Enclosure t o Gree npoint letter dated, March 13 , 2015

RE: Petition for Exemption from 14 CFR Part 25 § § 25.807 (f)(4) and SFAR 109 7(a) Page 1 of 4

A. Name and Address of the Petitioner

B arbara 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 Regu lations (CFR ) that are Affected

As provided for in § 11.61(b), Greenpoint hereby petitions for exem ption from the following 14 Code of Federal Regulation (CFR) §§ f or 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.

S FAR109 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 S pecial

F ederal A viation R egulation (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) Page 2 of 4

More specif ically, Greenpoint requests that the requirement for d istance to the exit s for

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

r ight side o f 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 o f 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 aircra ft 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 Indu stry. 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 d epend on potential customers worldwide finding the US certification process dependable and reasonable, so alternate requirements that provide an acceptable level of safety is desirable.

 G ranting of exemptions that meet the unique needs of the VIP modifier foster s the US aviation industry.

E. Statement of No Adverse Effect on Safety

T he FAA has made adjustments to regulatory requirements based on specific design and operational factor s numerou s 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

e xemption will have n o adverse impact on safety for the following reasons:

 Relief to the dist ance criterion for the 4 seats as proposed maintains the spirit of the original requ irement

, § 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 position s

, and access to the exits for the project airplane effectively eliminates crowding for the affected passengers which w ould delay evacuation and is the basis, in part, for the requirement.

 The request is an alternative approach to the 60 foot rule not consi dered previously by the FAA which maintains the intent of the a lternat ive 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) Page 3 of 4

F. Public Summary

Gree npoint Technologies requests partial exemption from § 25.807(f)(4 ) and SFAR 109 Paragraph 7 (a) for a 787

- 8 airplane . The 78 7

- 8 aircraft is intende d to be a VIP executive airplane including deactivation of the Door 2 right hand exit

. T his 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 cert ify an execut ive interior in a Boeing Model 78 7

- 8 per customer specifications. Supplemental Type C ertification is sought un der FAA project #

ST12319 SE

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

Sheet T00021SE and includes 14 CFR 25 through Amendment 25

- 120 and higher Amendments for certain regulations as contained in t he 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 loung e

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

aft half the Door 3 area

. Th e Door 2 Right has been deactivate d by means of an FAA

approv ed Boeing Service Bulletin to accommodate the bedroom area. Maximum

passe nger 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 c ommercial type areas of the cabin aft of

Door 3

.

The airplane wi ll 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 d esign certification requirements for transport category airplanes. SFAR 109 amended these standards for transport categ ory 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 theseEnclosure 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) Page 4 of 4

alternate standards is planned except that for the alternate requirement of SFAR 109 7(a) for the 4 seats in the l ounge for which relief is requeste d.

SFAR 109 paragraph 7 was issued as an alternative criterion to the 60 foot rule to be consistent with FAA polic y and to maintain the intent of § 25.807(f)(4) while als o 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 o r 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 . H owever, the seats are insta lled within 37 feet of exits on the

r ight and left side at Door 3, and 21 feet of the remaining exit on the l eft 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 a t 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 reques ts that the privileges of

this e xemption 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.