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 

November 20, 2015 

G-ODA-15-0955 

Subject: Request for Exemption from Section 25.813(e) of Title 14, Emergency Exit Access 

FAA Project No: TC-01-201 0-0024 

Attachment: Petition for Exemption -Installation of Mid-Cabin Interior Doors, Model GVII-G500 

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 its derivatives from full compliance with 14 CRF 25.813(e) at amendment 25-128, 

Emergency exit access, to allow for installation of interior doors between passenger compartments on 

private use aircraft. 

If you have any questions or need additional information please contact Robert Glasscock at (912) 965-

6817 (via e-mail at robert.glasscock@qulfstream.com) or the undersigned. 

Respectfully, 

Robert Glasscock 

Director ODA Programs 

P.O. Box 2206, M/S R-02 

Savannah, GA 31402-2206 

robert.glasscock@gulfstream.com 

(912) 965-6817 

Cc: N. Berryman, ACE-120A (via email) 

B. Whitton, Gulfstream ODA (via email) 

C. Underwood, ACE-120A (via email) 

M. Gordon, ANM-113 (via email) 

J. Nyberg, EASA (via email) 

P.O. Box 2206 • Savannah, GA 31402-2206 USA • Telephone (912) 965·3000 • gulfstream.com 
Petition for Permanent Exemption 

Gulfstream Aerospace Corporation 

Installation of Mid cabin pocket doors 

Model GVII-G500 and its derivatives 

Relieffrom section 14 CFR Part 25.813(e) Arndt. 25-128 

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

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

Gulfstream ODA project number TC-01-201 0-0024 has been assigned to this effort. 

The cabin interior of the GVII-G500, and its derivatives, relies on installation of mid cabin pocket 

doors to divide different sections of the passenger cabin areas and provide certain amenities 

and configuration options that have become the standard for executive class airplanes. 

14 CFR 25.813(e) Amendment 25-128- States that no door may be installed between any 

passenger seat that is occupiable for take-off and landing and any passenger emergency exit, 

such that the door crosses any egress path (including aisles, cross-aisles and passageways). 

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

14 CFR 25.813(e) for installations of these mid cabin pocket doors. Gulfstream proposes that 

specific design features of the GVII-G500 and its derivatives, and limiting this exemption to 

those aircraft that are operated as private use only (aircraft may not be offered for common 

carriage or operated for hire) will provide an appropriate level of safety. The information 

provided herein outlines this rationale. 

Supportive Information 

14 CFR 25.813(e) restricts the installation of any interior door between a passenger seat and 

any emergency exit, effectively restricting the use of all interior doors. 

Exemptions as well as Equivalent Level of Safety (ELOS) have been granted by the FAA to the 

14 CFR part 25 requirements allowing the installation of mid cabin doors when the aircraft is 

limited to private use only (aircraft may not be offered for common carriage or operated for hire). 

On June 08, 2009, the FAA released Special Federal Aviation Regulation (SFAR) 109 allowing 

the installation of interior doors when the aircraft is prohibited from operations involving the 

carriage of persons or property for compensation or hire beyond the remuneration afforded by 

14 CFR part 91, subpart F. 

Because Gulfstream operators transition between private use only and on-demand operations 

(14 CFR part 135), Gulfstream is requesting an exemption based on the requirements of the 

applicable sections of SFAR 109 to allow the installation of mid cabin pocket doors when the 

aircraft is limited to private use only (prohibited from operations involving the carriage of persons 
or property for compensation or hire beyond the remuneration afforded by 14 CFR part 91) and 

locking out the door for common carriage or on-demand operations (14 CFR part 135 

operations). 

For the GVII-500 airplane and its derivatives, Gulfstream believes that it is possible to provide a 

level of safety consistent with the intent of the 14 CFR Part 25 regulations while allowing 

installation of certain interior doors. This will be accomplished by incorporating specific design 

features that provide an acceptable level of safety. 

Factors supporting the Petition 

Under private use only, passengers become exceptionally familiar with the operation of interior 

features and the locations of the exits on their Gulfstream product. Unlike common carriage or 

on-demand operations, the crew of a private use Gulfstream aircraft has daily contact with their 

passengers. This has a positive influence on communicating safety issues. In addition, 

dedicated crews normally operate private use aircraft. The combination of these factors and the 

design features listed below provides a level of safety commensurate with the level of safety 

envisioned by Amendment 25-128. 

The design features of the mid cabin pocket doors installed on the GVII-G500 and its derivatives 

will ensure that the passengers' ability to effectively egress the airplane is not diminished per 

the following criteria. 

• The Airplane Flight Manual Supplement (AFMS) will include appropriate 

limitation(s) to require a preflight passenger briefing describing the appropriate 

functions to be performed by the passengers and the relevant features of the 

airplane to ensure the safety of the passenger and crew. 

• The airplane will not be offered for common carriage or operated for hire or hire 

beyond the remuneration afforded by 14 CFR part 91. The operating limitations 

section of the Airplane Flight Manual Supplement (AFMS) will be revised to 

prohibit any operations involving the carriage of persons or property for 

compensation or hire. 

• A placard stating that "Operations involving the carriage of persons or property 

for compensation or hire are prohibited, unless the mid-cabin door is locked in an 

open position" will be located in the area of the Airworthiness Certificate holder at 

the entrance to the flightdeck. 

• Each door between any passenger seat, occupiable for taxi, take-off and landing, 

and any emergency exit will have a means to signal to the flight crew, at the flight 

deck, that the door is in the open position for taxi, take-off and landing. 
• Appropriate procedures/limitations will be established to ensure that any such 

door is in the open configuration for taxi, take-off and landing. 

• Each door between any passenger seat and any exit will have dual means to 

retain it in the open position, each of which is capable of reacting the inertia 

loads specified in 14 CFR 25.561. 

• Doors installed across a longitudinal aisle will translate laterally to open and 

close, e.g., pocket doors. 

• Each door between any passenger seat and any exit will be frangible in either 

direction. 

• Each door between any passenger seat and any exit will be operable from either 

side, and if a locking mechanism is installed, it will be capable of being unlocked 

from either side without the use of special tools. 

The mid cabin pocket door will be equipped with a locking device to retain the door in the 

stowed position to be used should the aircraft be offered for hire operations (such as ondemand operations under 14 CFR part 135). This locking device will physically secure the door 

in a stowed condition using a fastener which requires the use of a special tool, preventing 

passengers from removing the lockout feature and deploying the door. 

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 design of the proposed mid cabin pocket door will 

ensure the same level of safety for cabin egress as is required for any emergency exit and clear 

egress path. 
Issue of Public Interest 

Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the 

world's most technologically advanced executive class airplane to an International market. 

Gulfstream's leadership position in the global executive class airplane is due to the efforts of its 

nearly ten thousand employees in the manufacturing plants, completion centers, and services 

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. This exemption will have a direct 

impact on sales of the GVII-G500 and its derivatives. The placement of mid cabin pocket door is 

significant to the owner/operator of the airplane. The flexibility to partition the airplane into 

individual rooms, such as private rooms, is paramount to an acceptable interior and is being 

requested by prospective airplane operators who compare the GVII-G500 and its derivatives 

with products of foreign airplane manufacturers. The inability to provide such features will 

ultimately cause a reduction in perspective sales. The manufacture, completion, and support of 

Gulfstream airplanes aids in the stabilization of the job market as well as the growth of the 

American economy, which is in the interest of the public. 

Since customers desire to have these mid cabin pocket doors, they may opt for airplane 

designed to an earlier certification basis, in the lieu of the GVII-G500 or its derivatives. This will 

restrict advancements in safety introduced by Gulfstream with the GVII-G500 and its 

derivatives, not only in the areas of the cabin safety, but throughout the airplane. This is 

counterproductive to both Gulfstream and the FAA's goal of continuous improvement in overall 

safety. The advancement of airplane safety is in the interest of the public. 

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 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. 

Waiver of Notice and Public Procedure 

In accordance with 14 CFR 11.29 and 14 CFR 11.87, Gulfstream requests that the period for 

public comment and publication be waived. This exemption is identical to the applicable 

sections of SFAR 109 except that it adds a lock out feature to be utilized should the aircraft be 

offered for hire operations (such as on-demand operations under 14 CFR part 135). Similar 

exemptions of this nature have been granted numerous times for similar installations. 
Previously Granted Exemptions: 

Exemption No. 1 0338A, Embraer S.A. 

Exemption No. 10274, Gulfstream Aerospace 

Exemption No. 1 0396, Dassault Aviation 

Conclusion: 

Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.813(e) that 

would allow for installation of mid cabin pocket doors on the GVII-G500 and its derivatives for 

private use operations. In addition, Gulfstream believes that an exemption is in the public 

interest and will provide a level of passenger safety consistent with the current 14 CFR Part 25 

regulations.