# Gulfstream

A GENERAL DYNAMICS COMPANY

U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 NewJerseyAvenue, SE. Washington, DC 20590 November20, 2015 G-ODA-15-0955

Subject: Requestfor Exemption from Section 25.813(e) ofTitle 14, Emergency ExitAccess FAA Project No: TC-01-2010-0024 Attachment: Petition for Exemption -Installation ofMid-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. Ifyou have any questions or need additional information please contact Robert Glasscock at (912) 965- 6817 (via e-mail at robert.glasscock@qulfstream.com) orthe undersigned. Respectfully,

Robert Glasscock Director ODA Programs P.O. Box 2206, M/S R-02 Savannah, GA31402-2206 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.comPetition for Permanent Exemption Gulfstream Aerospace Corporation Installation of Mid cabin pocketdoors

Model GVII-G500 and its derivatives
Relieffrom section 14CFR 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 Officefortype certification ofa new, twinengine, transport category airplane to be known as the Gulfstream model GVII-G500. Gulfstream ODA project numberTC-01-2010-0024 has been assigned to this effort. The cabin interiorofthe GVII-G500, and its derivatives, relies on installation of mid cabin pocket doorsto divide differentsections ofthe 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 passengerseatthat is occupiable fortake-off and landing and any passenger emergency exit, such thatthe doorcrosses any egress path (including aisles, cross-aisles and passageways). In accordancewith the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 14 CFR 25.813(e) for installations ofthese mid cabin pocket doors. Gulfstream proposes that specific design features ofthe GVII-G500 and its derivatives, and limiting this exemption to those aircraftthat are operated as private use only (aircraft may not be offered for common carriage or operated for hire) will provide an appropriate level ofsafety. The information provided herein outlines this rationale. Supportive Information 14 CFR 25.813(e) restricts the installation ofany interiordoor between a passenger seat and any emergency exit, effectively restricting the use ofall interiordoors. Exemptions as well as Equivalent Level of Safety (ELOS) have been granted by the FAAto the 14 CFR part 25 requirements allowing the installation ofmid 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 interiordoors 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 ofthe applicable sections of SFAR 109 to allowthe installation of mid cabin pocket doors when the aircraft is limited to private use only (prohibited from operations involving the carriage of personsor property for compensation or hire beyond the remuneration afforded by 14 CFR part 91) and locking outthe doorfor common carriage or on-demand operations (14 CFR part 135 operations). Forthe GVII-500 airplane and its derivatives, Gulfstream believes that it is possible to provide a level ofsafety consistentwith the intent ofthe 14 CFR Part25 regulations while allowing installation ofcertain interiordoors. This will be accomplished by incorporating specific design features that provide an acceptable level ofsafety.
Factors supporting the Petition Under private use only, passengers become exceptionallyfamiliarwith the operation ofinterior features and the locations ofthe exits on their Gulfstream product. Unlike common carriage or on-demand operations, the crew ofa private use Gulfstream aircraft has daily contactwith their passengers. This has a positive influence on communicating safety issues. In addition, dedicated crews normally operate private use aircraft. The combination ofthese factors and the design features listed below provides a level ofsafety commensuratewith the level ofsafety envisioned by Amendment 25-128. The design features ofthe mid cabin pocket doors installed on the GVII-G500 and its derivatives will ensure thatthe passengers' ability to effectively egressthe airplane is not diminished per the following criteria.

• TheAirplane 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 ofthe airplane to ensure the safety ofthe passenger and crew.

• The airplane will not be offered for common carriage oroperated for hire or hire beyond the remuneration afforded by 14 CFR part 91. The operating limitations section ofthe Airplane Flight Manual Supplement (AFMS) will be revised to prohibit any operations involving the carriage ofpersons or propertyfor compensation orhire.

• 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 oftheAirworthiness Certificate holderat the entrance to theflightdeck.

• Each door between any passengerseat, occupiable fortaxi, take-off and landing, and any emergency exitwill have a means to signal to the flight crew, atthe flight deck, thatthe door is in the open position fortaxi, take-offand landing.• Appropriate procedures/limitations will be established to ensure that any such door is in the open configuration fortaxi, take-off and landing.

• Each door between any passengerseat and any exitwill have dual meansto retain it in the open position, each ofwhich is capable of reacting the inertia loads specified in 14 CFR 25.561.

• Doors installed across a longitudinal aislewill translate laterallyto open and close, e.g., pocket doors.

• Each door between any passengerseatand any exitwill be frangible in either direction.

• Each door between any passengerseat and any exitwill be operable from either side, and ifa locking mechanism is installed, itwill be capable of being unlocked from eitherside withoutthe use ofspecial tools.
The mid cabin pocket doorwill 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 fastenerwhich requires the use ofa special tool, preventing passengersfrom removing the lockoutfeature and deploying the door.

Effectofthe Exemption on Safety The exemption requested will not adversely affectthe level ofsafety provided forthe GVII-G500 and any subsequent derivative models. The design ofthe proposed mid cabin pocket doorwill ensure the same level ofsafetyfor cabin egress as is required forany emergency exit and clear egress path.

### Issue of Public Interest Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the world's mosttechnologically 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 ofsuppliers located throughoutthe United States. Gulfstream competes for new business all overthe world. This exemption will have a direct impacton sales ofthe GVII-G500 and its derivatives. The placement of mid cabin pocketdoor is significanttothe owner/operator ofthe airplane. The flexibility to partition the airplane into individual rooms, such as private rooms, is paramountto an acceptable interiorand is being requested by prospective airplane operators who comparethe GVII-G500 and its derivatives with products offoreign airplane manufacturers. The inabilityto provide such features will ultimately cause a reduction in perspective sales. The manufacture, completion, and support of Gulfstream airplanes aids in the stabilization ofthejob market as well as the growth ofthe American economy, which is in the interest ofthe public. Since customers desireto have these mid cabin pocket doors, they may optfor airplane designed to an earlier certification basis, in the lieu ofthe 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 ofthe cabin safety, but throughoutthe airplane. This is counterproductive to both Gulfstream and the FAA's goal ofcontinuous improvement in overall safety. The advancement ofairplane safety is in the interest ofthe public.


### Operation Outsidethe United States In accordancewith 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 ofthe United States and projections are the same forthe 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.



### Waiver ofNotice and Public Procedure In accordancewith 14 CFR 11.29 and 14 CFR 11.87, Gulfstream requests thatthe period for public comment and publication be waived. This exemption is identical to the applicable sections of SFAR 109 exceptthat it adds a lock outfeature to be utilized should the aircraft be offered for hire operations (such as on-demand operations under 14 CFR part 135). Similar exemptions ofthis nature have been granted numerous times for similar installations.Previously Granted Exemptions: Exemption No. 10338A, Embraer S.A. Exemption No. 10274, Gulfstream Aerospace Exemption No. 10396, DassaultAviation
Conclusion: Gulfstream believes thatthe above arguments favor an exemption from 14 CFR 25.813(e) that would allowfor 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 ofpassenger safety consistentwith the current 14 CFR Part 25 regulations.