UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

Exemption No. 16838 

Textron Aviation Inc. Regulatory Docket No. FAA-2016-4919 

for an exemption from § 25.809(a) of 

Title 14, Code ofFederal Regulations 

GRANT OF EXEMPTION 

By letter dated March 7, 2016, Mr. Brian Richardet, Product Safety and Certification Manager, 

Textron Aviation Inc., One Cessna Boulevard, Wichita, Kansas, 67215, petitioned the Federal 

Aviation Administration (FAA) for an exemption from the requirements of§ 25.809(a) of Title 

14, Code of Federal Regulations (14 CFR). This exemption, if granted, would permit relief from 

the requirement for a means to permit viewing of the likely areas of evacuee ground contact prior 

to opening the overwing exit on Textron Aviation Inc., Model 700 airplanes. 

The petitioner requests partial relief from the following regulation: 

Section 25.809(a), at Amendment 25-116- Each emergency exit, including each 

flightcrew emergency exit, must be a moveable door or hatch in the external walls of the 

fuselage, allowing an unobstructed opening to the outside. In addition, each emergency 

exit must have means to permit viewing of the conditions outside the exit when the exit is 

closed. The viewing means may be on or adjacent to the exit provided no obstructions 

exist between the exit and the viewing means. Means must also be provided to permit 

viewing of the likely areas of evacuee ground contact. The likely areas of evacuee ground 

contact must be viewable during all lighting conditions with the landing gear extended as 

well as in all conditions of landing gear collapse. 

The petitioner supports its request with the following information: 

This section quotes the relevant information from the petitioner's request, with minor edits for 

clarity. The complete petition is available at the Department of Transportation's Federal Docket 

Management System, on the Internet at http://regulations.gov, in Docket No. F AA-2016-4919. 
Background 

The Textron Aviation Inc. (Textron Aviation) Model 700 is an executive jet with capacity 

for a maximum of 12 passengers and 2 crewmembers. The overwing exit is a Type III 

exit. It is located on the right hand side of the cabin over the wing. The overwing exit 

has a window that provides a means to permit viewing of the conditions outside the exit 

when the exit is closed. However, from the location of the overwing exit it is not possible 

to view the likely areas of evacuee ground contact with the landing gear extended as well 

as in all conditions of landing gear collapse. 

Extent of Relief Requested 

Partial relief is requested for 14 CFR 25.809(a). Relief is requested from the requirement 

for a means to permit viewing of the likely areas of evacuee ground contact prior to 

opening the overwing exit. The nature of this petition for partial exemption is similar to 

the previously granted Exemption 10756 for the Learjet Model LJ200, Exemption 10757 

for the Embraer Model EMB-550, and Exemption 11350 for the Textron Aviation Model 

680A. 

Public Interest 

Textron Aviation competes in the global market. This aircraft is a needed expansion to 

the Textron Aviation line of executive jets to compete in this market. The production of 

this aircraft will provide much needed jobs in today's environment. The added interface 

required to place the right hand exit in an area where the likely area of evacuee ground 

contact is viewable with the landing gear extended and in all conditions of landing gear 

collapse would limit interior arrangement of seating and adversely affect the customer. 

Effect on Safety 

In order to provide an exit that would allow viewing the likely area of evacuee ground 

contact with the landing gear extended, as well as in all conditions of landing gear 

collapse, the exit would need to be moved forward in the cabin. This would mean that 

the exit would either be located on the very leading edge of the wing or off of the wing. 

For the best safety ofthe passengers, the current location of the exit on the right hand side 

of the cabin over the wing is the best location. The current design allows the passengers 

visibility of the area outside the overwing exit to assess the immediate danger. Once out 

of the aircraft and on the wing, the passenger can view in all directions, assessing the best 

route to leave the wing. Thus, the granting of this exemption would not adversely affect 

safety of egress. 

Federal Register publication 

The FAA has determined that good cause exists for waiving the requirement for Federal Register 

publication for public comment because the request is identical in all material respects to 

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previously granted exemptions; the exemption, if granted, would not set a precedent; and any 

delay in acting on this petition would be detrimental to Textron Aviation. 

The FAA's analysis 

The FAA reviewed the information provided by Textron Aviation and concluded that granting 

this exemption is in the public interest for the reasons discussed below. The FAA determined 

there is no adverse impact on safety if an occupant cannot simultaneously see conditions 

immediately outside the exit door and the ground contact point under all lighting and landing 

gear conditions. The impact of the regulation, as codified, went beyond what was envisioned in 

the rulemaking process for the overwing exits on some airplanes. 

Overwing Exits: 

On many overwing exits, the location where evacuees first make contact with the ground is a 

considerable distance from the point where they exit the passenger cabin. The distance the 

evacuees would need to move, either forward or aft on the upper wing surface, and down to the 

ground by escape slide or jumping off the wing (or sliding down the leading or trailing edge of 

the wing) makes it difficult or impossible to see the ground contact point from inside the airplane 

due to the distance or the wing itself blocking the view. Some commenters to the notice of 

proposed rulemaking for§ 25.809(a) (Notice No. 96-9) made this point, and the FAA's response 

was: 

With respect to the potential for the exit to be somewhat remote from the point where the 

evacuees would contact the ground, the FAA agrees that this may be the case. The intent 

of the requirement is to enable a person to ascertain whether to open an exit, and whether 

it is safe to evacuate through the exit, based on an assessment of the outside conditions. 

To the extent that the means used for determination of the former does not also allow an 

assessment ofthe ground, the FAA agrees that an additional viewing means may be 

necessary, and that the additional means may be somewhat remote from the exit. We 

have therefore reworded the amendment to allow for the dual purpose of the viewing 

means, and to distinguish the required locations of the two. 

Our intent in this rule was that it is not necessary for a person to be able to view the ground 

contact point while in position to open an overwing exit. The rule itself refers to the ground 

contact view separately from the view of conditions outside the exit, but the intent of the rule was 

not clearly expressed in the rule language. The FAA worked with the European Aviation Safety 

Agency (EASA) to improve the rule language, based on our experience applying this rule. 

EASA incorporated the improved language in their certification specifications (CS) at 

Amendment 25/12, dated July 13, 2012. CS 25.809(a)(3) states: 

For non-over-wing passenger emergency exits, a means must also be provided to permit 

viewing ofthe likely areas of evacuee ground contact when the exit is closed with the 

landing gears extended or in any condition of collapse. Furthermore, the likely areas of 

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evacuee ground contact must be viewable with the exit closed during all ambient lighting 

conditions when all landing gears are extended. 

The FAA is considering rulemaking to harmonize this requirement with EASA. 

The proposed configuration provides a level of safety consistent with the intent of the rule. The 

window allows an outside view to assess the conditions outside prior to opening the exit. The 

evacuees can then open the exit and step out onto the wing and move along the wing to assess the 

conditions where they would make first contact with the ground. At that point, ifthe conditions 

were not acceptable, evacuees would search for another location from which to exit off of the 

wing. To enforce literal compliance that is more stringent than our original intent for the rule 

would result in an unnecessary burden on the petitioner. 

The FAA's decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701 delegated to me by 

the Administrator, I grant Textron Aviation an exemption from 14 CFR 25.809(a). The 

exemption is granted to the extent necessary to allow Textron Aviation to partially comply with 

the outside viewing requirements for the overwing exits. Specifically, the exemption allows 

viewing the first point of contact with the ground after the exit has been opened and the evacuee 

is on the upper surface ofthe wing on Textron Aviation Model 700 airplanes. Textron Aviation 

must demonstrate compliance with all other requirements of 14 CFR 25.809(a) at Amendment 

25-116 for this airplane. 

Issued in Renton, Washington, on JUN 15 2016 

Dionne Palermo 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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