### A. Name and Address of the Petitioner

Doug Lane, Director, Regulatory Administration Deputy Lead Administrator The Boeing Company

P.O. Box 3707 Seattle, Washington, 98124



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

As provided for in §11.61(b), Boeing hereby petitions for exemption from the following 14

CFR for the models 747-8:

Regulation Amendment Requirement 25.813(e) 25-116 “No door may be installed between any passenger seat that is occupiable for takeoff and landing and any passenger emergency exit, su ch that the door crosses any egress path (including aisles, cross-aisles and passageways).”



### C. The Extent of Relief Being Sought

Regulation Requirement Why relief is necessary 25.813(e) at

Amdt 25-

116 No door may

be installed between any
passenger seat
that is occupiable for

takeoff and landing and

any passenger

emergency exit. Operators are requesting Boeing to install premium mini-suite systems in a cabin of Boeing 747-8. A typical mini-suite consists of a seat, an ottoman, and personal stowage units. To provide additional comfort, convenience and care for the passenger, every seat is surrounded by partial height partitions and sliding

doors.

Doors, being of great value to the occupants of such seat systems by providing the impression of privacy, are integral to this configuration.

The proposed configuration will therefore not comply with the requirement of 14 CFR 25.813(e).

Description of relief sought: Boeing respectfully requests that the FAA grant an exemption for doors installed in mini-suites solely to allow installation of

mini-suites in 747-8 aircraft.

If granted Boeing would apply this exemption to 747-8 aircraft configured with premium mini-suite interiors meeting the technical and procedural conditions set forth in paragraph D

of this document

### D. Description of the Issue

NPRM No. 96-9 states the following as the rationale for imposing 14CFR 25.813(e) :

“ ...door could be detrimental in evacuation of passengers, who tended not to recognize that there was an exit beyond the door, even if it were the closest available.”

It is now considered undesirable to permit the installation of a door between any passenger and an exit. Should such a door (either throug h omission or mechanical failure) become jammed in the event of an emergency evacuation, persons could be prevented or delayed in evacuating which could result in fatalities or injuries that would not otherwise have occurred. The hazards associated with a jammed door are still present whether or not passengers are on both sides of the door, and the recognition factor has not been mitigated. Either could result in the same consequences--failure of some passengers to evacuate the airplane. ”

It is Boeing’s understanding that the primary intent of 14 CFR 25.813(e) is to protect passengers from being trapped or dela yed during an emergency egress.

Boeing postulates that 14CFR 25.813(e) limits the use of doors without giving consideration to systems that would eliminate the risk to th e occupant. For example, systems that would:

 Limit the number of occupants.

 Prevent formation of isolated compartments.

 Limit ambiguity by clearly recognizing emergency egress means.

 Provide alternate evacuation paths [from the occupant’s location].

 Provide redundant door retention mechanisms and controls.

 Inhibit the door from breaking loose and bloc king egress path, even when subjected to emergency landing loads.

Boeing submits that replacing conventional seats w ith mini-suites in a cabin will considerably reduce the number of occupants, which inherently improves the safety. This has been acknowledged by the FAA in PS05-0272-C-1, as “ Installation of mini-suites...reduces the occupancy in a given area by a factor of 6. All other things being equal, the reduction in the total number of occupants in a given part of the cabin is an enhancement to safety ”.

It is envisioned that 747-8 would have mini-su ites installed in various typical premium zones of the airplane. With mini-suites installed, the occupancy would be a maximum of 8, 12 or 20 for each of these premium zones in the airplane. Occupancy in these same premium zones based on typical first and business class layouts w ould be 12-16, 20-32, or 38-42 respectively. The total number of mini-suites installed on a single 747-8 is not expected to exceed 20.

Further, granting of numerous exemptions to ope rators of executive aircraft is evidence that the FAA recognizes that the regulation was written with areas of high occupancy to exit ratio

in mind. Executive aircraft, which are not for hire or common carriage, typically carry lower number of occupants and in granting these exemptions, the FAA has allowed installation of doors that completely separate cabin zones thus creating isolated compartments.

Mini-suites currently in service on other mode l airplanes and those intended for 747-8 have partial height doors and walls, and meet the d esign pre-requisites outlined below. As such, these mini suites are not designed to create a completely isolated compartment for theoccupant and they incorporate systems and proce dures that will ensure that the occupant can operate and exit the mini-suites safely in all conditions.

Partial height walls and doors allow the occ upant a level of recognition and observation of what is going on around the cabin from within th e suite. Attendants are also able to recognize and observe the suites when performing th eir duties. The mini-suites’ design and configuration will allow an occupant to exit the suite regardless of the door(s) position.

i. Conditions as Pre-requisite for Installing Mini-suites

The operator will allocate an additional flight attendant, above the minimum required by the applicable operating rules, whose principle duty is to ensure the mini-suite doors are “latched” in open position for taxi, takeoff and landing.

The mini-suites shall have the following features: 1. Each mini-suite provides accommodation for one single occupant for taxi, takeoff and landing. 2. Mini-suite entrance will not provide access to any other mini-suite. 3. Mini-suite or any of its features will not create any obstruction to the main aisles, interfere with, or divert evacuating passengers from any part of the cabin. 4. Mini-suites will not provide an egress path for evacuation other than the path out of the mini-suite for its single occupant. 5. Mini-suite shall have dual means of egr ess such that either egress path can accommodate both a 5th percentile female and a 95th percen tile male. One such means, but not the only means, of an egress path is the installation of a pair of sliding doors in the mini-suite

entrance. The doors must translate such that in the unlikely event of retention mechanism failure, inertial loads that tend to force one door in the closed position act to force the opposite door to the open position, thus f acilitating an open egress path at all times. 6. Mini-suite door(s) will not reduce main aisle width below 14 CFR 25.815 requirements in open, closed or translating position. 7. Mini-suite door(s) will not cross any main aisle, cross-aisle or passageway. 8. Mini-suite door(s) will not impede main aisle egress in open, closed or translating position. 9. Mini-suite door(s) can be opened even with a crowded aisle. 10. It will not be possible to latch or lock the doors together in closed position. 11. Mini-suite door(s) will be locked in open position for taxi, takeoff and landing. 12. Each mini-suite will have a placard, or marking, instructing the occupant that door(s) must be locked in open position during taxi, takeoff and landing. 13. Each door will have a primary and a sec ondary retention mechanism. Each individual mechanism will independently be capable of holding the door open under 14 CFR 25.561(b) emergency landing conditions. 14. Secondary retention mechanism control w ill be positioned such that a seated and belted occupant would not be able to operate it. 15. If doors are mechanically operated, a. Both primary and secondary retention mechanisms will be engaged during taxi, takeoff and landing. 16. If doors are electrically operated,

a. The mechanism will maintain the doo r(s) in open position even after power loss. b. Once opened for taxi, takeoff and landing, door(s) operation will be disabled by a

deactivation switch. c. Deactivation switch operation cannot be overridden by the mini-suite occupantduring taxi, takeoff and landing. 17. Mini-suite doors can manually be opened, regardless of power failure condition, from

inside or outside with a maximum force of 25 lbs. 18. Boeing will show that even if all retention mechanisms fail and door(s) close and jam, a 95th percentile male and a 5th percentile female can still exit the mini-suite without

additional assistance. This will be s ubstantiated by a demonstration.



### E. Statement of Public Interest

Sale of Boeing commercial airplanes greatly co ntribute to the balance-of-trade, the gross domestic product and economic health of the United States.

As with most other wide-body aircraft, the 747-8 is to be used primarily on long-haul routes. On flights lasting upwards of 14 hours, operators desire to provide the traveling public with a very high level of comfort and care, and the ability to install mini-suites with doors is an integral part of that goal.

At this time 100% of 747-8s are sold to foreign operators, of which at least 80% are operators offering premium cabins. The ability to insta ll and certify mini-suites with doors in 747-8 premium cabins significantly improves its mark etability, thus leading to increased sales supporting a positive balance-of-tra de and gross domestic product.

The petition for exemption is in essence an alternative method of achieving an appropriatelevel of safety, while at the same time providing features attractive to the operators. Minisuites installed on commercial aircraft are being requested by an increasing number of aircraft operators. Many of the operators who are requ esting this type of interior configuration already have other aircraft with mini-suites in their fleet. These customers want a consistent cabin operation and passenger experience across thei r fleet, and will continue to require that new additions to their fleet include mini-suites with doors. If they cannot obtain mini-suites on 747-8 aircraft, they will order aircraft from foreign manufacturers. This results in:

 lost opportunity to sell Boeing aircraft thus reducing the balance-of-trade, the gross domestic product and economic health of the United States.

 creating an unfair competitive advantage to fore ign aircraft manufacturers in this market.

Further, the public will benefit from the lower co st of travel when the operators increase their revenue and reduce their operating costs.

A majority of the flying pub lic will see benefit from lower ticket prices. Very often, premium class passengers will pay for a very high level of comfort and care on long-haul flights. Accordingly, aircraft operators strongly prefer to configure their cabins in such a way that the special needs of these premium class passenge rs can be met. One of the most popular configurations requested by a wide array of oper ators is mini-suites with doors. The ability to offer mini-suites with doors as part of the passenger experience allows the operators to generate additional revenue be yond that which would be available with more conventional seat solutions, allowing the opportunity to further reduce the cost of economy class travel. [Premium cabin seats account for 40-60% of an operator’s revenue compared with 15-27% of total number of seats per flight. Source: NY Times 11/20/2011].

Allowing installation of mini-suites on 747-8s will result in the operators choosing the 747-8 over other similar sized aircraft, thus allowing the operators to take advantage of operatingefficiencies and reduced fuel consumption of 747- 8. The cost savings achieved will in turn be passed on to the passengers in decreasing or maintaining airline ticket price levels.

In addition, the airlines will be able to keep operating costs down by having common training and operating procedures within their fleet. Many 747-8 operators that are requesting minisuites also operate fleets of other airplane m odels which include mini-suites. The most cost effective manner of operating these aircraft is to have consistent mini-suites designs and flight attendant training with respect to mi ni-suite features and evacuation methods across their fleet of airplanes. The ability to offe r mini-suites on the 747-8 coupled with the efficiency gains, makes the 747-8 the airplane of choice for its market segment.

Grant of Exemption as requested in this petition is in the best interest of the travelling public through introduction of this new product, which has an advanced certification basis, into the marketplace. Enabling common operating procedures across a fleet not only keeps operating cost down as noted above, but avoids the potential for human error that may be introduced when procedures vary substantially for similar products. For the reasons noted above, it is the petitioner’s opinion that the overall level of safet y is improved which is in the public’s best

interest.

In summary, allowing mini-suites to be installed on 747-8 aircraft will level the competitive field, and open a larger and more profitable ma rket to the Boeing company and its customers. Granting the Exemption expands Boeing’s sales, which benefits balance-of-trade, the gross domestic product and economic health of the Unite d States.. This serves the public interest by serving economic interests of the United States in general, and welfare of residents, employment and improved tax revenues of Washingt on State in particular. In addition, 747-8 aircraft with mini-suites improves operators’ economic health, which ultimately benefits the flying public, with no compromise to their safety.



### F. Statement of No Adverse Effect on Safety

Boeing strives to provide acceptable safety cond itions so that its 747-8 operators can safely operate their airplane with interior configurations and evacuation procedures consistent with

their current fleets.

A grant of Exemption will allow consistent procedures across an operator’s fleet thus maintaining safety. Many 747-8 operators that are requesting mini-suites also operate fleets of other airplane models with premium cabins c onfigured with mini-suites. By maintaining a consistent cabin configuration and flight a ttendant training across their fleet, each operator can provide the safest, most effective and economical manner to ensure safety of all

occupants.

Further, additional systems and personnel employed for mini-su ite configurations described in section D above will prevent the risk of p assenger entrapment behind a door jammed, due

to mechanical failure or omission to c ontrol, during an emergency evacuation.

These systems and procedures will ensure that the mini-suite doors will be, and remain, open for taxi, takeoff and landing such that the safe evacuation of any occupant will not be compromised in any way owing to the existence of doors.

### G. Summary of Petition

In response to a customer request, Boeing Co mmercial Airplanes requests exemption from 14 CFR 25.813(e), Amendment 25-116, doors betw een passenger compartments, for the sole purpose of installing mini-suite seating systems in premium cabin zone of 747-8 airplanes.

The design and configuration of the mini-suites will be governed such that the safe evacuation of occupant shall not be compromise d in any way owing to the existence of the

doors.



## H. Request for Reduced Public Comment Period

As the first mini-suite configured 747-8 is intended to be placed in service in mid-2014 (minisuites, typically, have a 22 months deve lopment flow) and this exemption being based on previously approved Boeing 777 ELOS (PS05-0272), Boeing respectfully requests that the public comment period be kept as short as permissible.



## I. Privileges of this Exempt ion Outside the United States

Per § 11.81(h), Boeing requests that the privileges of this Exemption be extended outside of the United States. This extension of privile ges is necessary for operations based within foreign countries having bilateral agreements with the United States accepting FAA 14 CFR

Part 25 as their airworthiness standards for tran sport category aircraft. The 747-8 is intended for the global market place.