f Lufthansa Technik AG 

Petition for Exemption - Summary 

FAA-Project No.: ST7317NY-T 

FAA Public Docket No.: FAA-2014-0136 
f Lufthansa Technik – Petition for Exemption – Summary 

FAA-Project No.: ST7317NY-T, FAA Public Docket No.: FAA-2014-0136 

Rev.: 01 Page 2 von 12 Mar. 31, 2014

Table of Content:

Revision History ..................................................................................................................................3 

Discussion ...........................................................................................................................................4 

Basis for Exemption ............................................................................................................................4 

14 CFR 25.785(h)(2) at amendment 25-88: Direct View ...................................................................5 

Safety Considerations ..................................................................................................................5 

Requested Relief ..........................................................................................................................5 

14 CFR 25.785(j) at Amendment 25-88: Firm Handholds .................................................................6 

Safety Considerations ..................................................................................................................6 

Requested Relief ..........................................................................................................................6 

14 CFR 25.791(a) and (d) at Amendment 25-72 and Special Condition 25-430-SC, condition 14: No 

Smoking Placards ............................................................................................................................6 

Safety Considerations ..................................................................................................................6 

Requested Relief ..........................................................................................................................6 

14 CFR 25.807(f)(4) at Amendment 25-114: Distance Between Exits ...............................................7 

Safety Considerations ..................................................................................................................7 

Requested Relief ..........................................................................................................................7 

14 CFR 25.813(e) at Amendment 25-116: Doors Between Passenger Compartments ......................8 

Safety Considerations ..................................................................................................................8 

Requested Relief ..........................................................................................................................9 

14 CFR 25.815 at Amendment 25-38: Width of Aisle .......................................................................9 

Safety Considerations ..................................................................................................................9 

Requested Relief ........................................................................................................................ 10 

14 CFR 25.853(d) at Amendment 25-116 and Special Condition 25-368-SC: Heat Release and Smoke 

Emission ....................................................................................................................................... 10 

Safety Considerations ................................................................................................................ 10 

Requested Relief ........................................................................................................................ 11 

Public Interest ................................................................................................................................... 12 

Future use and application of the exemption .................................................................................... 12 
f Lufthansa Technik – Petition for Exemption – Summary 

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Revision History:

Revision No.: Revision Highlight: 

IR Initial Issue 

01 - FAA public docket no. added to header and front page. 

- Revision number and date added to footer. 

- Revision history added. 

- Special Condition 25-430-SC added. 
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Discussion

Lufthansa Technik AG (LHT) in Hamburg (Germany) has been contracted by a customer for 

interior completion of VVIP business interiors in one Boeing Model 747-8 airplane. The 

Federal Aviation Administration (FAA) has accepted LHT’s application for a STC-validation 

of a European Aviation Safety Agency (EASA) STC and has filed the project under Project 

Number ST7317NY-T. The certification basis for the Boeing 747-8 has been defined based 

upon the EASA Type Certification Data Sheet (TCDS) IM.A.196 and the validation basis has 

been defined based upon the FAA TCDS A20WE. 

The EASA Certification Specifications (CS) as well as the Title 14 of the Code of Federal 

Regulations (14 CFR) parts 25 govern type design certification requirements for transport 

category airplanes. The primary intent of the CS and the CFR, as applied to transport aircraft 

is intended for commercial or common-carriage applications. These regulations are to ensure 

that aircraft manufacturers provide the appropriate design features to meet the standards 

necessary to protect the traveling public. These requirements define the normal public interest 

and safety level and provide regulatory guidelines to meet them. When the individual aircraft 

is to be used in private service (e.g., not for hire or common carriage), it is appropriate to take 

into consideration the specific needs of a different population of more experienced users and 

the operations specific to those users. 

Historically, the authorities have made adjustments to specific requirements based upon 

specific design and operational factors. As stated above, numerous exemptions and other 

regulatory changes have been granted to meet specific aircraft designs and applications. In 

like manner, LHT proposes to use mitigating design requirements and operational limitations 

to justify similar exemptions to the 747-8 aircraft modified for VVIP, not-for-hire or 

common-carriage service. 

In addition the requested exemptions are or have already been discussed with EASA as the 

certifying authority for this aircraft modification. 

Basis for Exemption

The aircraft that is the subject of this petition is a Boeing Model 747-8 modified for noncommercial/non-common-carriage VVIP service. It is typically in the service of foreign 

Heads-of-State interests and will be operated under 14 CFR parts 91 and 125 regulations or 

equivalent foreign standard. For this reason the privileges of this proposed exemption will be 

exercised outside the United States. 

The interior configurations typically installed result in a very small passenger population 

compared to for-hire or common-carriage standards. These passengers are typically very 

experienced travelers. For this reason the crews and passengers who fly on this aircraft have a 

substantially higher familiarity with the aircraft and its systems than those envisioned by the 

writers of the original regulations (CS and CFR). 

The exemptions proposed herein are justified based upon the following facts: 

· This aircraft is intended for VVIP use and is not appropriately configured for 

or intended for use for hire or common carriage. 

· This aircraft carries a lower amount of passengers compared to the originally 

type-approved passenger load. 
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· SFAR 109 Special Requirements for Private Use Transport Category Aircraft 

was issued in 2009 to address these issues among others. This SFAR is 

limited to aircraft with passenger counts of 60 or less. These requested 

exemptions will apply the same or similar requirements to an aircraft with 

higher passenger counts. 

· Similar exemptions have been routinely granted for VIP transport category 

aircraft for many years. For example: Exemptions 10339, 6820/6820A, 6881, 

7317/7317A, 7609, and 8765 as well as others have been either fully or 

partially granted by FAA. 

· These exemptions have been granted to both domestic and foreign applicants 

and applied equally to both domestically-produced aircraft and foreignproduced aircraft. 

· The Petitioner proposes mitigating requirements and conditions that establish 

acceptable levels of safety for the occupants consistent with previous grants. 

With these justifications in mind, LHT requests relief from and proposes a petition for 

exemption from the following regulations: 

14 CFR 25.785(h)(2) at amendment 25-88: Direct View

This aircraft interior is designed to accommodate VVIP personnel and staff members. 

These types of passengers require amenities such as meeting rooms, offices, 

bedrooms, lavatories, and lounges rather than traditional airline type seating. 

Furthermore they require a high level of privacy and security that is normally not 

available in airline-style interiors. An exemption to the flight attendant direct view 

requirement is therefore needed to allow the interior to meet these needs. 

As discussed in FAA Exemption 6820, the Direct-View requirement was incorporated 

into the FAA rules at amendment 25-51. During the rulemaking process FAA 

concluded that the “. . . location of the flight attendant seats near the floor level exits . . 

. is more important than the requirement to have a direct view of the cabin.” The final 

rule was revised from the NPRM proposal to state this. Further SFAR 109 set more 

flexible standards for this type of intended usage. 

Safety Considerations

Considering the smaller number of occupants in the VVIP aircraft, the familiarity of 

the flight and cabin crews with the specific airplane, its passengers and its interior 

arrangement, and the wording of the existing rule that places the proximity of the 

attendant to the exit over the ability of the attendant to view the cabin area, there 

should be no degradation in the passenger safety as a result of this requested 

exemption. 

Requested Relief

LHT proposes to meet the requirements as stated similarly in SFAR 109 and various 

Exemptions as: 

In lieu of the requirements of § 25.785(h)(2), to the extent practical without 

compromising proximity to a required floor level emergency exit, wherever possible 

the installed flight attendant seats shall be located to face the cabin area for which the 

attendant is responsible. 
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14 CFR 25.785(j) at Amendment 25-88: Firm Handholds

The current layout for the proposed VVIP interior in some areas is quite different from 

the airliner-type interior envisioned by the original rule. The proposed interior includes 

some large rooms or meeting areas where the originally envisioned requirement for 

firm hand hold along the aisles cannot be met. A typical airliner interior meets this 

requirement by relying on the individual seat backs along the main aisle or aisles. Any 

ceiling mounted handhold would ruin the appearance of the high quality interior and 

has the potential to create additional safety concerns. 

Safety Considerations

The risk for occupants due to the reduced number of direct hand holds in certain areas 

of the airplane should be considered acceptable for the following reasons: 

· in the various compartments seat backs, divan arms, tables, and furniture are 

readily within reach with one or two steps 

· all furniture in the passenger cabin will not have sharp corners and edges in 

order to avoid serious injury in case of contact during turbulence 

· the installed seats and divans are heavily upholstered and will not cause 

injuries when contacted, 

· occupants are experienced travelers and are generally familiar with this 

aircraft interior. 

Requested Relief

LHT proposes to meet the requirements as stated similarly in SFAR 109 and various 

Exemptions as: 

In lieu of the requirements of § 25.785(j), there must be means provided to enable 

persons to steady themselves in moderately rough air while occupying aisles or, where 

practicable, bordered by seats. 

14 CFR 25.791(a) and (d) at Amendment 25-72 and Special Condition		25-

430-SC, condition 14: No Smoking Placards

The VVIP aircraft is declared as a “no smoking” aircraft. 

Safety Considerations

There is no increase in occupants safety due to the special placement of “no smoking” 

placards. 

Requested Relief

LHT proposes to meet the requirements as stated similarly in SFAR 109 and various 

Exemptions as: 

Compliance with § 25.791 and Special Condition 25-430-SC is required except that 

for § 25.791(a) and (d) and Special Condition 25-430-SC, condition 14, when smoking 

is to be prohibited, notification to the passengers may be provided by a single placard 

so stating, to be conspicuously located inside the passenger compartment, easily 
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visible to all persons entering the cabin in the immediate vicinity of each passenger 

entry door. 

14 CFR 25.807(f)(4) at Amendment 25-114: Distance Between Exits

The current layout for the proposed VVIP interior foresees the deactivation of 

passenger emergency exits no. 3. Due to this deactivation the distance between 

passenger emergency exits is more than 60 feet. 

Safety Considerations

The risk for occupants due to the deactivated passenger emergency exit # 3 should be 

considered acceptable for the following reasons: 

· the airplane will be operated under 14 CFR parts 91 and 125 or foreign 

equivalent and will not be operated for hire or offered for common carriage 

· occupants are experienced travelers and are generally familiar with this 

aircraft interior and the location of the emergency exits 

· no passenger seat that is certified for the used during taxi, take-off and landing 

is located more than 30 feet from the nearest emergency exit 

· the number of passengers is substantially less (less than 33 percent) than the 

aircraft was originally certified for 

· a distance of more than 60 feet between adjacent passenger emergency exits 

on the same side of the same deck of the fuselage , is only foreseen once on 

each side of the fuselage 

Requested Relief

LHT proposes to meet the requirements as stated similarly in SFAR 109 and various 

Exemptions as: 

For an airplane that is required to comply with § 25.807(f)(4), in effect as of July 24, 

1989, which has more than one passenger emergency exit on each side of the fuselage, 

no passenger emergency exit may be more than 60 feet from any adjacent passenger 

emergency exit on the same side of the same deck of the fuselage, as measured parallel 

to the airplane's longitudinal axis between the nearest exit edges, unless the following 

conditions are met: 

(a) Each passenger seat must be located within 30 feet from the nearest exit on 

each side of the fuselage, as measured parallel to the airplane's longitudinal 

axis, between the nearest exit edge and the front of the seat bottom cushion. 

(b) The number of passenger seats located between two adjacent pairs of 

emergency exits (commonly referred to as a passenger zone) or between a pair 

of exits and a bulkhead or a compartment door (commonly referred to as a 

``dead-end zone''), may not exceed the following: 

(1) For zones between two pairs of exits, 50 percent of the combined 

rated capacity of the two pairs of emergency exits. 

(2) For zones between one pair of exits and a bulkhead, 40 percent of 

the rated capacity of the pair of emergency exits. 

(c) The total number of passenger seats in the airplane may not exceed 33 

percent of the maximum seating capacity for the airplane model using the exit 
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ratings listed in §25.807(g) for the original certified exits or the maximum 

allowable after modification when exits are deactivated, whichever is less. 

(d) A distance of more than 60 feet between adjacent passenger emergency 

exits on the same side of the same deck of the fuselage, as measured parallel to 

the airplane's longitudinal axis between the nearest exit edges, is allowed only 

once on each side of the fuselage. 

14 CFR 25.813(e) at Amendment 25-116: Doors Between Passenger

Compartments

This discussion covers doors that separate passenger compartments from other areas 

throughout the aircraft. This discussion does not include doors that separate e.g. 

lavatories or bathrooms from passenger compartments and these doors do not apply to 

this exemption request. 

The majority of the interior doors of the current layout for the proposed VVIP interior 

separate a passenger compartment from other areas (e.g. exit area). There are only two 

interior doors that directly separate two passenger compartments. These interior doors 

are installed in: 

· the upper deck forward of the emergency exit 

· the main deck in the area between emergency exit #3 and emergency exit #4 

Doors between passenger compartments and doors between passenger compartments 

and other areas (e.g. emergency exits) will have the following design features: 

· all doors will be operated manually 

· doors that need to be latched in the open position will have dual latches (each 

of which is able to withstand the forces defined § 25.561(b)) to secure the 

doors in the open position and to prevent inadvertent closing 

· the doors will be frangible to allow egress in the event that they should become 

stuck 

· the doors will provide vent areas to allow free airflow in the event of a rapid 

decompression 

· in case a locking mechanism is installed, these doors will provide features to 

unlock the door from either side without the use of a special tool 

· cockpit indication of the door position for taxi, take-off and landing 

· cabin crew indication of each individual door position to identify which 

door/doors is/are not in the correct position for taxi, take-off and landing 

Safety Considerations

The risk for occupants due to the use of doors between passenger compartments 

should be considered acceptable due to the features mentioned above and for the 

following reasons: 

· the airplane will be operated under 14 CFR parts 91 and 125 or foreign 

equivalent and will not be operated for hire or offered for common carriage 
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· the Airplane Flight Manual Supplement (AFM-S) or other adequate manual 

will provide procedures and limitations to ensure that the doors are in the 

proper position for taxi, take-off and landing. 

Requested Relief

LHT proposes to meet the requirements as stated similarly in SFAR 109 and various 

Exemptions as: 

· In lieu of the requirements of § 25.813(e), interior doors may be installed 

between passenger seats and exits, provided the following requirements are 

met: 

- each door between any passenger seat, occupiable for taxi, takeoff, 

and landing, and any emergency exit must have a means to signal to 

the flight-crew, at the flight-deck, that the door is in the open position 

for taxi, takeoff and landing. 

- appropriate procedures/limitations must be established in the AFM 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 must have dual 

means to retain it in the open position, each of which is capable of 

reacting the inertia loads specified in § 25.561(b). 

- each door between any passenger seat and any exit must be frangible 

in either direction. A frangibility test will be performed on each type 

of interior compartment door installation in the aircraft using a 5th 

percentile female subject. 

- each door between any passenger seat and any exit must be operable 

from either side, and if a locking mechanism is installed, it must be 

capable of being unlocked from either side without the use of special 

tool. 

· When the aircraft is equipped with interior doors under this Exemption: 

- the AFM must 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 passengers and crew. 

14 CFR 25.815 at Amendment 25-38: Width of Aisle

LHT is installing seats that translate laterally and longitudinally and also recline. 

Translating and/or reclining of seats will occur in flight only but can encroach on the 

aisle width required by Section 25.815. 

Safety Considerations

The risk for occupants in the passenger cabin due to reduced width of aisle in-flight 

should be considered acceptable for the following reasons: 

· the number of passengers is substantially less than the aircraft was originally 

certified for 
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· the passengers who use this aircraft are much more familiar with the aircraft 

interior and systems compared to passengers of a commercially operated 

aircraft 

· aisle width is only to be reduced during in-flight operation. For taxi, take-off 

and landing each individual seat position is clearly defined to provide the aisle 

width as required by § 25.815 

· reduced aisle width does not restrict access to any cabin area because all areas 

of the cabin will be accessible by a crew member in the event of an 

emergency (e.g., in-flight fire, decompression) without excessive effort or 

excessive loss of time 

· procedures will be established and documented in the AFM-S or other 

adequate manual to ensure that the cabin will be restored to proper 

configuration for taxi, take-off, and landing 

· the aircraft will not be operated for hire or common carriage 

Requested Relief

LHT proposes to meet the requirements as stated similarly in SFAR 109 and various 

Exemptions as: 

Compliance is required with § 25.815, except that the aisle width may be reduced to 

zero inches between passenger seats during in-flight operations only, provided that the 

applicant demonstrates that: 

· all areas of the cabin are easily accessible by a crew member in the event of 

an emergency (e.g. in-flight fire, decompression) 

· instructions are provided at each passenger seat for restoring the aisle width 

required by § 25.815 

· the operation to return the cabin furnishings to their proper taxi, take-off and 

landing positions is easy to handle 

· procedures must be established and documented in the AFM to ensure that the 

required aisle widths are provided during taxi, take-off, and landing 

14 CFR 25.853(d) at Amendment 25-116 and Special Condition 25-368-SC:

Heat Release and Smoke Emission

Completion centers have been able to simultaneously satisfy both the styling 

requirements of customers and the interior material flammability requirements of § 

25.853(a) and (c); however, many of the materials required in the aircraft interiors do 

not comply with the heat release and smoke emission requirements of § 25.853(d). 

Safety Considerations

The vast majority of the heat release and smoke portion of the rule was driven by the 

post-crash fire experiences in airline operations. The 65/65 heat release regulation was 

specifically developed to reduce the likelihood of the flash-over phenomenon which 

was proven by tests to be a primary factor to the rapid propagation of post-crash fires 

and the generation of blinding smoke. Rapid fire propagation combined with the 

relatively slow rate of passenger evacuation from densely packed airplanes has proven 

to be a deadly combination during actual airline accidents. Since it is clear that 
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material selection is being controlled by aesthetics in this application, we cannot 

exercise any real control over the actual heat within the first 90 seconds. Therefore, it 

is proposed as mitigation to the fire hazard that an evacuation analysis be performed to 

show that all occupants can be safely evacuated in less than 45 seconds. 

Requested Relief

LHT proposes to meet the requirements as stated similarly in SFAR 109 and various 

Exemptions as: 

Compliance is required with the applicable provisions of Sec. 25.853, except that 

compliance with appendix F, parts IV and V, need not be demonstrated if it can be 

shown by analysis that the maximum time for evacuation of all occupants does not 

exceed 45 seconds under the conditions specified in appendix J to part 25. 
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Public Interest

As in the cases of numerous already established Exemptions, granting this petition for 

exemption would be clearly in the public interest of the people of the United States of 

America for the following reasons: 

· Given the proliferation of VVIP configured Transport Category Airplanes, 

and anticipated in the near future, approval of these exemptions will enable 

the United States manufacturers of Transport Category Airplanes to 

effectively compete in this expanding market. 

· Additional sales of components manufactured in the United States even for 

VVIP interiors installed outside the United States will serve to increase 

supplying/supporting company’s profitability. 

· Stability and improved financial performance of these United States 

companies gives greater job stability to the workers employed by the 

companies, causing a stabilizing influence to the greater United States 

economy, due to the consumer pending activities associated with stable 

workers. 

· Improved financial performance of United States owned and operated 

corporations, and increased workforce stability translates into continued and 

improved local, state, and federal tax revenues which in turn add to the 

stability of the total United States economy. 

· Improved financial performance allows United States corporations to continue 

to invest in Research and Development, allowing the United States to 

maintain or improve its competitive position in the world economy. 

· Foreign Heads-of-State operating US-manufactured aircraft strengthens the 

preeminent global position of the United States aircraft manufacturing. 

· This aircraft will be operated under 14 CFR parts 91 and 125 or its foreign 

equivalent. This aircraft will not be operated for hire or offered for common 

carriage inside the US and therefore there is no safety impact on the US flying 

public. 

Future use and application of the exemption

This Exemption is intended for use on one single 747-8 interior program by LHT. Use and 

applicability of the Exemption will be controlled in the project and will be submitted to the 

applicable FAA Certification Office (i.e. NYACO). 

Exemptions to specific rules and associated mitigating requirements are to be individually 

applied. There is no requirement that all portions of this Exemption be applied 

simultaneously. When the approved exemption to a specific rule or rules is not used then full 

compliance to that rule or rules is required. 

We request to exercise the privilege of this exemption outside the United States since the 

operator of the airplane is located in a foreign country.