### r U.S. Department ofTransportation Docket Operations West Building Ground Floor, Roomw12'-140 1200 New Jersey Avenue, SE. Washington, DC 20590 October2, 2015 File: J905 FAA Project Number: ST07970NY-T

References: 1. FAA Exemption No. 10422 (Docket No. FAA-2011-1052) Subject: Petition for Exemption Amendment- Company Name Change

To whom it may concern, Please acceptthis letter as our petition to amend FAA Exemption Number 10422 (attached) to change the company name from ACS-NAI Ltd. to B/E Aerospace Limited. The company location remains unchanged from 25 Dunlop Avenue, Winnipeg, Manitoba Canada, R2X 2V2. B/E Aerospace Limited was formerly known as ACS-NAI Ltd. Between the time period when Reference 1was issued (December 2011) and today, our company name has changed as follows:

• October2013 -company name changed from "ACS-NAI Ltd." to "EMTEQ Canada Limited" • February 2014- Transport Canada Design Approval Organization Certificate DAO #98-C-01 re-issued in EMTEQ Canada Limited name • December 2014- company name changed from "EMTEQ Canada Limited" to "B/E Aerospace Limited" • February 2015- Transport Canada Design Approval Organization Certificate DAO #98-C-01 re-issued in B/E Aerospace Limited name This request is in support of current (and future) FAA validations of TCCA STCs held by B/E Aerospace Limited which include an Exemption from 25.813(e) as part ofthe Basis of Certification for the design change. Should you have any questions, please do not hesitate to contact me. Regards,



# 4L

Adam Coolidge, P. Eng. Certification Manager B/E Aerospace Limited Encl.

25 Dunlop Avenue, Winnipeg, MB R2X 2V2 Canada • Office +1-204-783-5402 Fax +1-204-783-5436 • beaerospace.com

### Exemption No. 10422

UNITED STATES OFAMERICA DEPARTMENT OFTRANSPORTATION FEDERALAVIATIONADMINISTRATION RENTON, WASHINGTON 98057-3356

In the matter ofthe petition of ACS-NAI Ltd. for an exemption from§ 25.813(e) ofTitle 14, Code ofFederal Regulations Regulatory Docket No. FAA-2011-1052

GRANT OFEXEMPTION Byletter dated September 13,2011, Mr. Ian Stewart, ofACS-NAI Ltd., 25 Dunlop Avenue, Winnipeg, MB, Canada R2X 2V2, petitioned for exemption from the requirements of §

### 25.813(e) ofTitle 14, Code ofFederalRegulations (14 CFR). The petitionerhas requested the exemption to permit installation ofinteriordoors between passengercompartments on a BombardierAerospace Model CL-600-2B19 airplane, to be designated asprivate use, not for hire, not for common carriage. Thepetitioner requests relieffrom the following regulation: Section 25.813(e), Amendment25-46 1

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### No door may be installed in any partition betweenpassenger compartments. Thepetitioner supports their request with the following information: This section quotes the relevant information, with some edits for clarity, from the petitioner's request. Theircomplete petition is available at the Department ofTransportation's Federal Docket Management System, on the Internet at http://regulations.gov, in Docket No. FAA-2011- 1052.

1For 14 CFRpart 135 operations, there shall be instructions within the Airplane FlightManual Supplement (AFMS) and Instructions for Continued Airworthiness (ICA) to provide a procedure to lockthe door in the openposition and install a coverplate to obscure the doorand preventingthe use ofthe doorduring flight.ACS-NAI Ltd. requests an exemption to Federal Aviation Regulations (FAR) 25.813(e) to permit the installation ofdoors in partitions between passengercompartments in CL600-2819 aircraft used for corporate transport. In support ofthis request, ACS-NAI Ltd. is attaching a copyofTCCAExemption NCRIRCN #147-2008 granting an exemption from the requirements of25.813(e). The CL-600-2B19 aircraft is designed to the requirements ofFAR part 25, for Transport Category Aircraft. These rules are addressed to Transport Category airplanes that are used for the carriage offare payingpassengers from the general public and consider aircraftwith passenger seating configurations ofseveral hundred. The CL-600-2B 19 aircraft configured with a corporate interioris Type Certified for a maximum of 19 passengers. FARpart 25 does not provide segregation for intended use ofthe aircraft, such as commercial airtransport or corporate use. The mid-cabin door installed for corporate interior configurations provides an increased level ofcomfort and privacy for the "office in the sky" concept. ACS-NAI Ltd. contends that aircraft interiors specificallydesigned for corporate operations should beeligible for an exemption [from] FAR part 25 requirements provided a level ofsafety is provided and canbe demonstrated. Design Safety Features: 1. The cabin ofthe CL-600-2B19 is approximately 8-feet wide. In orderto provide a private area for use as an office orbedroom, it is necessaryto divide the cabin width laterally. A side corridor is not practical for the interior arrangement on CL600-28 19 aircraft. The doors to be installed 

### will be sliding pocket doors with retracting footers. The slidingpocket door will be frangible to ensure it can be broken open during an emergency landing condition and to haveblow-out capabilities to provide adequate decompression capabilities. 2. The proposed doors will have a placard installed on both sides requiring the door to be secured within the bulkhead (i.e. door open) for taxi, take-offand landing. 3. Theproposed doors will be equipped with dual means to latch the door within the bulkhead to minimize the probability ofthe door deploying into the egress path during an emergency landing condition. Eithermeans will becapable of supporting the inertia loads specified in FAR 25.561. 4. A lighted annunciator will be installed in the cockpit instrumentpanel to alert the flight crew when the door is closed (i.e. across the egress path) and the airplane gear is down and locked, or flaps are not zero degrees. Due to the design philosophy ofthe cockpit and the configuration ofthe EICAS software for the CL-600-2B 19, posting a "cabin door" message on the EICAS is not possible. The



### 2TCCA Exemption pem1its this signal as the annunciator is "effected in an equivalent manner" to posting on the EICAS. 5. A description ofthe doors, passengerbriefingrequirements, limitations and procedures will be contained in the applicable Airplane Flight Manual Supplement and/or Flight Crew Operating Manual Supplement. 

### Effect ofthe Exemption: The effect ofthe exemption considering the design safety features will ensure that there is a clearpath through a cabin partition to an emergency exit. Should the cabin doorbe fully orpartiallyclosed following an emergency landing, there will still be simple means to get through the door to reach an exit. The frangibility feature will be tested using a 51 h percentile female and the resulting opening will be demonstrated to be large enough for a 95 1 hpercentile maleto escape. These safety features would provide a level ofsafety for the passengers in a CL-600-2B19 aircraft equal to that required for airline aircraft and othercorporate aircraft such as the BD-700-1A1 0 and BD-700-1A11. 

### Issue ofPublic Interest: Cabin doors have been installed in corporate aircraft such as the BD-700-lAIO and BD-700-lA11. Interiorcabin doors are commonly installed on corporate aircraft at the request ofthe members ofthe publicthat use these aircraft. The installation ofthese cabin doors [has] been shown to be adequately safe for corporate aircraft operations. It is ourposition that the above stated design safety features, the effect ofthe exemption and the issue ofpublic interest provide an acceptable level ofsafety for passengers in a CL-600-2B19 with an interior cabin door installed. Compliance has been established against TCCA ExemptionNCR/RCN #147-2008 for the installation ofan interior cabin door. We request to forgo the period for public consultation for the mid-cabin door exemption petition due to similarity with other FAA Exemption[s] [issued allowing] the installation ofan interior cabin door. 

### Federal Register publication The FAAhas determined that good cause exists for waiving the requirement for Federal Register publication and comment because the exemption, ifgranted, would not set a precedent and any delay in acting on this petitionwouldbe detrimental to ACS-NAI Ltd.



### 3The 

### FAA's analysis The FAA considers the petitioner's proposal to be in the public interest for the same reasons as those previously stated bythe petitioner. As more transport-category airplanes havebeen configured (orre-configured) for private use, the FAA has given considerable attention to the issue ofappropriate regulation ofsuch airplanes. Some ofthe currentregulations governing design certification oftransport-category airplanes are not compatible with private use ofsuch airplanes. Because ofthis, we have received a number of petitions for exemption from certain regulations. We have granted such exemptions when we find that to do so is in the public interest and does not adversely affect the level ofsafety provided bythe regulations. The FAA published Special Requirements for Private Use Transport CategoryAirplanes, SFARNo. I09 (74 FR 21533, May 8, 2009), which significantly reduced the need for case-by-case review ofindividual petitions for exemption for private-use airplanes. This airplane can not use SFAR No. 109because this is a new type-certificate project, and the SFAR is applicable to amended type-certificate and supplemental type-certificate programs only. Theplacement ofinterior doors is clearlyquite significant to the owner/operatorofthe airplane. The flexibilityto partition the airplane into individual rooms, such as private meeting rooms or bedrooms, is paramount to an acceptable interior. The availability ofprivate meeting rooms and bedrooms is essential. The FAA acknowledges the desirability ofthese features from the operator's point ofview. When the regulations pertaining to interior doors were adopted, they did not necessarily consider "rooms." They considered two possible types ofinteriordoors in a passenger compartment. The first type is an interior doorbetween passengercompartments. The second type is an interior door between the exit and the passengercompartment. Until recently, only the first type ofdoor was prohibited by 14 CFR 25.813(e). However, part 25, as amended by Amendment 25-116, prohibits interior doors between the exit and the passenger compartment. In addition, Amendment 121-306 prohibits these doors in airplanes manufactured after November 27, 2006, operated under 14 CFRpart 121. Amendments 25-116 and 121-306, titledMiscellaneous Cabin Safety Changes, were published in the Federal Register on October 27, 2004. Airplanes configured for private-use, not-for-hire, not-for-common carriage typically use any of five different categories ofdoor in the passenger cabins: Category 1- A door in a room and the room is less than the full width ofthe airplane. An aisle is outside the room. This type ofroom may be occupied during taxi, takeoff, and landing, and only the occupants ofthe room must use the doorto reach an exit. Category 2

- A door in a room and that is the same as Category 1, except a single emergency exit orpair ofemergency exits is within the room. · 

### 4Category 3 - A door ordoors in a compartment and the compartment is the full width ofthe airplane. Passengers are seated on both sides (fore and aft) ofthe door(s), and the main aisle leads out of, orpasses through, the compartment. The compartment does not have emergency exits. This type ofcompartment maybe occupied during taxi, takeoff, and landing with doors in the properconfiguration. Category 

### 4- A door in a room and the room is the full width ofthe airplane. Passengers are seated onboth sides (fore and aft) ofthedoor, and apairofemergencyexits is at one end ofthe room. This type ofcompartment may be occupied during taxi, takeoff, and landing with doors in the properconfiguration. Category 

### 5- A doorin a room that may be the full width ofthe airplane. This type ofroom is not occupied during taxi, takeoff, and landing. This room is only occupied during flight. Passengers seated in taxi, takeoff, and landing seats must not need to pass through this doorto get to any emergencyexits. Because not all interior doors between passengercompartments are equivalent, the FAA has determined that the following requirements will produce an adequate level ofsafety: I. To maximize the level ofsafety, doors in Category 2, 3, or4 installed across the main cabin aisle must open andclose in a transverse direction. That is, the direction ofmotion ofthe doormust be at a right angle to the longitudinal axis ofthe airplane. A "pocket door" is one example ofsuch a design. This will tend to minimize the chance that the inertia forces ofan accident could force the doorclosed. 2. Redundant means are necessary to latch doors open for taxi, takeoff, and landing. Each latching means musthave the capability ofretaining the door in the taxi, takeoff, and landing position under the inertia forces of§ 25.561. 3. Each interior door must be frangible, in the event that it isjammed in the closed position in flight orduring taxi, takeoff, or landing. Frangibility is intended to ensure that ifa door isjammed closed, occupants can escape in either direction and emergency equipment can be moved. Frangibilitymaybedemonstrated in either ofthe fo11owing ways:

• A 51hpercentile female can break through the door, creating a large enough opening that a 95th percentile (or larger) male can passthrough. (See Advisory Circular 25-17A, TransportAilplane Cabin Interiors Craslnvorthiness Handbook, paragraph43b(2)).

• A 5th percentile female can break a hinge on the doorora hinge on a smaller door within the door such that the door can swing open, allowing a 95th percentile (or larger) male to pass through the opening with the door swung open. This evaluation must be made with any cabin furnishing orequipment installed that could limit the swing-arc ofthe door with furnishing orequipmentplaced in the most adverse position. In using this approach, one must considerthe possibility 

### 5that the door is physicallyjammed in the closed position bydistortion ofthe fuselage or furnishings. This possibilitymustbeconsidered even ifthe door normallytranslates into the open and closed positions. 4. Doors that fall into Category 1must be in the open position during taxi, takeoff, and landing onlywhen the room is occupied. 

### 5. Doors that fall into Categories 2, 3, or4 must be in the open position during taxi, takeoff, and landing, regardless ofoccupancy. 6. Doors that fall into Category 5 must be in the closed position during taxi, takeoff, and landing. With respect to the possibilitythat a doorremains closed whenit should not be, we have determined that a higher level ofawareness is required to address this issue. The petitioner's proposal to provide indication to the flight crew is considered adequate. After considerable deliberation, we conclude that installation ofinterior doors, with certain limitations, can be accepted. To maximize the level ofsafety, we require that certain limitations, including some proposedbythe petitioner, bemade mandatoryto pem1it such installations. As notedpreviously, precedents have been set for this decision and which apply to other private-use, not-for-hire, not-for-common-carriage airplanes. 

### The FAA's decision In consideration ofthe foregoing, I find that a grant ofexemption is in the public interest and will not adversely affect the level ofsafetyprovided by the regulations. Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701, delegated to meby the Administrator, I grant the petition ofACS-NAI Ltd. for an exemption from the requirements of 14 CFR 25.813(e) to allow insta11ation ofinterior doors betweenpassengercompartments on a Bombardier Aerospace Model CL-600-2819 airplane. This exemption is subject to the following conditions. Conditions 1, 3, 4, 5, and 6 must be documented as operating limitations in the Limitations section ofthe Airplane Flight Manual (AFM). Referto Categories 1 - 

### 5, listed earlierin this document, where conditions reference categories. This exemption is subject to the following conditions, and limitation numbers 1, 2, 3, 4, 5, and 6 must be documented in the Limitations Section ofthe AFM: I. The airplane must not beoperated for hire oroffered for common carriage. This provision does not preclude the operator from receiving remuneration to the extent consistent with 14 CFRparts 125 and 91, subpart F, as applicable. 2. Each door betweenpassengercompartments mustbe frangible from both sides. A placard describing the frangibility procedure must be installed in a conspicuous location onboth sides ofthe door. 

### 6• . ' II

3. Doors that fall into Category I must be latched in the open position duringtaxi, takeoff, and landing when the room is occupied. A placard requiring the door to be in the open position must be installed in a conspicuous position on both sides ofthe door. 4. Doors that fall into Categories 2, 3, or4 must be latched in the open position during taxi, takeoff, and landing, regardless ofoccupancy ofthe room. A placard requiring the door to be in the open position must be installed in a conspicuous position on both sides ofthe door. 

### 5. Doors that fall into Category 5 must be in the closed position during taxi, takeoff, and landing. A placard requiring the door to be in the closed position, and requiring the room to be vacant, must be installed in a conspicuous position on both sides ofthe door. 6. Appropriate procedures must be established to both signal the flightcrew in the event a doorbetween passenger compartments is not in the properposition, and prohibit taxi, takeoff, or landing. Doors in Category 5 do not need to comply with this requirement. For Category 5 doors, placards located on ornear the door, indicating that the door must be closed and the room must be vacant for taxi, takeoff, and landing, are acceptable. 7. Doors between passenger compartments must have dual means to retain them in the open position. Each means must be capable ofwithstanding the inertia loads specified in §25.561. Doors in Category 5 do not need to comply with this requirement because they are required to be closed for taxi, takeoff, and landing. Issued in Renton Washington, on 

## DEC 27 lOU

# ~KC

# l**\tu(l~ur\-tk**\0- K. C. Yartlmura Acting Manager, Transport Airplane Directorate Aircraft Certification Service



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