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May 24, 2013

U.S. Department of Transportation

Docket Management Facility

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12-140

Washington, DC 20590

SUBJECT: Petition for Exemption from 14 CFR §25.785(h)(1) flight attendant direct 

view, §25.785(d) firm handhold, §25.791(a) no smoking placards, §25.813(e) doors 

between passenger compartments and §25.853(a)(1) maximum heat release rates for 

large panel cabin interior materials on an Airbus Model A330-200 airplane.

Ref: GDC ODA STC Project no. GDC-P579-STC

BACKGROUND:

Gore Design Completion, ltd. (GDC) has been contracted for the completion of an 

executive business interior in Airbus Model A330-200 airplane. The FAA Organization 

Management Team (OMT) is reviewing our ODA Project Number GDC-P579-STC for 

this project.

The certification basis of the Airbus A330-200 is 14 CFR Part 25, Amendments 25-1 

through 25-63, 25-65, 25-66, 25-68, 25-69, 25-73, 25-77, 25-78, 25-81, 25-82, 25-84 

and 25-85 with numerous special conditions and equivalent safety findings. Also 

amendment levels 25-64 and 25-72 are met with exceptions. 

There are good technical arguments to support special consideration for private use

airplanes: the airplanes are not for public hire and they are configured to carry a fraction 

of the passengers carried in airline service. For these reasons, Gore Design 

Completion, Ltd. has prepared a petition for exemption to the following regulations:

14 CFR §25.785(h)(1), Amendment 25-64 - Flight attendant seats must be 

located to provide direct view of the cabin area.

14 CFR §25.785(d), Amendment 25-64 - Requires a “firm handhold” along each 

aisle.
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14 CFR 25.791(a), Amendment 25-32 – Requires signs in the passenger cabin 

indicating when smoking is prohibited.

14 CFR 25.807(d)(7), Amendment 25-72 – Limits the distance between 

passenger emergency exits to sixty feet.

14 CFR §25.813(e), Amendment 25-46 - No door may be installed in any 

partition between passenger compartments.

14 CFR §25.853(a)(1), Amendment 25-66 - Limits maximum heat release rates 

for large panel cabin interior materials.

DISCUSSION:

14 CFR Part 25 governs design certification of transport category airplanes. The 

primary intent of these regulations, as written, are to be certain that airplane

manufacturers provide the appropriate design features to meet the standards necessary 

to protect the traveling public. Clearly, there is a requirement “in the public interest” and 

in the interest of safety to provide regulatory guidelines for certification. However, it is 

also very clear these regulations are intended to regulate the certification of 

“commercial” airplanes, which are “for hire” to the general public.

While the greatest majority of these regulations represent a common sense inclusion for 

any aircraft regardless of it’s intended use, a few are obviously intended to regulate 

situations that are specific to an airline, or for hire operation. When a transport category 

airplane is operated under 14 CFR Part 91 or Part 125, some of the Part 25 rules have 

acceptance criteria that are inappropriate, or are not compatible with the type of 

operation and the intended use of this airplane.

The FAA clearly recognizes these differences as evidenced by the issuance of 

Exemption numbers 6820A, 6822, 7120A, 7489, 9786 and numerous others which 

eliminate many of the more onerous regulations when applied to “private use, not-forhire” operations under 14 CFR Part 91 and Part 125.

BASIS FOR EXEMPTION:

The airplane that is the subject of this petition is an Airbus Model A330-200. It is 

privately owned and will be operated under Part 125 regulations or other equivalent 

non-US foreign national operational standard. In accordance with 14 CFR §11.81(h), 

we request to exercise the privilege of this exemption outside the United States since 

the operator of the airplane is located in Turkey.
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The interior configuration being installed in this airplane is planned to provide seating for 

ninety-eight (98) passengers (see attached floor plan drawing) for taxi, takeoff, and 

landing – 4 passengers in the office, 3 passengers in the conference room, and 91 

passengers in business class. There are an additional 10 seats in the lounge and six 

seats in the conference room that are not occupied for taxi, takeoff, and landing

The remaining seats in the cabin are to be occupied by crew only – three cabin 

attendants in the door 1 area, two cabin attendants in the door 3 area, and four cabin 

attendants in the door 4 area. Two additional crew seats are in the crew rest area. The 

maximum certified passenger count for this airplane is 375 seats for three pairs of Type 

A and one pair of Type 1 exits configuration. The passenger count of the subject 

airplane represents just 24% of the capacity allowed for this airplane.

Regulation 14 CFR §25.785(h)(1) 

Customers are buying these large airplanes as an extension of the office and are 

requiring privacy areas within the airplane sometimes spanning the whole cabin, such 

as board rooms, bedrooms, lavatories, and lounges rather than traditional airline type 

seating. An exemption to the flight attendant direct view requirement is therefore 

needed to allow the full use of the airplane capabilities. In addition, this requirement 

was incorporated into the FAA rules through amendment 25-51. Out of the comments 

submitted to the FAA during the NPRM comments period, two said that, if galley doors 

were used as emergency exits, the placement of an attendant seat near the exit 

preclude compliance with the requirement that the attendant be provided with direct 

view of the cabin area. To cover this situation, it was suggested that the requirement be 

conditioned to apply in so far as practicable and without compromising the proximity to 

required floor level exits. The FAA concurred and further stated in the preamble to the 

final rules that “location of the flight attendant seats near the floor level exits in this case 

is more important than the requirement to have a direct view of the cabin”. The final 

rule was revised from the NPRM proposal to address this relative importance. 

Regulation 14 CFR §25.785(d)

Customers are buying airplanes because they wish to create a spacious and impressive 

atmosphere they are used to. The wide body of the A330 satisfies these requirements. 

On the other hand, the requirement for firm hand hold along the aisles cannot be met for 

certain areas in the passenger cabin due to the wide open spaces, specifically, the 

lounge, conference room and passageways. On a typical “commercial” flight this 

requirement is met by the individual seat backs which typically provide an adequate 

hand hold for a passenger to stabilize themselves in the aisle during turbulence. In fact 

due to the spaciousness of the interior there is no readily identifiable “aisle” in the 
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conference room. Any construction hanging from the ceiling would ruin the appearance 

of the high quality interior, is not acceptable to the customer, and may add additional 

safety concerns.

It has been acknowledged by the FAA, that the passengers on this type of airplane are 

typically the same people on most of the trips. Familiarity with the airplane layout and 

operation provides an addition benefit towards the level of safety.

Regulation 14 CFR §25.791(a)

The proposed VIP airplane is intended to be a non-smoking airplane. Placards will be 

displayed at each entry door indicating such and passengers are familiar with this 

designation of the airplane. An acceptable level of safety will be maintained with 

placement of placards different than required in the applicable rule but equally visible to 

all occupants upon boarding. Therefore, an exemption to the No Smoking Placards 

requirement, similar to that granted in Exemption 10686, is needed to meet the needs of 

the end customer.

Regulation 14 CFR 25.807(d)(7)

The proposed VIP airplane will require exemption from the requirement of a maximum 

of sixty feet between exits on the right side because of the deactivation of the R2 door 

to support the interior configuration. This area of the aircraft has a total of four 

passengers in taxi, takeoff, and landing (TTL) configuration. 

The L2 Type A door remains active and a pair of Type A exits at positions L1 and R1 

provide egress forward of the passengers forward of the compartment within thirty feet 

of fuselage length. Between the Type A L2 exit and pair of Type 1 exits at positions L3 

and R3, the cabin configuration has no TTL passengers farther than thirty feet from the 

L3 and R3 exits. The remaining seventy passengers are located between the L3 and 

R3 exits and Type A exits at positions L4 and R4.

Due to the small numbers of passengers the airplane will carry, the adverse effect of 

these passengers on the ability of the flight attendant to carry out a rapid and safe 

evacuation from the airplane in the case of an emergency, will be minimized. The 

maximum number of passengers aboard the airplane will be ninety-eight, and, in most 

cases, the knowledge of the airplane and its emergency systems, by these passengers, 

will be greater than passengers on board an airliner. 

Concern over distance between exists arises from managing an evacuation, of a 

commercial airliner, when the passenger queue in the aisles becomes excessive due to 
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long distances between exits. Because of the reduced number of occupants on the 

subject airplane in the area of the deactivated exit, the passenger queue will be much 

shorter. Gore Design believes that there are sufficient numbers of exits in close 

proximity of each other and fewer passengers to evacuate. 

As stated above, when the separation of exits along the fuselage becomes greater, the 

task of managing a successful evacuation becomes greater. This increase in difficulty is 

a function of the number of passengers that fill the aisles of the airplane at the onset of 

the evacuation. The paramount overall criterion, for any exit arrangement, is that the 

exits be adequate in number and in compliance with the rules. They should be 

uniformly distributed along the length of the fuselage with exits located near the front 

and the rear of the fuselage. Given a maximum number of ninety-eight passengers, the 

pairs of type A exits at locations 1 and 4, the pair of type 1 exits at location 3, and the 

remaining Type A exit at L2 satisfies that general criteria.

Regulation 14 CFR §25.813(e) 

There will be six manual mechanical pocket type doors (one each located at the 

office/bedroom and hallway/lounge doorways and two located each at the 

lounge/conference room and conference room/business class seating area doorways) 

and an electrically actuated mechanical pocket type door is located at the hallway/office 

doorway. Swing doors are located between passenger compartments in the 

hallway/bedroom and bedroom/VIP lavatory doorways. An additional swing door that is 

not between passenger compartments is located in the front entry/hallway doorway.

Door between passenger compartments (except for the bedroom door) will have the 

following design features: dual latches (each of which are able to withstand the forces 

defined by 14 CFR §25.561) to secure them in the open position, cockpit annunciation 

of the door position for taxi, takeoff and landing, and the doors will be frangible in the 

event that they should become stuck in the closed position. The bedroom door will be 

placarded to be closed for taxi, takeoff and landing and this door will be shown to be 

frangible.

Regulation 14 CFR §25.853(a)(1)

With the sudden growth in the VIP or executive transport airplane market together with

the simultaneous introduction of more stringent interior material flammability standards,

aircraft interior modifiers have been faced with a serious dilemma in resolving the styling

requirements of the private aircraft owner/operator of these executive aircraft and the

flammability requirements imposed by §25.853. For the most part, modifiers have been

able to simultaneously satisfy both the styling and interior material flammability
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requirements of §25.853(a) and (c) with great effort and diligence; however, many of the 

materials required in these aircraft interiors simply cannot pass the 65/65 heat release

requirement of § 25.853(a)(1) no matter how diligent the designer is. It is not within the 

grasp of current technology to make certain natural materials conform to these 

standards and the owners of these airplanes define, in fact demand, the use of these 

materials. It should be understood that these aircraft must be outfitted in a style not 

unlike fine executive board rooms or luxurious residences to satisfy their private users.

OCCUPANT SAFETY CONSIDERATIONS:

14 CFR §25.785(h)(1)

Considering the reduced number of occupants in the business, private airplane, in this 

case 24% of that of a traditional commercial configuration, and the familiarity of the flight 

and cabin crews with the specific airplane, the passengers and the interior arrangement, 

and the wording of the existing rule that places the emphasis for safety on the proximity 

of the exit to the attendant over the ability of the attendant to view the cabin area, there 

should be no degradation in the passenger safety as a result of this requested 

exemption.

14 CFR §25.785(d)

The risk for occupants due to the non-availability of direct hand holds in certain areas of 

the airplane should be considered acceptable for the following reasons: 

 All furniture in the passenger cabin has rounded corners and edges to avoid 

serious injury in case of turbulence.

 The installed seat and divans are heavily upholstered and will not cause injuries 

when contacted.

 In the conference room, seat backs, tables, and furniture are readily within reach 

with one or two steps.

 There will be a recommendation to passengers to remain seated with their seat 

belts fastened in case of turbulence during flight.

 Occupants are intimately familiar with the interior arrangement.

 The airplane will be operated under 14 CFR Part 125 and will not be operated for 

hire or offered for common carriage.
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14 CFR §25.791(a)

There is no safety risk for occupants due to the special placement requirements of no

smoking placards.

Regulation 14 CFR 25.807(d)(7)

The risk for occupants because of deactivation of the R2 exit should be considered 

acceptable for the following reasons: 

 The aircraft passenger count is just 24% of that of a traditional commercial 

configuration.

 Even without R2 exit, the aircraft still provides emergency exits uniformly 

distributed along the length of the fuselage and with an emergency evacuation 

capacity far above the number of passengers

 The aircraft configuration has only four passengers in the area of the deactivated 

doors, who remain within 30 feet of a pair Type A exits.

 Occupants are intimately familiar with the interior arrangement.

 The airplane will be operated under 14 CFR Part 125 and will not be operated for 

hire or offered for common carriage.

14 CFR §25.813(e)

The risk for occupants due to the use of doors between passenger compartments 

should be considered acceptable for the following reasons:

 All doors between passenger compartments will be frangible.

 The swing door between the bedroom and hallway will be placarded to be closed

for takeoff and landing.

 The pocked door between the office and bedroom will be placarded to be closed 

for takeoff and landing.

 The pocket doors between the hallway and lounge, between the lounge and 

conference room, and between the conference room and business class area will

be placarded to be open for takeoff and landing. 
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 The doors between passenger compartments will have dual means to retain 

them in the open position for takeoff and landing, each of which will be capable of 

withstanding the inertia loads specified in 14 CFR §25.561.

 The airplane will be operated under 14 CFR Part 125 and will be not be operated 

for hire or offered for common carriage.

 The AFMS will provide procedures and limitations to ensure that the doors are in 

the proper position for takeoff and landing.

14 CFR §25.853(a)(1)

The vast majority of the rule was driven by the post-crash fire experiences in airline

operations. The 65/65 heat release regulation was specifically developed to reduce the

likelihood of the flash-over phenomenon which was proven by tests to be a prime

contributor to the rapid propagation of post-crash cabin interior fires and the generation

of blinding smoke. Rapid fire propagation combined with the relatively slow rate of

passenger evacuation from densely packed air carrier airplanes has proven to be a 

deadly combination during actual airline accidents. Since it is clear that material 

selection is being controlled by aesthetics in this application, we cannot exercise any 

real control over the actual heat release but the exposure time to this heat release is still 

within the designer’s control. Therefore, it is proposed as a first step in mitigating the fire 

hazard that an evacuation analysis be performed to show that all souls on board can be 

safely evacuated in less than 45 seconds. This would be possible because of excess 

emergency exits for the airplane passenger capacity, eleven flight attendants, smooth 

evacuation routes, and the small number of seats in the cabin. In addition, GDC will 

install fire detectors in the conference/dining room, office, lounge and bedroom that 

would compensate for the potential for an increased in-flight fire threat.

PUBLIC INTEREST:

As in the cases of numerous already established Exemptions, granting this petition for 

exemption would be clearly in the public interest for the following reasons:

 It allows efficient and safe carriage of Head of State and executives in the sought 

for environment that would otherwise not be possible,

 There is no degradation of safety involved with this request and therefore no 

detrimental impact to the public at large,
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 Increased sales of these executive configured transport airplanes will ultimately 

result in some portion of those airplanes being completed at US owned or 

operated aircraft completion facilities, providing improved financial performance 

and work force stability for those organizations as well,

 Improved financial performance of US owned or operated corporations, and 

increased work force stability translates into continued and improved tax revenue 

for all governmental organization involved,

 Improved financial performance allows US corporations to continue to invest in 

new R & D research which will allow the US to maintain or improve it’s 

competitive position in the world economy,

 A large number of these types of sales can be predicted to be to “offshore” 

clients, improving the US balance of trade deficit.

PUBLIC COMMENT:

In accordance with 14 CFR 11.87, Gore Design Completions, ltd., requests that the 

period for public comment be waived because of numerous similar exemptions that 

have previously been granted.

Sincerely,

Mark Creager

Certification Manager

Gore Design Completion, Ltd.

Phone: 210-496-5614 Ext 5222

Cell: 210-616-1825

Email: mark.creager@goredesign.com 

cc: Bill Vickers, ASW-190, Special Certification Office

Enclosure: Floor Plan
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Bedroom Office

Lounge Conference Room Business Class Seating

VIP

Lav

Front Entry Hallway Main Entry

Crew 

Rest Galley

Flight Attendant Seats Occupiable for Taxi, Takeoff, and Landing

Passenger Seats Occupiable for Taxi, Takeoff, and Landing