Gulfstream 

A GENERAL DYNAMICS COMPANY 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

July 30, 2015 

G-ODA-15-0619 

Subject: Request for Exemption from 14 CFR 25.1447(c)(1) amdt 25-116, 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 of the 

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 amendment 25-116, 

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 that the 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. 

' If there are any questions, or if we can be of further 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. g lasscock@g u lfstream. 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.com 
Enclosure to G-ODA-15-0619 

July 30, 2015 

Petition for Permanent Exemption 

Gulfstream Aerospace Corporation 

14 CFR 25.1447(c)(1) 

Relieffrom section 14 CFR Part 25.1447(c)(1) Arndt. 25-116 

Gulfstream Aerospace Corporation (Gulfstream) of Savannah, Georgia has submitted 

application to the FAA's Atlanta Aircraft Certification Office for type certification of a new, twinengine, transport category aircraft to be known as the Gulfstream model GVII-G500. 

Gulfstream ODA project number TC-01-2010-0024 has been assigned to this effort. 

Gulfstream intends to certify the GVII-G500 and any subsequent derivative models to support 

landing field elevations (LFE) of up to 15,000 feet. 

14 CFR 25.1447(c)(1), Amendment 25-116- states in part that an oxygen-dispensing unit must 

be connected to oxygen-supply terminals immediately available to each occupant, wherever 

seated. If certification 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 15,000 feet, and the crew must be provided with a manual 

means to make the dispensing units immediately available in the event of failure of the 

automatic system. 

In accordance with the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 

14 CFR 25.1447(c)(1). This will allow the GVII-G500 and any subsequent derivative models to 

operate in and out of airports with landing field elevations approaching 15,000 feet and will 

prevent nuisance deployment of oxygen masks. Gulfstream is proposing alternative design 

requirements to provide an appropriate equivalent level of safety. This information provided 

herewith will outline this rationale. 

Supportive Information 

Nagqu Dagring Airport is a new airport under construction in northern Tibet. The airport is 

scheduled to be completed in 2015 and will have a landing field elevation (LFE) of 14,554 ft 

above sea level (excluding barometric pressure variations). This airport will help improve the 

transportation conditions in the region. 

In order for the GVII-G500 and any subsequent derivative models to provide the additional 

capability for landing at airports up to 15,000 feet, the Cabin Pressure Control System (CPCS) 

and the passenger oxygen control panel will be configured to allow the cabin internal pressure 

altitude to reach as high as 15,300 feet during normal operations. 

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Enclosure 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 proposes that 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 passenger oxygen mask 

deployment during takeoff and 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 of the passenger oxygen 

masks when operating into and out of airports up to 15,000 feet LFE. 14 CFR 25.1447(c)(1) 

states that oxygen dispensing units must be presented to the occupants before the cabin 

pressure exceeds 15,000 feet and that the crew must have a manual means of making 

dispensing units available in the event of a failure of the automatic system. An exemption is 

requested to allow a maximum oxygen altitude limit of more than 15,000 feet. 

The passenger oxygen control system design will account for field elevations up to 14,000 ft, 

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 has two 

positions: 

• "NORMAL": Automatic passenger oxygen mask activation at 14,750 ± 250 feet 

• "HI AL T": Automatic passenger oxygen mask activation at 15,750 ± 250 feet 

During operations into and out of an airport with a landing field elevation greater than 14,000 ft, 

"HI AL T" must be selected in order to reset the automatic passenger oxygen mask activation to 

approximately 15,750 feet and prevent a nuisance deployment of the 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 that the crew is reminded to 

reset the switch after departure from high altitude airports. The indication light will turn off when 

the switch is reset to "NORMAL". The manual mask deployment feature 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 > 14,000 feet, the procedures will instruct the crew to 

depress the "HI AL T" switch on the passenger oxygen control panel during descent and similarly 

after take-off when the cabin altitude has decreased below 14,000 feet. 

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Enclosure to G-ODA-15-0619 

July 30, 2015 

The AFM high elevation procedures will require that after engine start, the cockpit crew will wear 

oxygen masks until the cabin altitude is less than 10,000 feet. If the airplane takes off 

unpressurized for any reason (crew error, CPCS failure etc ... ) when departing an airport with 

elevation above 14,500 feet, 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 crew will be alerted to Low Cabin Pressure at cabin altitudes appropriate for high landing 

field elevation. The CPCS logic, (which is discussed in the AFM), specifies that during 

descent/climb the Cabin Pressure Low Warning is reset according the LFE selected (see 

below): 

Landing Field Elevation (Entered in Cabin Pressure Low Warning Setpoint for 

FMS) Aircraft with 15,000 feet LFE Maximum 

Less than or equal to 7,500 feet 8,000 feet 

7,500 < LFE::;; 9,500 feet 10,000 feet 

9,500 < LFE ::;;14,000 feet 14,500 feet 

14,000 feet to 15,000 feet 15,500 feet 

A Blue CAS message "Cabin Alt Alert Exceeds 1 OK" will display anytime the Cabin Pressure 

Low Warning is set above 10,000 ft. 

For high field elevation, during ground operation and at the start of climb, the Cabin Pressure 

Low Warning can start as high as 16,000 ft (LFE + 1000 ft) and is reset towards 8,000 ft as the 

cabin altitude decreases. During climb whenever the aircraft is above 34,000 ft, the Cabin 

Pressure Low Warning is reset to 8,000 ft and remains at 8,000 feet in cruise regardless of the 

LFE. During descent the Cabin Pressure Low Warning is reset according to the LFE selected. 

The additional 15,500-ft set point allows a 500-foot margin above maximum LFE to account for 

the Cabin Pressure Controller Unit (CPCU) internal sensor tolerance plus additional margin to 

prevent nuisance warnings. 

The passenger oxygen control system for the GVII-G500, and any subsequent derivative 

models, will incorporate a digital cabin pressure altitude sensor. This design will increase the 

accuracy and reliability of the passenger oxygen system over previous mechanical aneroid 

control systems. The new design will utilize a 3-way knob (OFF, AUTO, and MANUAL 

selections). In the event of a failure of the automatic system to deploy the passenger oxygen 

masks, indication will provide to the crew through CAS message alert. The flight crew will then 

have the ability to manually deploy the oxygen masks to the passengers. 

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Enclosure to G-ODA-15-0619 

July 30, 2015 

The GVII aircraft models will comply with 14 CFR 25.1447(c)(1) under all other conditions since 

the "NORMAL" set point for passenger mask deployment is 14,750 ft. Gulfstream will include all 

detailed instructions for High Field Elevation operation in the Airplane Flight Manual (AFM). 

Effect of the Exemption on Safety 

The exemption requested will not adversely affect the level of safety provided for the GVII-G500 

and any subsequent derivative models. 

The safety features described above are to ensure the avoidance of nuisance oxygen mask 

deployment while still allowing deployment in the event of a 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 pressure to 

exceed 15,000 feet. The CPCS and passenger oxygen control panel meet or exceed the FAA 

probability of failure requirements in all areas. As stated earlier, in the event of an unannunciated CPCS failure, the oxygen masks will drop automatically at a cabin altitude of no 

more than 16,000 feet, 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 of the GVII-G500 pressurization and oxygen systems and the AFM procedures 

provides for a safe environment for the crew and passengers while allowing for operation into 

and out of landing field elevations of up to and including 15,000 ft. 

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 due to 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 throughout the United 

States. Gulfstream competes for new business all over the world. This exemption will directly 

impact the high-altitude utility of the 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, or derivatives, with 

products of European and other aircraft manufacturers located outside the 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 of achieving 

an appropriate level of safety, while at the same time providing features attractive to prospective 

purchasers. 

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Enclosure to G-ODA-15-0619 

July 30, 2015 

The manufacture, 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. 

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 that the nature of this 

exemption does not set a precedent and this exemption is effectively identical to those of 

previously granted for which 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 Outside the United States 

In accordance with 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 GVIIG500 and its derivatives. Gulfstream believes that limiting this exemption to use within the 

United States would put unfair restrictions on the marketability of this 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 15,000 feet for the GVIIG500 and its derivatives. In addition, Gulfstream believes that an exemption is in the public 

interest and will not adversely affect passenger safety. 

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