# Gulfstream

A GENERAL DYNAMICS COMPANY

U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE. Washington, DC 20590 July 30, 2015 G-ODA-15-0619

Subject: Requestfor Exemption from 14 CFR 25.1447(c)(1) amdt25-116, Equipment standards for oxygen dispensing units FAA Project No: TC-01-2010-0024 Enclosure: Petition for Permanent Exemption -14 CFR 25.1447(c)(1)

Dear Sirs: In accordance with 14 CFR Part 11, Gulfstream Aerospace Corporation requests consideration ofthe enclosed petition for exemption. This petition is being submitted to relieve the Gulfstream GVII-G500 model aircraft, and it's derivatives, from full compliance with 14 CFR 25.1447(c)(1) at amendment25-116, Equipment standards for oxygen dispensing units. This exemption is being requested to allow uncomplicated operations into landing fields up to 15,000 feet. Gulfstream believes that good cause exists why action on this petition should not be delayed by publication and comment procedures. We request thatthe 120-day FAA review and process period specified in 14 CFR 11.63(d) be reduced to 60 days. Gulfstream feels this request is appropriate as it does not set a precedent, and because the relief requested herein is identical to exemptions previously granted. ' Ifthere are any questions, or ifwe can be offurther assistance, please do not hesitate to contact us at: Robert Glasscock Gulfstream Aerospace Corporation PO Box 2206, M/S R-02 Savannah, GA 31402-2206 robert.glasscock@gulfstream.com (912) 965-6817 Respectfully,



# ~~- Robert Glasscock Director ODA Programs Gulfstream Aerospace Corporation Cc: N. Berryman, FAA (via email) C. Underwood, FAA (via email) B. Whitton Gulfstream ODA, Savannah (via email) 

### R. Nilson, Gulfstream ODA, Savannah (via email)

P.O. Box 2206 • Savannah, GA 31402-2206 USA • Telephone (912) 965-3000 • gulfstream.comEnclosure to G-ODA-15-0619 July 30, 2015 Petition for Permanent Exemption Gulfstream Aerospace Corporation 14 CFR 25.1447(c)(1)

Relieffrom section 14CFR Part 25.1447(c)(1) Arndt. 25-116 Gulfstream Aerospace Corporation (Gulfstream) of Savannah, Georgia has submitted application to the FAA'sAtlanta Aircraft Certification Office fortype certification ofa new, twinengine, transport category aircraftto be known as the Gulfstream model GVII-G500. Gulfstream ODA project numberTC-01-2010-0024 has been assigned to this effort. Gulfstream intendsto certify the GVII-G500 and any subsequent derivative modelsto support landing field elevations (LFE) of upto 15,000feet. 14 CFR 25.1447(c)(1), Amendment25-116- states in partthat an oxygen-dispensing unit must be connected to oxygen-supplyterminals immediately available to each occupant, wherever seated. Ifcertification for operation above 30,000 feet is requested, the dispensing units providing the required oxygen flow must be automatically presented to the occupants before the cabin pressure altitude exceeds 15,000feet, and the crew must be provided with a manual means to makethe dispensing units immediately available in the event offailure ofthe automatic system. In accordancewith the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 14 CFR 25.1447(c)(1). This will allowthe GVII-G500 and any subsequent derivative models to operate in and out ofairports with landing field elevations approaching 15,000feet and will prevent nuisance deployment ofoxygen masks. Gulfstream is proposing alternative design requirements to provide an appropriate equivalent level ofsafety. This information provided herewith will outline this rationale. Supportive Information Nagqu Dagring Airport is a new airport underconstruction in northern Tibet. The airport is scheduled to be completed in 2015 and will have a landing field elevation (LFE) of 14,554ft above sea level (excluding barometric pressure variations). This airport will help improve the transportation conditions in the region. In orderforthe GVII-G500 and any subsequent derivative models to provide the additional capabilityfor landing at airports up to 15,000feet, the Cabin Pressure Control System (CPCS) and the passenger oxygen control panel will be configured to allowthe cabin internal pressure altitude to reach as high as 15,300feet during normal operations.

1Enclosure to G-ODA-15-0619 July 30, 2015 Factors supporting the Petition 14 CFR 25.1447(c)(1) was designed to provide passenger safety during flight conditions. Gulfstream proposesthat passenger safety can be maintained during all flight conditions and can be further enhanced with simple and logical flight crew procedures to allow operation at high altitude airports. The changes proposed are designed to maintain an equivalent level of safety during flight while minimizing the possibility of nuisance passengeroxygen mask deployment during takeoffand descent at high altitude airport. The GVII-G500 and any subsequent derivative models will be designed to provide operations into high LFE airports. The design will prevent nuisance deployment ofthe passengeroxygen masks when operating into and out of airports up to 15,000feet LFE. 14 CFR 25.1447(c)(1) states that oxygen dispensing units must be presented to the occupants before the cabin pressure exceeds 15,000feet and that the crew must have a manual means of making dispensing units available in the event ofa failure ofthe automatic system. An exemption is requested to allow a maximum oxygen altitude limit of morethan 15,000feet. The passenger oxygen control system design will accountforfield elevations upto 14,000ft, and will have a secondary setting for high field elevations. To provide this, the Passenger Oxygen Control Panel will have an airport elevation selection switch installed that hastwo positions:

• "NORMAL": Automatic passenger oxygen mask activation at 14,750

### ±250feet • "HI AL 

### T": Automatic passenger oxygen mask activation at 15,750 

### ± 250feet During operations into and out of an airportwith a landing field elevation greaterthan 14,000ft, "HI AL 

### T" must be selected in orderto reset the automatic passenger oxygen mask activation to approximately 15,750feet and prevent a nuisance deployment ofthe passenger oxygen masks. The switch will remain in the "HI AL

### T" position during ground operations. An indication light on the switch will be illuminated when it is in the "HI AL

### T" position so thatthe crew is reminded to reset the switch afterdeparture from high altitude airports. The indication lightwill turn offwhen the switch is reset to "NORMAL". The manual mask deploymentfeature is available regardless of switch position. Gulfstream will include AFM operational procedures for LFE:::; 14,000, and procedures for LFE > 14,000 feet. For operations at LFEs > 14,000feet, the procedures will instructthe crewto depress the "HI AL

### T" switch on the passenger oxygen control panel during descent and similarly aftertake-offwhen the cabin altitude has decreased below 14,000feet.

2Enclosure to G-ODA-15-0619 July 30, 2015 The AFM high elevation procedures will require that afterengine start, the cockpit crewwill wear oxygen masks until the cabin altitude is less than 10,000feet. Ifthe airplane takes off unpressurized for any reason (crew error, CPCS failure etc

...) when departing an airportwith elevation above 14,500feet, the oxygen masks will be automatically presented to the passengers at 15,750

### ±250 feet. The passengers who boarded the airplane from high altitude airports should already be acclimated to the elevation. The crewwill be alerted to Low Cabin Pressure at cabin altitudes appropriate for high landing field elevation. The CPCS logic, (which is discussed in theAFM), specifiesthat during descent/climb the Cabin Pressure LowWarning is reset according the LFE selected (see below): Landing Field Elevation (Entered in Cabin Pressure LowWarning Setpointfor FMS) Aircraftwith 15,000feet LFE Maximum Less than orequal to 7,500 feet 8,000feet 7,500 < LFE::;; 9,500feet 10,000feet 9,500 < LFE ::;;14,000 feet 14,500feet 14,000feet to 15,000feet 15,500feet A Blue CAS message "Cabin Alt Alert Exceeds 1

### OK" will display anytimethe Cabin Pressure LowWarning is set above 10,000ft. For high field elevation, during ground operation and atthe start ofclimb, the Cabin Pressure LowWarning can start as high as 16,000ft (LFE 

### + 1000ft) and is resettowards 8,000ft as the cabin altitude decreases. During climb wheneverthe aircraft is above 34,000 ft, the Cabin Pressure LowWarning is resetto 8,000ft and remains at 8,000 feet in cruise regardless ofthe LFE. During descentthe Cabin Pressure LowWarning is reset according tothe LFE selected. The additional 15,500-ftset point allows a 500-foot margin above maximum LFE to accountfor the Cabin Pressure Controller Unit (CPCU) internal sensortolerance plus additional margin to prevent nuisance warnings. The passenger oxygen control system forthe GVII-G500, and any subsequent derivative models, will incorporate a digital cabin pressure altitude sensor. This design will increasethe accuracy and reliability ofthe passenger oxygen system over previous mechanical aneroid control systems. The newdesign will utilize a 3-way knob (OFF, AUTO, and MANUAL selections). In the event ofa failure ofthe automatic system to deploythe passengeroxygen masks, indication will provide to the crewthrough CAS message alert. The flight crewwill then have the ability to manually deploythe oxygen masksto the passengers.

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### ' Enclosureto G-ODA-15-0619 July 30, 2015 The GVII aircraft models will comply with 14 CFR 25.1447(c)(1) under all otherconditions since the "NORMAL" set point for passenger mask deployment is 14,750ft. Gulfstream will include all detailed instructions for High Field Elevation operation in the Airplane Flight Manual (AFM). 

### Effectofthe Exemption on Safety The exemption requested will not adversely affect the level ofsafety provided forthe GVII-G500 and any subsequent derivative models. The safetyfeatures described above are to ensure the avoidance of nuisance oxygen mask deploymentwhile still allowing deployment in the event ofa CPCS failure during operations into high LFE airports. The proposed CPCS will comply with 14 CFR 25.841(a)(1) as there are no probable failure conditions in the pressurization system that would cause the cabin pressureto exceed 15,000feet. The CPCS and passenger oxygen control panel meet or exceed the FAA probability offailure requirements in all areas. As stated earlier, in the event ofan unannunciated CPCS failure, the oxygen masks will drop automatically at a cabin altitude of no more than 16,000feet, same as the Gulfstream Model GVI. Manual passenger oxygen mask deployment is always available to the crew in the event of Low Cabin Pressure indication, and the cabin oxygen masks fail to automatically deploy. The design ofthe GVII-G500 pressurization and oxygen systems and the AFM procedures provides for a safe environmentforthe crew and passengerswhile allowing for operation into and out of landing field elevations of up to and including 15,000ft. 

### Issue of Public Interest Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the world's mosttechnologically advanced businessjet aircraftto an International market. Gulfstream's leadership position in the global businessjet market is dueto the efforts of its nearly ten thousand employees in the manufacturing plants, completion centers, and services centers access North America. The corporation utilizes numerous products, such as avionics and environmental control systems, from scores of suppliers located throughoutthe United States. Gulfstream competes for new business all overthe world. This exemption will directly impactthe high-altitude utility ofthe GVII-G500, and any subsequent derivative models, thereby having a direct effect on sales. High Landing field elevation operations are being requested by prospective aircraft operators who compare the GVII-G500 airplane, orderivatives, with products of European and other aircraft manufacturers located outsidethe United States. This operational capability will make Gulfstream aircraft more marketable to these prospective operators. This exemption as proposed above is in essence an alternative method ofachieving an appropriate level ofsafety, while at the same time providing features attractive to prospective purchasers.

4t I :,. Enclosure to G-ODA-15-0619 July 30, 2015 The manufacture, completion, and support of Gulfstream aircraft would aid in the stabilization of thejob market as well as the growth ofthe American economy, which is in the interest ofthe public. Waiver of Notice and Public Procedure Gulfstream Aerospace Corporation respectfully requests that action on this petition should not be delayed by publication and comment procedures. Gulfstream believes thatthe nature ofthis exemption does not set a precedent and this exemption is effectively identical to those of previously granted forwhich they were no public comments. Previously Granted Exemptions: Exemption No. 9940, Gulfstream GVI Exemption No. 6076, Boeing 757 Exemption No. 8668A, Boeing 737 Exemption No. 9801, Boeing 787 Exemption No. 6994, Airbus A320 Operation Outsidethe United States In accordance with 14 CFR 11.81(h), Gulfstream requests consideration be given to extending this exemption foroperation outside ofthe United States. Gulfstream aircraft are routinely registered and operated outside ofthe United States and projections are the sameforthe GVIIG500 and its derivatives. Gulfstream believes that limiting this exemption to use within the United States would put unfair restrictions on the marketability ofthis aircraft. Conclusion: Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.1447(c)(1) that would allow uncomplicated operations into landing fields up to 15,000feet forthe GVIIG500 and its derivatives. In addition, Gulfstream believes that an exemption is in the public interest and will not adversely affect passengersafety.

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