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, such 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 

Enclosure to RA-12-04846 

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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 through 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 delayed 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 the 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 blocking egress path, even when subjected to 

emergency landing loads. 

Boeing submits that replacing conventional seats with 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-suites 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 would 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 operators 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 model airplanes and those intended for 747-8 have 

partial height doors and walls, and meet the design pre-requisites outlined below. As such, 

these mini suites are not designed to create a completely isolated compartment for the 

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occupant and they incorporate systems and procedures that will ensure that the occupant can 

operate and exit the mini-suites safely in all conditions. 

Partial height walls and doors allow the occupant a level of recognition and observation of 

what is going on around the cabin from within the suite. Attendants are also able to recognize 

and observe the suites when performing their 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 egress such that either egress path can accommodate 

both a 5th percentile female and a 95th percentile 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 facilitating 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 secondary 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 will 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 door(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 occupant 

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during 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 substantiated by a demonstration. 

E. Statement of Public Interest 

Sale of Boeing commercial airplanes greatly contribute 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 install and certify mini-suites with doors in 747-8 

premium cabins significantly improves its marketability, thus leading to increased sales 

supporting a positive balance-of-trade and gross domestic product. 

The petition for exemption is in essence an alternative method of achieving an appropriate 

level 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 requesting 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 their 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 foreign aircraft manufacturers in this market. 

Further, the public will benefit from the lower cost of travel when the operators increase their 

revenue and reduce their operating costs. 

A majority of the flying public 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 passengers can be met. One of the most popular 

configurations requested by a wide array of operators 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 beyond 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 operating 

Enclosure to RA-12-04846 

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efficiencies 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 models 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 mini-suite features and evacuation methods across 

their fleet of airplanes. The ability to offer 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 safety 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 market 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 United 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 Washington 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 conditions 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 configured with mini-suites. By maintaining a 

consistent cabin configuration and flight attendant 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-suite configurations described 

in section D above will prevent the risk of passenger entrapment behind a door jammed, due 

to mechanical failure or omission to control, 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. 

Enclosure to RA-12-04846 

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G. Summary of Petition 

In response to a customer request, Boeing Commercial Airplanes requests exemption from 14 

CFR 25.813(e), Amendment 25-116, doors between 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 compromised 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 development 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 Exemption 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 privileges 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 transport category aircraft. The 747-8 is intended 

for the global market place. 

Enclosure to RA-12-04846 

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