1

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- 3 3 2 8 www.goredesign.com May 24 , 201 3

U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Floor Room W12

- 140 Washington, DC 2059 0

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 A 330

- 2 00 airplane.

Ref: GDC ODA STC Project no. GDC

- P579

- STC

BACKGROUND:

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

e xecutive business interior in Airbus Model A3 30

- 200 airplane. The FAA Organization Management Team (OMT) is reviewing our ODA Project Number GDC

- P 579

- STC for this project

.
The certification basis of the Airbus A 330

- 200 is 14 CFR Part 2 5, 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 saf ety 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 passenge rs carried in airline service. For these re asons, Gore Design Completion, L td. has prepared a petition for exemption to the following regulation s :
14 CFR §25. 7 85(h)( 1 ) , Amendment 25

- 64

- F light 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.2

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- 3 3 2 8 www.goredesign.com 1 4 CFR 25.791(a), Amendment 25

- 32

– Requires signs in the passenger cabin indicating when smoking is prohibited.

1 4 CFR 25. 8 07 ( d ) (7) , Amendment 25

- 7 2

– 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 t ransport c ategory air planes

. The primary intent of these regulations, as written, are to be certain that air plane manufacturers provide the appropriate design feat ures 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 regulati ons are intended to regulate the certification of “commercial” air planes , which are “for hire” to the general public.

While the great e s t majority of these regulations represent a common sense inclusion for any aircraft regar d less of it’s intended use, a f ew are obviously intended to regulate situations that are specific to an airline, or for hire operation. When a transport category air plane is operated under 14 CFR Part 91 or Part 125, some of the Part 25 rules have acceptance criteria that are inappropr iate, or are not compatible with th e type of operation and the intended use of th is air plane

. The FAA clearly recognizes these differences as evidenced by the is suance 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

- for

hire” 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 A3 30

- 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

.3

A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e

- S a n A n t o n i o T X 7 8 2 2 6

- U S A

- 2 1 0 . 4 9 6 . 5 6 1 4

- F A X 2 1 0 . 9 2 3

- 3 3 2 8 www.goredesign.com The interior configuration being installed in this airplan e is planned to provide sea ting 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 a rea. The maximum certified passenger count for this airplane is 3 75 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

sea ting. 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 sub mitted 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 tha n the requirement to have a direct view of the cabin”. The final rule was revised from the NPRM proposal to address this relative importa nce.
Regulation 14 CFR §25.785( d )

Customers are buying airplanes because they wish to create a spacious and impressive atmosphere they are used t o. The wide body of the A330 satisfies these requirements. On the other hand, the requirement for firm ha nd 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 w hich 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 identifiab le “aisle” in the4

A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e

- S a n A n t o n i o T X 7 8 2 2 6

- U S A

- 2 1 0 . 4 9 6 . 5 6 1 4

- F A X 2 1 0 . 9 2 3

- 3 3 2 8 www.goredesign.com 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 peo ple 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 n o n

- s moking airplane. Placards will be displa yed 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)

T he proposed VIP airplane will re quire exemption from the requirement of a maximum of sixty feet between exit s on the right side because of the deactivation of the R2 door to support the interior configuration. T h is area of the aircraft has a total of four passenger s in t axi, takeoff, and landing (TTL ) configuration

.

T h e L2 Type A door remains active and a pair of Type A exits at position s L1 and R1 provide egress forward of the passengers forward of t he compar tment within thirty feet of fuselage length. Between the Type A L 2 exit and pair of T ype 1 exits at positions L3 and R 3

, t h e cabin configuration has no TTL passengers farther than thir ty feet from the L3 and R3 exits. The remaining seventy pas s engers ar e located between the L3 and R3 exits and Type A exits at positions L4 and R4.

Due to the small numbers of passengers the airplan e 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 n inety

- 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 to5

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- 3 3 2 8 www.goredesign.com 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 beli eves 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 fu selage becomes greater, the task of managing a success fu l 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 ad equate in number and in compliance with the rules. They should be uniformly distributed along the length of the fu selage with exits located near the f r ont and the rear of the fuselage. Given a maximum number of n inety

- 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 s ix manual mechanical pocket type door s ( 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. S wing doors are located between passenger compartments in the hallway/bedroom and bedroom/VIP lavatory doorways. A n additional swing door that is not between passenger compartments is located in the front entry/hall way doorway.

D oor between passenger compartment s (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 an nunciation 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 w ill 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 flammab ility requirements imposed by § 25.853. For the most part, modifiers have been able to simultaneously satisfy both the styling and interior material flammability6

A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e

- S a n A n t o n i o T X 7 8 2 2 6

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- 3 3 2 8 www.goredesign.com 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 req uirement 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 mate rials. 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 numbe r 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 wordin g 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 exemptio n.
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 wi ll be a recommendation to passengers to remain seated with their seat belts fastened in c ase 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.7

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- S a n A n t o n i o T X 7 8 2 2 6

- U S A

- 2 1 0 . 4 9 6 . 5 6 1 4

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- 3 3 2 8 www.goredesign.com 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 th e 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 d eactivated 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 c ompartments 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 door s 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.8

A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e

- S a n A n t o n i o T X 7 8 2 2 6

- U S A

- 2 1 0 . 4 9 6 . 5 6 1 4

- F A X 2 1 0 . 9 2 3

- 3 3 2 8 www.goredesign.com  The door s 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 s pecified in 14 CFR §25. 561.

 The airp lane 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 pr ime 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 re lease 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 po ssible 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 th e 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 f or the following reasons:

 I t 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 degra da tion of safety involved with this request and therefore no detrimental im pact to the public at large,9

A I R C R A F T I N T E R I O R D E S I G N , E N G I N E E R I N G & C O M P L E T I O N S 6 0 7 N . F r a n k L u k e D r i v e

- S a n A n t o n i o T X 7 8 2 2 6

- U S A

- 2 1 0 . 4 9 6 . 5 6 1 4

- F A X 2 1 0 . 9 2 3

- 3 3 2 8 www.goredesign.com  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 pe rformance 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 predic ted 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 Plan10

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- S a n A n t o n i o T X 7 8 2 2 6

- U S A

- 2 1 0 . 4 9 6 . 5 6 1 4

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- 3 3 2 8 www.goredesign.com Office Bedroom

Lounge Conference Room Business Class Seating VIP Lav

Hallway Main Entry Front Entry Crew Rest Galley

F light Attendant Seats O ccupiable for T a x i, T akeof f, and Landing P assenger Seats O ccupiable for T a x i, T akeof f, and Landing