·-

GREENPOINT 

Technologies 

February 25, 2013 

U. S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Avenue, SE 

Room W12-140, West Bldg. Ground Floor 

Washington, DC 20590-0001 

Subject: Petition for Exemption from§§ 25.562(a) and 25.785(b) of Title 14 Code of 

Federal Regulations on Boeing Model 747-8ZV Airplane 

Reference: FAA Project No. ST11824SE-T 

Enclosed please find Greenpoint Technologies' petition for an exemption from §§25.562(a) and 

25.785(b) of Title 14 Code of Federal Regulations (CFR) on a Boeing Modei747-8ZV airplane. 

This request is necessary in order to certify the desired airplane configuration for the end 

customer. 

Greenpoint Technologies respectfully requests that the publication and comment period be 

waived in accordance with 14 CFR §11.87 for the following reasons: 

• The exemption will not set a precedent and is non-controversial; 

• The exemption sought is identical to Exemption No. 1 0687, Regulatory Docket No. 

FAA-2012-0954, granted January 24,2013 for relief from §§25.562(a) and 

25.785(b) for two Boeing Model 747-8 airplanes with similar VIP applications; 

• Delaying action on our petition would affect us adversely as the modified airplane 

is scheduled to be completed in early 2014 and certification testing for seats is 

scheduled to begin in March 2013; 

• The petition is being filed in a timely manner. 

Please contact this office if you have further questions. 

Sincerely, 

~~~ Senior Certification Engineer 

Enclosure 

cc: Ms. Susan Monroe, FAA 

Greenpoint Technologies, Inc. • 4600 Carillon Pt • Kirkland WA 98033 • Tel: (425) 828-2777 Fax: (425) 827-6105 
Enclosure to Greenpoint letter dated, February 25,2013 

RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) 

Page 1 of 6 

A. Name and Address of the Petitioner 

Barbara Baillie, Senior Certification Engineer 

Greenpoint Technologies, Inc. 

4600 Carillon Point 

Kirkland, Washington 98033 

Ph: 425-739-7877 

Email: bbaillie@greenpnt.com 

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

As provided for in § 11 .61 (b), Green point hereby petitions for exemption from the 

following 14 CFR §§for a Boeing Model 747-8ZV airplane, serial number 42096: 

Regulation Amendment Requirement 

25.562(a) 25-64 The seat and restraint system in the airplane must be 

designed as prescribed in this section to protect each 

occupant during an emergency landing condition when-- (1) 

proper use is made of the seats, safety belts, and shoulder 

harnesses provided for in the design; and (2) the occupant is 

exposed to loads resulting from the conditions prescribed in 

this section. 

25. 785(b) 25-88 Each seat, berth, safety belt, harness, and adjacent part of 

the airplane at each station designated as occupiable during 

takeoff and landing must be designed so that a person 

making proper use of the facilities will not suffer serious 

injury in an emergency landing as a result of the inertia 

forces specified in§§ 25.561 and 25.562. 

C. Extent of and Reason for Relief Being Sought 

Greenpoint requests relief from the general occupant protection requirements of §§ 

25.562(a), Amendment 64, and 25.785(b), Amendment 88, for side-facing seats in the 

passenger compartment on Boeing Model 747-8ZV airplane, S/N 42096, operated for 

"private, not-for-hire, not-for-common carriage." Relief will be limited to the original 

supplemental type certificate (STC) and will not apply to subsequent amendments to 

those STCs. This request is limited to the specific side-facing seat designs installed by 

the petitioner for the original STC and this limitation will be included in the limitation 

section of the STC. This request is limited to side-facing seats that do not include 

inflatable devices. Greenpoint Technologies proposes the following criteria as 

conditions of the exemption: 
~:.i 

Enclosure to Greenpoint letter dated, February 25, 2013 

RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) 

Page 2 of 6 

I. Existing Criteria: All injury protection criteria of§ 25.562(c)(1 )) through (c)(6) apply 

to the occupants of side-facing seating. The Head Injury Criterion (HIC) assessments 

are only required for head contact with the seat and/or adjacent structures. 

2. Body-to-Body Contact: Contact between the head, pelvis, torso, or shoulder area 

of one Anthropomorphic Test Dummy (ATD) with the adjacent seated ATD's head, 

pelvis, torso, or shoulder area is not allowed during the tests conducted in accordance 

with§ 25.562(b)(1) and (b)(2). Contact during rebound is allowed. 

3. Thoracic Trauma: If the torso of an ATD at the forward most seat place impacts seat 

and/or adjacent structure during testing, compliance with Thoracic Trauma Index (Til) 

injury criterion must be substantiated by dynamic test or by rational analysis based on 

previous test(s) of a similar seat installation. Til data must be acquired with a Side 

Impact Dummy (SID), as defined by 49 CFR part 572, subpart F, or an equivalent ATD, 

or a more appropriate ATD and must be processed as defined in Federal Motor 

Vehicle Safety Standard (FMVSS) part 571.214, section S6.13.5. TTl must be less 

than 85, as defined in 49 CFR part 572, subpart F. Torso contact during rebound is 

acceptable and need not be measured. 

4. Pelvis: If the pelvis of an ATO at any seat place impacts seat and/or adjacent 

structure during testing, pelvic lateral acceleration injury criteria must be substantiated 

by dynamic test or by rational analysis based on previous test(s) of a similar seat 

installation. Pelvic lateral acceleration must not exceed 130g. Pelvic acceleration data 

must be processed as defined in FMVSS part 571.214, section S6.13.5. 

5. Body-to-Wall I Furnishing Contact: If the seat is installed aft of a structure such as 

an interior wall or furnishing that may contact the pelvis, upper arm, chest, or head of an 

occupant seated next to the structure, the structure or a conservative representation of 

the structure and its stiffness must be included in the tests. It is recommended, but not 

required, that the contact surface of the actual structure be covered with at least two 

inches of energy absorbing protective padding (foam or equivalent) such as Ensolite. 

6. Shoulder Strap Loads: Where upper torso straps (shoulder straps) are used for sofa 

occupants, the tension loads in individual straps must not exceed 1,750 pounds. If dual 

straps are used for restraining the upper torso, the total strap tension loads must not 

exceed 2,000 pounds. 

7. Occupant Retention: All side-facing seats require end closures or other means to 

prevent the A TO's pelvis from translating beyond the end of the seat at any time during 

testing. 
Enclosure to Greenpoint letter dated, February 25, 2013 

RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) 

Page 3 of 6 

8. Test Parameters: 

(a) All seat positions need to be occupied by ATDs for the longitudinal tests. 

(b) A minimum of one longitudinal test, conducted in accordance with the 

conditions specified in § 25.562(b )(2), is required to assess the injury criteria as 

follows. Note that if a seat is installed aft of structure (for example, an interior wall 

or furnishing) that does not have a homogeneous surface; an additional test(s) 

may be required to demonstrate that the injury criteria are met for the area which 

an occupant could contact. For example, different yaw angles could result in 

different injury considerations and may require separate tests to evaluate. 

• For configurations without structure (for example, wall, bulkhead) installed 

directly forward of the forward seat place, Hybrid II ATDs or equivalent must 

be in all seat places. 

• For configurations with structure (for example, wall, bulkhead) installed 

directly forward of the forward seat place, an SID or equivalent ATD or more 

appropriate ATO must be in the forward seat place and a Hybrid II ATD or 

equivalent must be in all other seat places. 

• The test may be conducted with or without deformed floor. 

• The test must be conducted with either no yaw or 10 degrees yaw for 

evaluating occupant injury. Deviating from the no yaw condition must not 

result in the critical area of contact not being evaluated. Allowing the test to 

be conducted at 10 degrees yaw will permit many occupant injury tests to be 

considered in conjunction with the structural test. This test is considered 

acceptable since an exemption is sought in lieu of compliance with part 25. 

Note that this condition does not provide relief from the requirement that torso 

restraint straps, where installed, must remain on the occupant's shoulder 

during the impact condition of§ 25.562(b )(2). 

(c) For the vertical test, conducted in accordance with the conditions specified in 

§ 25.562(b )(1 ), Hybrid II ATDs or equivalent must be used in all seat positions. 

D. Statement of Public Interest 

Granting this exemption would be in the public interest for the following reasons: 

• VIP aircraft are used by Heads-of-State and Diplomatic Persons. Developing and 

maintaining positive relations with the operators of these aircraft benefits the US 

economy in terms of trade and balance of power; 
. .. 

Enclosure to Greenpoint letter dated, February 25, 2013 

RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) 

Page 4 of 6 

• The use of US design and manufacture of aircraft and interiors such as this one 

develops and maintains the worldwide positive image and influence currently 

enjoyed by the US Aerospace Industry. Consistency in regulations and design 

requirements at and after contract award affects competitiveness and significant 

changes after the time of contract places the US industry in a significantly lowered 

position to foreign industry. For instance, the imposition of the latest side-facingseat policy represents a major, unplanned change that if imposed require increases 

in program cost and effort, and in this case result in lost viability of applicable interior 

modification. Future sales depend on potential customers worldwide finding the US 

certification process dependable and reasonable and changing requirements midstream is counter to this end; 

• Granting of exemptions that are identical to others issued for the same airplane 

model and in the same time frame serves to level the playing field so as not to 

create an unfair advantage for one US modifier over another. The "in work" option 

provided for in the most recent side-facing-seat policy, FAA Policy Statement PSANM-25-03-R1, dated November 5, 2012, is the means to keep the playing field 

level which is in the public interest. 

E. Statement of No Adverse Effect on Safety 

The FAA has made adjustments to regulatory requirements based on specific design 

and operational factors numerous times in the past. This exemption will have no 

adverse impact on safety for the following reasons: 

• The operation of this aircraft is limited to private use by an individual or a company 

and does not include scheduled flights, fare-paying public passengers or cargo-forhire commercial service; 

• The proposed interior configuration is designed for very small and highly controlled 

passenger population; 

• The mitigating design requirements proposed will establish an acceptable level of 

safety for the occupants consistent with previous grants of exemption; 

• This project meets the criteria for relief via grant of exemption in accordance with 

FAA Policy Statement PS-ANM-25-03-R1, dated November 5, 2012, related to 14 

CFR §§ 25.562(a) and 25.785(b), page 4, In-work section; 

• The relief requested is identical to that previously granted in Exemption No. 10687, 

Regulatory Docket No. FAA-2012-0954, dated January 24, 2013 for relief from 

§§25.562(a) and 25.785(b) for two Boeing Model 747-8 airplanes with similar VIP 

applications. 
Enclosure to Greenpoint letter dated, February 25, 2013 

RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) 

Page 5 of 6 

F. Public Summary 

Greenpoint Technologies requests exemption from 14 CFR §§ 25.562(a) and 25.785(b) 

for a 747-8ZV airplane. The 747-8 aircraft is intended to be a VIP executive airplane 

including installation of single and multiple-place side-facing divans. This request is 

necessary in order to certify the desired aircraft configuration for the end customer. 

G. Background and Supportive Information 

The Boeing Model 747-8ZV project airplane is intended to be a VIP executive aircraft; 

modified under Bahamian registration. Greenpoint is contracted to design, install and 

certify an executive interior in a Boeing Model 7 4 7 -8ZV per customer specifications. 

STC certification is sought under FAA project# ST11824SE-T. The certification basis 

for the project is defined in Type Certificate Data Sheet A20WE and includes 14 CFR 25 

through Amendment 25-120 and Special Conditions for the Model Boeing 747-8 aircraft. 

The Project Specific Certification Plan, Greenpoint Document G1265-CP-01, Revision 

D, dated February 1, 2013, was accepted by FAA Letter 150S-13-45, dated February 

18, 2013. The proposed interior installation includes the use of single and multipleplace side-facing divans. No inflatable seat belts or harnesses will be used. All seats 

will be manufactured by B/E Aerospace located in Miami, Florida. Seats will fall into 

four categories based on location of the seat on the aircraft. Each side facing seat is 

actually a discrete frame. Multiple, discreet seat frames may be installed end-to-end 

with a gap between structures to ensure that the seats do not load share regardless of 

occupancy. 

14 CFR part 25 governs Type Design certification requirements for transport category 

airplanes. The FAA has stated that to the extent considered appropriate for safety, part 

25 requirements contain different provisions based on passenger capacity 

discriminants. These requirements do not distinguish between airplanes operated in air 

carrier service and airplanes operated for private use. Aviation industry representatives 

have stated that the part 25 standards are written with only air carrier operation in mind, 

and the FAA has issued alternative standards related to cabin interiors for private use 

airplanes based on these alternate standards providing an acceptable level of safety. 

The relief requested is in line with these prior issued alternative standards and will have 

no adverse impact on safety given the operation of the aircraft is limited to private use 

by an individual or a company and does not include scheduled flights, fare-paying public 

passengers or cargo-for-hire commercial service. Additionally, the occupants are a 

small, highly controlled passenger population. 

Recently, the FAA issued Policy Statement PS-ANM-25-03-R1 on November 5, 2012, 

which contains compliance methods that should be applied to new seat-certification 

programs. Defined therein, is an implementation option for "in-work" projects when the 

date of application precedes the effective date of the final policy and that do not have a 

previously granted exemption or an approved special condition in the certification basis. 
Enclosure to Greenpoint letter dated, February 25, 2013 

RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) 

Page 6 of 6 

The FAA's intent of the policy is to achieve long-term safety benefits associated with a 

more-comprehensive examination of safety aspects relevant to side-facing-seats, and 

has found that applicants with projects currently in work, are eligible, under certain 

conditions, for exemption to the criteria defined therein given the applicant adequately 

addresses all requirements of 14 CFR §11.87. Greenpoint requests relief based on the 

"in-work" allowance defined in this recent policy statement as our STC date of 

application precedes the effective date of this new policy. 

H. Privilege of this Exemption Outside the United States 

In accordance with §11.81 (h), Green point Technologies requests that the privileges of 

this exemption be extended outside of the United States. This extension of privileges is 

necessary because the end user of the Boeing Model 747-8 airplane being modified is a 

foreign national and the airplane will be operated the majority of time outside the US.