption Gulfstream G280- Interior Door Since customers desire to have these interior doors, they may opt foraircraft designed to an earlier certification basis, in lieu ofthe model Gulfstream G280 airplane. This will restrict advancements in safety introduced by Gulfstream with the G280, not only in the areas ofcabin safety, but throughout the airplane. This is counterproductive to both Gulfstream and the FAA's goal ofcontinuous improvement in overall aircraft safety. The advancement ofaircraft safety is in the interest ofthe public.

Waiver ofNotice and Public Procedure

Gulfstream respectfully requests that action on this petition should not be delayed by publication ofa summary ofour petition and associated comment period. We believe thatthe nature ofthis exemption does not set a precedent. The relief requested herein is effectively identical to exemptions previously granted on the Gulfstream model GVI, and delay ofgranting this exemption will unnecessarily delayfinal certification ofthe Amendment on the model Gulfstream G280 Cabin Interior STC.

Operations Outside ofthe United States:

The European Aviation SafetyAdministration (EASA) Certification Specification (CS) 25.813 is not currently harmonized with 

### § 25.813 and does not restrictthese types ofdoor installations.
Regardless of EASA requirements, in accordancewith 14 CFR 

### § 11.81(h), GAC petitions consideration be given to extending this exemption for operation outside ofthe United States. GAC/GALP aircraft are routinely registered and operated outside ofthe United States and projections are the sameforthe model Gulfstream G280 airplane. Granting this extension of privileges will allowfor operations based within foreign countries, including European Union membercountries, having bilateral agreements with the United States accepting FAA 14 CFR Part25 as equivalentto their airworthiness standardsfortransport category aircraft. GAC believes that limiting this exemption to use within the U.S. would put unfair restrictions on the marketability ofthe model Gulfstream G280 airplane.

Conclusion:

GAC believes the additional pocket doorfeatures, cabin/fuselage features and the aforementioned arguments support extending a new 14 CFR 

### § 25.813(e) pocket door exemption to G280 aircraftfor operations under Part 91 or Part 135. GAC further believesthat the proposed exemption is in the public interest, and provides a level ofoccupant safety consistentwith the current Federal Aviation Regulations.