Enclosure to Greenpoint letter dated, March 13, 2015

RE: Petition for Exemption from 14 CFR Part 25 §§ 25.807(f)(4) and SFAR 109 7(a)

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A. Name and Address of the Petitioner

Barbara Baillie, Senior Certification Engineer

Greenpoint Technologies, Inc.

4600 Carillon Point

Kirkland, Washington 98033

Ph: 425-739-7877

Email: bbaillie@greenpnt.com

B. Section of the Code of Federal Regulations (CFR) that are Affected

As provided for in §11.61(b), Greenpoint hereby petitions for exemption from the 

following 14 Code of Federal Regulation (CFR) §§ for a Boeing Model 787-8 airplane, 

serial number 35309:

Regulation Amendment Requirement

25.807(f)(4) 25-114 For an airplane that is required to have more than one 

passenger emergency exit for each side of the fuselage, no 

passenger emergency exit shall 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.

SFAR109 

7(a)

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. 

C. Extent of and Reason for Relief Being Sought

Greenpoint requests relief from the distance between exit requirements of Special 

Federal Aviation Regulation (SFAR) 109 Paragraph 7(a) for the 4 seats located in the 

lounge area of a VIP interior installation on a Boeing Model 787-8 airplane, S/N 35309, 

operated for “private, not-for-hire, not-for-common carriage.” 
Enclosure to Greenpoint letter dated, March 13, 2015

RE: Petition for Exemption from 14 CFR Part 25 §§ 25.807(f)(4) and SFAR 109 7(a)

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More specifically, Greenpoint requests that the requirement for distance to the exits for 

the 4 forward most seats in the lounge area be increased from 30 feet to 37 feet on the 

right side of the airplane. To partially compensate for this increase in distance, 

Greenpoint proposes a decrease in the distance to the exit on the left side of the 

airplane for these same seats from 30 feet to 21 feet. This alternative requirement to 

SFAR 109 7(a) is necessary due to deactivation of the Door 2 right hand.

D. Statement of Public Interest

Granting this partial exemption would be in the public interest for the following reasons:

 VIP aircraft are used by Heads-of-State and Diplomatic Persons. Developing and 

maintaining positive relations with the operators of these aircraft benefits the US 

economy in terms of trade and balance of power;

 The use of US design and manufacture of aircraft and interiors such as this one 

develops and maintains the worldwide positive image and influence currently 

enjoyed by the US Aerospace Industry. Consistency in regulations and design 

requirements at and after contract award affects competitiveness and significant 

changes after the time of contract places the US industry in a significantly lowered 

position to foreign industry. Future sales depend on potential customers worldwide 

finding the US certification process dependable and reasonable, so alternate 

requirements that provide an acceptable level of safety is desirable.

 Granting of exemptions that meet the unique needs of the VIP modifier fosters the 

US aviation industry.

E. Statement of No Adverse Effect on Safety

The FAA has made adjustments to regulatory requirements based on specific design 

and operational factors numerous times in the past. Additionally, SFAR 109 provides 

alternative criteria for transport category airplanes that are operated for private use 

while continuing to provide an acceptable level of safety for those operations. This

exemption will have no adverse impact on safety for the following reasons:

 Relief to the distance criterion for the 4 seats as proposed maintains the spirit of the 

original requirement, § 25.807(f)(4), and more specifically to the SFAR 109 alternate 

criteria of paragraph 7(a), because the limited capacity of the room, the seat 

positions, and access to the exits for the project airplane effectively eliminates

crowding for the affected passengers which would delay evacuation and is the basis, 

in part, for the requirement.

 The request is an alternative approach to the 60 foot rule not considered previously 

by the FAA which maintains the intent of the alternative included in SFAR 109, while 

taking into consideration the project airplane’s unique layout.
Enclosure to Greenpoint letter dated, March 13, 2015

RE: Petition for Exemption from 14 CFR Part 25 §§ 25.807(f)(4) and SFAR 109 7(a)

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F. Public Summary

Greenpoint Technologies requests partial exemption from § 25.807(f)(4) and SFAR 109 

Paragraph 7(a) for a 787-8 airplane. The 787-8 aircraft is intended to be a VIP executive 

airplane including deactivation of the Door 2 right hand exit. This request is necessary 

in order to certify the desired aircraft configuration for the end customer. 

G. Background and Supportive Information

The Boeing Model 787-8 project airplane is intended to be a VIP executive aircraft; 

modified under United States registration (N28MS). Greenpoint is contracted to design, 

install and certify an executive interior in a Boeing Model 787-8 per customer 

specifications. Supplemental Type Certification is sought under FAA project # 

ST12319SE-T. The certification basis for the project is defined in Type Certificate Data 

Sheet T00021SE and includes 14 CFR 25 through Amendment 25-120 and higher 

Amendments for certain regulations as contained in the Project Specific Certification

Plan, Greenpoint Document G1350-CP-01, Revision D, dated January 23, 2015, and

accepted by FAA Letter 150S-15-20, dated February 4, 2015. Voluntary compliance to 

the requirements contained in SFAR 109 has been elected.

The airplane was delivered from Boeing in a zero passenger configuration with a valid 

FAA Certificate of Airworthiness. The proposed interior installation includes a pilot 

lounge just aft of the flight deck, a bedroom including closet and lavatory, a passenger 

lounge, conference, and lavatory areas, as well as traditional commercial type seating

aft half the Door 3 area. The Door 2 Right has been deactivated by means of an FAA 

approved Boeing Service Bulletin to accommodate the bedroom area. Maximum 

passenger count will be limited to 40 occupants for taxi, takeoff or landing (TTOL): 4

seats certified for TTOL in the lounge, 12 seats certified for TTOL in the conference 

area, and 24 seats certified for TTOL in the commercial type areas of the cabin aft of 

Door 3. 

The airplane will be operated as a private use, not for hire, not for common carriage 

airplane. These types of VIP interiors require a high level of privacy and security that is 

normally not available in airline-style interiors. This results in increased focus on 

maintaining control and safety of the occupants as well as greater understanding and 

general awareness by the occupants of the safety risks and existing design features in 

the interior that mitigate these. 

14 CFR part 25 governs type design certification requirements for transport category 

airplanes. SFAR 109 amended these standards for transport category airplanes by 

adding new interior criteria for operators of private use, not for hire, not for common 

carriage airplanes such as the project airplane. The SFAR provides alternative criteria 

for transport category airplane that are operated for private use while continuing to 

provide an acceptable level of safety for those operations. Certification to these 
Enclosure to Greenpoint letter dated, March 13, 2015

RE: Petition for Exemption from 14 CFR Part 25 §§ 25.807(f)(4) and SFAR 109 7(a)

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alternate standards is planned except that for the alternate requirement of SFAR 109 

7(a) for the 4 seats in the lounge for which relief is requested. 

SFAR 109 paragraph 7 was issued as an alternative criterion to the 60 foot rule to be 

consistent with FAA policy and to maintain the intent of § 25.807(f)(4) while also 

allowing deactivation of exits that is common in VIP interior installations. In coming up 

with the specific requirement that a maximum of 30 feet is allowed between a 

passenger seat and exits on both sides of the airplane, the FAA has stated there were 

different approaches that would have been possible, but none were considered or 

allowed for in the final rule. Given that VIP interiors vary greatly in terms of passenger 

capacity and layout, it is reasonable that a different approach to meet the intent of this 

one aspect of the alternative criterion found in SFAR 109 is feasible. 

The project airplane is a unique interior with a 40 passenger capacity in which 4 of the 

seats are installed a few feet beyond the 30 foot distance to an exit on one side of 

airplane only. These 4 seats are 4 of only 16 seats to be certified for TTOL in this 

compartment. This compartment is the only one with seats certified for TTOL forward of 

Door 3 on the airplane. The seats are situated in the forward section of the 

compartment on a main aisle with a direct path to exits in 2 directions. Deactivation of 

the Door 2 right side exit is the reason these seats fall outside strict compliance to the 

SFAR 109 7(a) criteria. However, the seats are installed within 37 feet of exits on the 

right and left side at Door 3, and 21 feet of the remaining exit on the left side of the 

airplane at Door 2. There are only 12 other passengers in this compartment that would 

be competing for these 3 exits in an emergency egress situation. The remaining 24 

passengers will be seated aft of the Door 3 area with access to exits at Doors 3 and 4 

on both sides of the airplane. Given the limited capacity, and access to the exits for this 

particular VIP layout, an alternative approach than is offered by existing SFAR 109

paragraph 7(a) for the 60 foot rule is reasonable and maintains the original intent of the 

rule when applied to this VIP interior. 

H. Privilege of this Exemption Outside the United States

In accordance with §11.81(h), Greenpoint Technologies requests that the privileges of 

this exemption be extended outside of the United States. This extension of privileges is 

necessary because the project airplane will be operated a substantial amount time 

outside the US.