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GREENPOINT Technologies February25, 2013
U. S. Department ofTransportation Docket Operations, M-30 1200 NewJerseyAvenue, SE Room W12-140, West Bldg. Ground Floor Washington, DC 20590-0001 Subject: Petition for Exemption from§§ 25.562(a) and 25.785(b) ofTitle 14 Code of Federal Regulations on Boeing Model 747-8ZVAirplane Reference: FAA Project No. ST11824SE-T
Enclosed please find GreenpointTechnologies' petition for an exemption from §§25.562(a) and 25.785(b) ofTitle 14 Code of Federal Regulations (CFR) on a Boeing Modei747-8ZV airplane. This request is necessary in orderto certifythe desired airplane configuration forthe end customer. GreenpointTechnologies respectfully requests thatthe publication and comment period be waived in accordancewith 14 CFR §11.87forthe following reasons: • The exemption will not set a precedent and is non-controversial; • The exemption sought is identical to Exemption No. 10687, Regulatory Docket No. FAA-2012-0954, granted January24,2013for relieffrom §§25.562(a) and 25.785(b) fortwo Boeing Model 747-8 airplanes with similarVIP applications; • Delaying action on our petition would affect us adversely as the modified airplane is scheduled to be completed in early2014 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 ifyou have furtherquestions. Sincerely,

# ~~~ SeniorCertification Engineer Enclosure

cc: Ms. Susan Monroe, FAA
GreenpointTechnologies, Inc. • 4600 Carillon Pt • Kirkland WA98033 • Tel: (425) 828-2777 Fax: (425) 827-6105Enclosure to Greenpoint letterdated, February 25,2013 RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) Page 1of6

A. Name and Address ofthe Petitioner
Barbara Baillie, SeniorCertification Engineer GreenpointTechnologies, Inc. 4600 Carillon Point Kirkland, Washington 98033 Ph: 425-739-7877 Email: bbaillie@greenpnt.com
B. Section ofthe Code of Federal Regulations (CFR) that are Affected
As provided for in §11 .61 (b), Greenpoint hereby petitions for exemption from the following 14 CFR §§fora Boeing Model 747-8ZV airplane, serial number42096: Regulation Amendment Requirement 25.562(a) 25-64 The seatandrestraintsystem in the airplane mustbe designedasprescribedin this section toprotecteach occupantduring an emergencylanding condition when-- (1) properuse is made ofthe seats, safetybelts, andshoulder harnessesprovidedforin the design; and (2) the occupantis exposed to loads resulting from the conditionsprescribedin this section. 25. 785(b) 25-88 Each seat, berth, safetybelt, harness, andadjacentpartof the airplane ateach station designatedas occupiable during takeoffandlanding mustbe designedso that

### a person makingproperuse ofthe facilities willnotsufferserious injuryin an emergencylanding as

### a result ofthe inertia forces specifiedin§§ 25.561 and25.562.

C. Extent ofand Reason for Relief Being Sought Greenpoint requests relieffrom the general occupant protection requirements of§§ 25.562(a), Amendment 64, and 25.785(b), Amendment 88, for side-facing seats inthe passenger compartment on Boeing Model 747-8ZV airplane, S/N 42096, operated for "private, not-for-hire, not-for-common carriage." Reliefwill be limited to the original supplemental type certificate (STC) and will not applyto subsequent amendments to those STCs. This request is limited to the specific side-facing seat designs installed by the petitionerforthe original STC and this limitation will be included in the limitation section ofthe STC. This request is limited to side-facing seats that do not include inflatable devices. GreenpointTechnologies proposes the following criteria as conditions ofthe exemption:**~:.i** Enclosure to Greenpoint letter dated, February 25, 2013 RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) Page 2 of6
I. Existing Criteria: All injury protection criteria of§ 25.562(c)(1)) through (c)(6) apply to the occupants ofside-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, orshoulder area ofone Anthropomorphic Test Dummy (ATD) with the adjacent seated ATD's head, pelvis, torso, or shoulderarea is not allowed during the tests conducted in accordance with§ 25.562(b)(1) and (b)(2). Contact during rebound is allowed.
3. ThoracicTrauma: Ifthe torso ofan 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 dynamictest or by rational analysis based on previous test(s) ofa similar seat installation. Til data must be acquired with a Side Impact Dummy (SID), as defined by 49 CFR part 572, subpart F, oran equivalentATD, ora 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: Ifthe pelvis ofan ATO at any seat place impacts seat and/or adjacent structure during testing, pelvic lateral acceleration injury criteria must be substantiated by dynamictest or by rational analysis based on previous test(s) ofa 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: Ifthe seat is installed aft ofa structure such as an interiorwall orfurnishing that may contactthe pelvis, upperarm, chest, or head ofan occupant seated nextto the structure, the structure ora conservative representation of the structure and its stiffness must be included in the tests. It is recommended, but not required, that the contact surface ofthe actual structure be covered with at least two inches ofenergy absorbing protective padding (foam orequivalent) such as Ensolite.
6. Shoulder Strap Loads: Where uppertorso straps (shoulder straps) are used for sofa occupants, the tension loads in individual straps must not exceed 1,750 pounds. Ifdual straps are used for restraining the uppertorso, 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 ATO's pelvis from translating beyond the end ofthe seat at anytime during testing.Enclosure to Greenpoint letter dated, February 25, 2013 RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) Page 3 of6

8. Test Parameters: (a) All seat positions need to be occupied byATDs forthe longitudinal tests. (b) A minimum ofone longitudinal test, conducted in accordance with the conditions specified in § 25.562(b)(2), is required to assess the injurycriteria as follows. Note that ifa seat is installed aft ofstructure (forexample, an interiorwall orfurnishing) that does not have a homogeneous surface; an additional test(s) may be required to demonstrate that the injury criteria are metforthe 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 directlyforward ofthe forward seat place, Hybrid II ATDs orequivalent must be in all seat places.

• Forconfigurations with structure (for example, wall, bulkhead) installed directlyforward ofthe forward seat place, an SID orequivalent 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 orwithout deformed floor.

• The test must be conducted with either no yaw or 10 degrees yawfor evaluating occupant injury. Deviating from the no yaw condition must not result in the critical area ofcontact not being evaluated. Allowing the testto be conducted at 10 degrees yaw will permit many occupant injurytests to be considered in conjunction with the structural test. This test is considered acceptable since an exemption is sought in lieu ofcompliance with part 25. Note thatthis condition does not provide relieffrom 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) Forthe vertical test, conducted in accordance with the conditions specified in § 25.562(b)(1 ), Hybrid II ATDs orequivalent must be used in all seat positions. 

### D. Statement of Public Interest Granting this exemption would be in the public interest forthe following reasons:

• VIP aircraft are used by Heads-of-State and Diplomatic Persons. Developing and maintaining positive relations with the operators ofthese aircraft benefits the US economy in terms oftrade 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 of6

• The use of US design and manufacture ofaircraft 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 aftercontract award affects competitiveness and significant changes afterthe time ofcontract places the US industry in a significantly lowered position to foreign industry. For instance, the imposition ofthe 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 ofapplicable interior modification. Future sales depend on potential customers worldwide finding the US certification process dependable and reasonable and changing requirements midstream is counterto this end;

• Granting ofexemptions 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 unfairadvantage for one US modifierover 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 safetyforthe following reasons:

• The operation ofthis aircraft is limited to private use by an individual ora company and does not include scheduled flights, fare-paying public passengers orcargo-forhire commercial service;

• The proposed interiorconfiguration is designed forvery small and highly controlled passenger population;

• The mitigating design requirements proposed will establish an acceptable level of safetyforthe occupants consistent with previous grants ofexemption;

• This project meets the criteria for relief via grant ofexemption 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 January24, 2013 for relieffrom §§25.562(a) and 25.785(b) for two Boeing Model 747-8 airplaneswith similarVIP applications.Enclosure to Greenpoint letterdated, February 25, 2013 RE: Petition for Exemption from§§ 25.562(a) and 25.785(b) Page 5 of6

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 ofsingle and multiple-place side-facing divans. This request is necessary in orderto certify the desired aircraft configuration forthe 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 74 7-8ZV per customer specifications. STC certification is sought under FAA project# ST11824SE-T. The certification basis forthe project is defined in Type Certificate Data Sheet A20WE and includes 14 CFR 25 through Amendment 25-120 and Special Conditions forthe 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 ofsingle 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 ofthe 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 fortransport 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 thatthe part 25 standards are written with only aircarrier 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 ofsafety. The relief requested is in line with these prior issued alternative standards and will have no adverse impact on safety given the operation ofthe aircraft is limited to private use by an individual ora 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 November5, 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 ofapplication precedes the effective date ofthe final policy and that do not have a previously granted exemption oran 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 of6
The FAA's intent ofthe policy is to achieve long-term safety benefits associated with a more-comprehensive examination ofsafety 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 ofthis new policy.
H. Privilege ofthis Exemption Outside the United States
In accordance with §11.81(h), Greenpoint Technologies requests that the privileges of this exemption be extended outside ofthe United States. This extension of privileges is necessary because the end userofthe Boeing Model 747-8 airplane being modified is a foreign national and the airplane will be operated the majority oftime outside the US.