### DGT-DTC/CER 582947 1/3

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. DIRECTION GÉNÉRALE TECHNIQUE


### Saint Cloud, March 12th, 2012

U.S. Department of Transportation Docket Operations West Building Ground Floor, Room W12–140, 1200 New Jersey Avenue, SE. Washington, DC 20590 USA DGT-DTC/CER 582947 CM/FT

P lease contact Frederic TARDY Tél : +33 (0) 147 115 497 Fax : +33 (0) 147 115 745



## SUBJECT: Falcon 7X Series - Petition for am endment of exemption n°9506 regarding 14 CFR Part 25.813(e) Applicable to: Doors betw een passenger compartments

Dear Administrator,

In accordance with 14 CFR Part 11, we respectfully re quest that you consider th e updated Petition for Amendment of Exemption n°9506, document reference DGT354445 revision 2 dated 06-Mar-2012, that is attached to this letter.

Please do not hesitate to contact us at the following address:

Frederic TARDY DASSAULT AVIATION Certification Directorate 78, quai Marcel Dassault 92214 St Cloud Cedex - France Phone / fax : +33 (0)1 47 11 54 97 / 57 45 e-mail : frederic.tardy@dassault-aviation.com

Thank you for your assistance. Best regards.

Th BOISSON On behalf of

F. BALTZINGER J.P. DARGENTOLLE Evidence of signature is provided by a red electronic stamp on the first page left hand margin.



### Att : DGT354445 - FT F7X - Petition for amendment of exemption n°9506 Issue 2 regarding 14 CFR Part 25.813(e) Applicable to Doors between passenger compartments090040008059a44b - RELEASED - Certification Repository

### DGT-DTC/CER 582947 2/3

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

### SUBJECT : Falcon 7X Series - Petition for amendment of exemptio n n°9506 regarding 14 CFR Part 25.813(e) Applicable to: Doors betw een passenger compartments

EXTERNAL COPIE(S) : M D. JACQUET FAA Renton (P.J) T. RODRIGUEZ FAA Renton (P.J) R. BADER EASA Cologne (P.J)

### DGT-DTC/CER 582947 3/3

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

### SUBJECT : Falcon 7X Series - Petition fo r amendement of exemption n°9506 regarding 14 CFR Part 25.813(e) Applicable to: Doors betw een passenger compartments

INTERNAL COPIE(S) :

MM. Ph. BRIAUD DPAC St Cloud ROLLAND DPF St Cloud M. LAVANANT DGT/DIRM Mérignac J.P. DARGENTOLLE DGT/DTC-DIR St-Cloud G. GARROUSTE DGT/DTC-DIR Mérignac C. GIRAUDEAU DGT/DTC-SDV Mérignac P. GEORGES DGT/DTC-RSN St Cloud F. BALTZINGER DGT/DTC-CER St Cloud Th. BOISSON DGT/DTC-CER Mérignac L. MANTEZ DGT/DTC-CER Mérignac R. BARTHE DGT/DTC-CER Mérignac F. TARDY DGT/DTC-CER St Cloud J.C. LERMINIAUX DGT/DTACF/BE ACF Mérignac B. MONNIER DGT/DTACF/RT St Cloud P. BATS DGT/DTACF/RT Mérignac O. CLAUDON DGT/DTACF/RT St Cloud Y. TITEUX DFJ/ENGINEERING Little Rock P. DEBRUGE DFJ/CERTIFICATION Little Rock D. BOWERS DFJ/CERTIFICATION Little Rock I. WILSON DFJ/ENGINEERING Little Rock R. FEAZELL DFJ/CERTIFICATION Little Rock Classement DGT St Cloud1/ 5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. DIRECTION GÉNÉRALE TECHNIQUE


### Saint Cloud, February 13 th 

### , 2012 Issue 2, March 06 th 

### , 2012

DGT354445 Issue 2 CM/FT

Please contact Frederic TARDY Tél : +33 (0) 147 115 497 Fax : +33 (0) 147 115 745

SUBJECT: Falcon 7X Series - Petition for amendment of exemption n°9506 regarding 14 CFR Part 25.813(e) Issue 2

Applicable to: Doors between passenger compartments

Changes in issue 2: Public Interest section u pdated following FAA request by mail on 27-Feb-2012



## 1. Summary of the Petition for Amendment of Exemption [as per FAR Part 11.81 (b) and (f)]

DASSAULT AVIATION is officially applying on behalf of Falcon 7X Series owners/operators, for an amendment of the permanent Exemption n°9506 to 14 CFR Part 25.813(e) rule. Exemption n°9506 was granted to DASSAULT AVIATION in order to a llow the installation on Falcon 7X airplane of a latchable sliding door which can be stored in a cabin partition during takeo ffs, landings and emergency conditions.

This petition for amendment aims at making the Ex emption n°9506 consistent with the recently granted FAA Exemption n°10396 applicable to Falc on 900 Series, as well as with EASA’s CRI D-14 applicable to F7X series, in:

- Allowing the installation of mid cabin simple (or double) sliding door(s),

- Allowing their installation in Public Transporta tion pending they remain blocked in fully open position and require a maintenance operation to set them operational if the airplane has to be operated in Private Transportation,

- Taking into account the integration of the cockpit annunciator into EASy system (introduced per M0566 “ EASy load 10 ”)090040008057f84a - RELEASED - Certification Repository2/ 5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

## 2. Background / Extent of relief a nd reason [as per Part 11.81(c)]

Since DASSAULT AVIATION has more and more custom ers requesting to have an airplane capable of both private and public transportation we would like FAA to consider the possibility to allow the installation of a mid cabin partition, even for pub lic operation, considering that the door must be inoperable and blocked in fully open position duri ng all flight phases when operated in public transportation. In case the customer/operator wants to switch to private configuration, a maintenance operation (i.e. not possible to be executed by crew or passenger), will be necessary to unblock the door (of course, a reverse operation will be necessary to go b ack to public configura tion). This will give to the customer a more flexible way to switch from private to public configuration without having to remove the door from the airplane.

Note that DA’s proposition does not preclude the inst allation of a door only applicable to private use but prevents some operators from applying unpractic al door removal procedure for the specific case of F7X operated under public operation.

Besides, for aesthetic reasons, double sliding doors are now often requested by customers in lieu of simple ones. Yet, these double doors are curren tly not addressed in the Exemption n°9506. Consequently, the present petition for amendment is also requesting to include the possibility of installation of double sliding doors as well as simple ones on F7X airplanes.

As indicated above, these requests have already been found acceptable recently by FAA for Falcon 900 Series through Exemption n°10396 (see table in §5) which acknowledges the installation of single and double doors between passenger compartments ( see § “Description of the partition and door” (1.)), as well as the possibility of installing such doors blocked fully open in Public Transportation (see special condition (8.)).

Besides, EASA’s CRI D-14 also allows the insta llation of simple and double doors for Falcon 7X Series (see special condition (d)) as well as their inst allation in Public Transportation pending the door(s) is(are) blocked in open position (see special condition (c)).3/ 5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

## 3. Description of the partition and door(s)

Impacts of those changes on this section are highlighted in yellow.

1. The cabin of the Falcon 7X Series is approximately 7 feet wide. Thus, some customers request to divide the cabin full width laterally, to produce a priv ate area, because a side corridor is impractical. The doors to be installed would be single (or dual) pocket sliding door(s) retracting into the partition on one (or both) side(s) of the airplane. The doors wi ll require a retracting footer because with a cabin head-room of 6 ft the door must slide downward ta ngential to the fuselage contour. The door would be frangible to enable it to be broken open in an emer gency, in addition to having blow-out capability for decompression.

2. Only one partition of the passenger seating area with a door installed would be permitted.

This will allow one section of the passenger seating area to be used as a private office or bedroom during long duration flights. The proposed door would have a placard, requiring it to be open for takeoff and landing. Any other partitions of the passe nger area would be closed out with a curtain.

3. Each door would also be equipped with redundant means of locking the door in the open position, such that the probability of unlocking due to distor tion of the fuselage in an emergency landing would be minimized. Either means will be capable of supp orting the inertia loads specified in FAR 25.561.

4. By similarity to lavatory door, the door be tween passenger compartments will allow persons on either side of the door to unlock or unlatch the door without the use of tools (regardless of where it is located in relation to the emergency exits).

5. Moreover, lighted signs will be installed on the fo rward and aft face of the partition stating that the door must be open for takeoff and landing. An amber light will be installed in the cockpit (or a white CAS message will be available in case of integration in EASy system). The lighted signs and warning (or CAS message) will be controlled by the cockp it “No Smoking” switch and will be “ON” whenever the “No Smoking” signs are “ON” and the the door (s) is (are) closed (in case of EASy integration, it will be controlled according to the logic describ ed in M0566). The signs and warning (or CAS message) will remain illuminated until the door is secured in the open position at which time it will extinguish.

6. The emergency exit sign requirements will be a ddressed separately to ensure that the level of passenger guidance required to find an exit will be pr ovided. This will be customized on each airplane since there are often differences between the individual airplane interior arrangements.4/ 5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

## 4. Public Interest [as per Part 11.81(d)]

DASSAULT AVIATION believes that the installation of the combination latchable sliding door and cabin partition is in the public’s best interest. It will permit the conduct of important business meetings which because of their sensitivity, requir e an atmosphere of complete privacy.

It is a well established fact that an enormous amount of commercial activity occurs on board the United States business aviation fleet. Such commerc ial activity, including private business meetings where important commercial decisions are made, ar e vital to maintaining the competitiveness and overall strength of the U.S. economy (Business Aircraft Utilization Strategy - NBAA).

For example, business aircraft reduce not only flight time but also total travel time by providing point to point service and their ability to utilize sma ller airports closer to final destinations. 

### In addition, the
"office" environment which exists within the busines s aircraft allows travel time of busy executives and their guests, to become productive time. Busin ess aviation enables a company to maximize its two most important assets: people and time.

Very often, conversations conducte d on business aircraft are confidential and deal with commercially sensitive matters. Accordingly, owners of business airc raft strongly prefer to configure their cabins in such a way that special requirements of their operation can be met. One of the most popular configurations requested by a wide array of bu siness and public sector customers is a split cabin configuration where one sector is devoted to cl ub seating used for individual work areas and dining areas while the second sector is devoted to private meetings and/or a rest area set off from the remainder of the cabin.

Moreover, the installation of a mid cabin door in both private and public airplanes, pending specific means are provided to make the door inoperable a nd blocked in open position during all flight phases when operated in public operation, will preven t some operators from applying unpractical door removal procedure for the specific case of F7X ope rated under public operation. This will increase the flexibility of customers to use th eir airplanes either in Public or in Private Transportation.

The granting of this amendment for exemption will pe rmit the most efficient use of the airplane cabin which will significantly enhance the value of the airplane to its owner/operator.

Further, the granting of the petition will allow better and more comfortable rest area accommodations for busy executives and physically challenged passengers.

For these reasons, we believe the exemption requested is clearly warranted. In addition, note that sick or infirmed passengers could be more comfortably transported with the divi ded cabin configuration



## 5. Reasons why granting the exemption will not adversely affect safety [as Part 11.81(e)]

The effect of the updated safety features described a bove (cf. §2) will ensure that there is always a clear path through the partition to an emer gency exit. However even if some extreme condition should5/ 5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. result in the door being closed or par tially closed after an accident there are still simple, failsafe means to get through the door to reach an exit. The frangibility feature will be tested using a 5 th percentile female, and the resulting aperture demonstrated to be large enough to allow for a 95 th percentile male to escape.

Because the basic issues concerning a passenger fi nding and reaching an exit in an emergency are addressed by the above features as well as the previous ly described safety parameters, it is our position that the amendment for exemption as requested, would provide a level of safety for the passengers in a Falcon 7X equivalent to that require d for commercial carrier airplane.



## 6. Additional information [as Part 11.81(g)]

As reminded in § 1. FAA has previously grante d an exemption n°10396 Falcon 900 Series allowing:

- Applicability to dual doors designs,

- Authorization to allow the installation of a mi d cabin partition, even for public operation, considering that the door will be blocked ope n by a maintenance operation in this case. Integration of the cockpit annunciator has been a pproved in January 2010 by EASA and FAA through M0566 “ EASy load 10 ” Major Level 1 modification.


## 7. Operation outside US [as per FAR Part 11.81(h)]

Considering the multitude of countries in which Falc on 7X Series are sold and operated, it is very likely that this Amendment for exemption should be recognized by some other countries usually agreeing with FAA position.

Based on the information provided above, we request an official FAA position regarding our petition for amendment for exemption n°9506.

Please do not hesitate to ask for any additional info rmation which you may require in order to respond to this petition.

Respectfully submitted,

Th BOISSON

On behalf of

F. TARDY F. BALTZINGER