Transport Airplane Directorate

1601 Lind Avenue, S.W.

Renton, Washington 98057-3356

7 March 2013

Y. Regis

Head of Product Integrity

Airbus

1 Rond-Point Maurice Bellonte

31707 Blagnac Cedex, France 31707

Dear Mr. Regis:

We received your petition (M13003411) dated 11 February 2013, on behalf of Airbus, 

requesting exemption from Title 14, Code of Federal Regulations (14 CFR) 25.813(e) at 

Amendment 25-116 and 14 CFR 121.310(f)(6). You requested this exemption to install 

“mini-suites” in the Airbus Model A321 for Jet Blue Airlines, a U.S. operator.

This request, which you submitted to the Department of Transportation’s Federal Docket 

Management System, has been given Docket No. FAA-2013-0189. 

We have reviewed your petition and have determined that more information is needed 

before we can process it. Please resubmit your petition addressing the following issues to 

the Federal Docket Management System Docket No. FAA-2013-0189. 

1. The petition requests exemption from § 25.813(e) at Amendment 25-116. The 

correct Amendment level of this regulation for the Airbus Model A321 is 

Amendment 25-46 as shown in Type Certificate Data Sheet No. A28NM. The 

requirements of § 121.310(f)(6) do not affect the Amendment level of § 25.813 in 

the certification basis for the airplane. Airbus will need an exemption from 

§ 25.813(e) at Amendment 25-46 to support installation of the mini suites. Please 

revise your request accordingly.

2. The petition requests exemption from § 121.310(f)(6). An exemption from 

§ 121.310(f)(5) is also required. Please revise your request accordingly.

3. Please provide a plan view of the proposed aircraft interior arrangement and side 

views of the mini-suites when viewed from inside and outside the suites.

4. Item 13 of the “Supporting Argumentations” section notes a second path out of the 

mini-suite is provided. Please describe this second path.

5. The “Supporting Argumentations” section states, in part, “...the design precautions 

implemented on these mini-suites are in line with the ones certified on previous 
2

mini-suite installations.” And a note on the last page states, “Similar exemption has 

already been granted for very similar mini-suite installations. See Boeing 777 ELOS 

(PS05-0272).” With regard to the Boeing 777 equivalent level of safety (ELOS) 

findings, an additional flight attendant, above the minimum required by the operating 

rules, was also required. The additional flight attendant’s principal duty is to ensure 

the mini-suite doors are “latched” in the open position for taxi, takeoff, and landing. 

Please revise the request accordingly.

6. Item 21 of the “Supporting Argumentations” section notes the passenger seat 

modules will not exceed 25% of the maximum number of passenger seats allowed 

between the doors, as defined in the A321 type certification. We were unable to find 

the maximum number of passenger seats allowed between the doors by reviewing 

the type certificate data sheet. Please specify the maximum number of mini-suites to 

be installed between the fuselage doors.

7. The “Public Interest” section specifies why granting this exemption is in the interest 

of passengers and operators but not the public as a whole. Please revise the “Public 

Interest” statement accordingly.

When we receive the requested information, a summary of your petition will be published 

for comment in the Federal Register for a 20-day comment period, in accordance with the 

requirements of § 11.89. You will be advised of the agency’s decision on your petition as 

soon as possible after the comment period closes.

We also need to make you aware that the Transportation Security Administration (TSA) has 

required the removal of curtains that separate the different parts of the passenger cabins 

because of security concerns after the events of September 11, 2001. TSA has allowed 

curtains that separate the galley area from the passenger area. One of the reasons they allow 

these curtains is that crew members occupy the galley area and not passengers. At this time 

it is unclear if TSA will accept the doors installed on these mini-suites.

If we do not hear from you within 30 days, we will close the project without notifying you 

further. In the meantime, if you have any questions or concerns regarding your petition or 

the petition process, please contact Dan Jacquet at 425-227-2676 or at 

daniel.jacquet@faa.gov.

Sincerely,

/s/

Suzanne Masterson

Manager, Airframe/Cabin Safety Branch, ANM-115

Transport Standards Staff

cc: European Aviation Safety Agency