Exemption No. 10686A 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

L-3 Communications Integrated 

Systems, L.P. 

for an exemption from§ 25.813(e) ofTitle 

14, Code of Federal Regulations 

Regulatory Docket No. FAA-2012-0707 

DENIAL OF AMENDED EXEMPTION 

By letter dated February 12,2014, Mr. Phillip T. Crawford, ODA-750154-SW Administrator, 

L-3 Communications Integrated Systems, L.P., 7601 Maehr Road, P.O. Box 154580, Waco, 

Texas, 76715-4580, petitioned the Federal Aviation Administration (FAA) for an amendment to 

exemption number 10686 and from section 25.813(e) ofTitle 14, Code of Federal Regulations 

(14 CFR). The proposed exemption, if granted, would permit relief from the requirements and 

limitations specified in exemption no. 10686 that permit the installation of interior doors between 

passenger compartments. Specifically, the petition requests removing the requirement that doors 

installed across the main aisle must open and close in a transverse direction. The proposed 

exemption is specifically for the installation of an executive interior on Boeing Model 747-8 

airplanes designated as "private use, not for hire, not for common carriage:· 

The petitioner requests relief from the following regulations: 

Section 25.813(e) at Amendment 25-46- Requires that no door may be installed in any 

partition between passenger compartments. 

The petitioner supports their request with the following information. 

This section quotes, in pertinent part, the relevant information from the petitioner·s request. The 

complete petition is available at the Department of Transportation· s Federal Docket Management 

System. on the Internet at http:/lt-c!!ulations.Qov, in Docket No. F AA-20 12-0707. 
Discussion 

L-3 Communications Integrated Systems has been contracted by customers for interior 

completions of VVIP/Government/Head-of-State business interiors in more than one 

Boeing 747-8 airplane. The FAA has accepted L-3's STC application on one program and 

has authorized L-3 ODA-750154-SW to conduct the program under Project Number P12-001. The certification basis for the Boeing Model 747-8 is 14 CFR 25, Amendment 

25-1 through 25-120 with revisions, later amendments, Exemptions, and Special 

Conditions as shown in FAA Type Certificate Data Sheet A20WE. 

14 CFR 25 governs Type Design certification requirements for transport category 

airplanes. The primary intent of the CFR, as applied to Transport Aircraft, is intended for 

US commercial or common-carriage applications. These regulations are to ensure that 

aircraft manufacturers provide the appropriate design features to meet the standards 

necessary to protect the traveling US public. These requirements define the normal public 

interest and safety level and provide regulatory guidelines to meet them. When the 

individual aircraft is to be used in private services (e.g. , not for US hire or common 

carriage), it is appropriate to take into consideration the specific needs of a different 

population of more experienced users and the operations specific to those users. 

Historically, the FAA has made adjustments to specific requirements based upon specific 

design and operational factors. As stated above, numerous exemptions and other 

regulatory changes have been granted to meet specific aircraft designs and applications. 

In like manner, L-3 proposes to use mitigating design requirements and operational 

limitations to justify similar exemptions to 747-8 aircraft modified for 

VVIP/Government/Head-of-State, not-for-hire or common-carriage service. 

L-3 Communications Integrated Systems successfully petitioned for an Exemption from a 

number of 14 CFR 25 requirements. FAA Exemption 10686 was issued and among other 

items allows the use of doors that translate at right angles to the longitudinal aisle of the 

aircraft. L-3 's latest customer's design contains a rotunda-type entryway that has multiple 

aisles to other parts of the aircraft. Those aisles are not necessarily longitudinal aisles but 

are aisles to other compartments. Relief is needed to allow the use of straight or curved 

pocket -type doors that translate across the direction of travel. 

Basis for Exemption 

The aircraft that are the subjects of this petition are Boeing Model 747-8 modified for 

non-commercial/non-common-carriage VVIP/Government use/Head-of-State service. 

They are typically in the service of foreign Heads-of-State friendly to US interests and 

will be operated under 14 CFR 91/14 CFR 125 regulations or equivalent foreign standard. 

For this reason the privileges of this proposed exemption will be exercised outside the 

United States. 

The interior configurations typically installed result in a very small passenger population 

vis-a-vis for-hire or common-carriage standards. These passengers are typically very 

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experienced travelers. For this reason the crews and passengers who fly on this aircraft 

have a substantially higher familiarity with the aircraft and its systems than those 

envisioned by the writers of the original CFR. 

The exemption proposed herein are justified based upon the following facts: 

• This aircraft is intended for VVIP/Government/Head-of-State use and is not 

appropriately configured for or intended for use for hire or common carriage. 

• Depending on the interior layout, these aircraft typically carry a low fraction of the 

originally Type-Approved passenger load. 

• SFAR I 09, Special Requirementsfor Private Use Transport Categmy Aircrqft, 

was issued in 2009 to address these issues among others. This SF AR is limited to 

aircraft with passenger counts of 60 or less. This exemption will apply similar 

requirements and basis to the slightly larger aircraft. 

• The Petitioner proposes mitigating requirements and conditions that establish 

acceptable safety levels for the occupants consistent with previous grants. 

With these justifications in mind, L-3 Communications Integrated Systems requests relief 

from and proposes a petition for exemption from the listed regulations. 

14 CFR 25.813(e): Doors Between Passenger Compartments 

Discussion 

This discussion covers doors that separate passenger compartments throughout the 

aircraft. This discussion does not include doors or folding partitions that separate nonpassenger compartments and these doors do not apply to this exemption request. Door[s] 

between passenger compartments will have the following design features: dual latches 

(each ofwhich are able to withstand the forces detined by 14 CFR 25.561) to secure them 

in the open position, cockpit annunciation of the door position for taxi, take-off, and 

landing, and the doors will be frangible to allow egress in the event that they should 

become stuck in the closed position. 

Occupant Safety Considerations 

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

be considered acceptable for the following reasons: 

• Any door between passenger compartments will have dual means to retain them in 

the open position for take-off and landing, each of which will be capable of 

withstanding the inertia loads specified in 14 CFR 25.561 , 

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• Doors to compartments that are unoccupied during Taxi/Take-off/Landing 

operations will be closed. Door position will be indicated in the cockpit when the 

door is in the wrong position for take-off and landing, 

• All doors between passenger compartments will be frangible, 

• The airplane will be operated under 14 CFR 91/14 CFR 125 or foreign equivalent 

and will not be operated for hire or offered for common carriage. 

• The airplane flight manuals (AFMs) will provide procedures and limitations to 

ensure that the doors are in the proper position for take-otT and landing. 

Requested Relief 

L-3 proposes to meet the requirements as stated in SF AR I 09 and various Exemptions as: 

• In lieu ofthe requirements of Sec. 25.813(e), interior doors may be installed 

between passenger seats and exits, provided the following requirements are met: 

o Each door between any passenger seat, occupiable for taxi, take-off, and 

landing, and any emergency exit must have a means to signal to the 

tlightcrew, at the tlightdeck, that the door is in the open position for taxi, 

take-oft~ and landing. 

o Appropriate procedures/limitations must be established in the AFM to 

ensure that any such door is in the open configuration for take-off and 

landing. 

o Each door between any passenger seat and any exit must have a dual 

means to retain it in the open position, each of which is capable of reacting 

the inertia loads specified in Sec. 25.561. 

o The direction of motion of any straight or curved doors installed across an 

aisle must be across the direction of motion of the occupant, e.g., pocket 

doors are one example of such a design. 

o Each door between any passenger seat and any exit must be frangible in 

either direction. A frangibility test will be performed on each type of intercompartment door installation in the aircraft using a 5th percentile female 

subject. 

o Each door between any passenger seat and any exit must be openable from 

either side, and if a locking mechanism is installed, it must be capable of 

being unlocked from either side without the use of special tools. 

• When the aircraft is equipped with interior doors under this Exemption: 

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o The airplane flight manual (AFM) must include an appropriate limitation 

that the airplane must be staffed with at least the number of flight 

attendants required by 14 CFR 91.533(a) who meet the requirements of 14 

CFR 91.533(b). 

• The AFM must include appropriate limitation(s) to require a preflight passenger 

briefing describing the appropriate functions to be performed by the passengers 

and the relevant features of the airplane to ensure the safety of the passengers and 

crew. 

Public Interest 

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

exemption would be clearly in the public interest ofthe people of the United States of 

America for the following reasons: 

1. Given the proliferation ofVVlP/Government use/Head-of-State Configured 

Transport Category Airplanes, and anticipated in the near future, approval of these 

exemptions will enable the United States manufacturers ofTransport Category 

Airplanes to effectively compete in this expanding market. 

2. Additional sales of United States VVlP/Government use/Head-of-State 

Configured interiors outside of the traditional airline market will serve to increase 

manufacturer's profitability and that of their supplying/supporting companies. 

3. Stability and improved financial performance of these United States companies 

gives greater job stability to the workers employed by the companies, causing a 

stabilizing influence to the greater United States economy, due to the consumer 

pending activities associated with stable workers. 

4. Improved financial performance of United States owned and operated 

corporations, and increased workforce stability translates into continued and 

improved local, state, and federal tax revenues which in turn adds to the stability 

of the total United States economy. 

5. Improved financial performance allows United States corporations to continue to 

invest in Research and Development, allowing the United States to maintain or 

improve its competitive position in the world economy. 

6. A large number of these types of airplanes will probably be sold to foreign clients, 

improving the United States balance of trade. 

7. This grant supports positive relations with the Heads-of-State of foreign countries 

operating US-built aircraft. 

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8. Foreign Heads-of-State operating US-manufactured aircraft strengthens the 

preeminent global position ofthe United States aircraft manufacturing, 

completion, and regulatory industry. 

9. These aircraft will be operated under 14 CFR 91 or 14 CFR 125 or its foreign 

equivalent. These aircraft will not be operated for hire or offered for common 

carriage, therefore there is no safety impact on the US flying public. 

10. The exemption request, if granted, allows the FAA to expend resources on this 

subject only this one time, not for each interior arrangement, and thereafter to 

concentrate resources on the FAA's highest priorities, including Continuing 

Operational Safety. 

Future Use and Application of the Exemption 

This Exemption is intended for use on current and future 747-8 interior programs by L-3 

Communications and its subsidiaries. Use and applicability of the Exemption will be 

controlled in the Project Specific Certification planning submitted to the applicable FAA 

Certification Office. 

Exemptions to specific rules and associated mitigating requirements are to be individually 

applied. There is no requirement that all portions of this Exemption be applied 

simultaneously. When the approved exemption to a specitic rule or rules is not used then 

full compliance to that rule or rules is required. 

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 first airplane is located in a 

foreign country. 

Federal Register publication 

A summary ofthe petition was published in the Federal Register on April 28, 2014 [79 FR 

2340 I]. No comments were received. 

The FAA's analysis 

The FAA has issued numerous exemptions for installation of interior doors on airplanes that are 

operated for private use only. We have been consistent with the requirement that the doors in 

category 2, 3, or 4, installed across the main cabin aisle, must open and close in a transverse 

direction. This is consistent also with SFAR I 09 paragraph 1 O(d) which requires "Doors installed 

across a longitudinal aisle must translate laterally to open and close, e.g., pocket doors." That is. 

the direction of motion of the door must be at a right angle to the longitudinal axis of the 

airplane. This is a condition that was included in exemption no. 10686 and from which the 

petition requests an exemption. This condition, along with the other conditions and limitations in 

this exemption, produces an acceptable level of safety for these types of airplanes operated for 

private use only. 

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In a forward-crash event, the major loading force is in the forward direction along the 

longitudinal axis of the airplane. When the direction of motion of the door is at a right angle to 

the longitudinal axis of the airplane, this forward-crash loading condition does not tend to close 

the doors. For the configurations the petitioner proposes, a forward-crash loading condition 

would tend to close the entire door or one half of the door opening for the doors across the maincabin aisle. The FAA considers this an important condition due to the possibility that, during a 

crash event, the doors could become unlatched as the result of fuselage deformations and/or 

structural failures. 

The petitioner has not proposed any additional compensating features for the proposed design 

that are not already required by the exemption or the operating regulations for the airplane. The 

FAA was unable to develop any additional compensating features that could be added to the 

petitioner· s proposal to restore the level of safety provided by the existing exemption conditions 

and limitations. 

The FAA does not find this petition to be in the public interest because it does not provide the 

level of safety the FAA requires for these "private-use only" airplanes with curved interior doors 

installed across the main cabin. 

The FAA's decision 

In consideration of the foregoing, I find that a grant of amended exemption is not in the public 

interest. Therefore, pursuant to the authority contained in 49 U .S.C. 40113 and 44 701 , delegated 

to me by the Administrator, I deny L-3 Communications Integrated System ·s petition for an 

exemption from§ 25.813(e) that would have allowed installation of interior doors installed 

across the main-cabin aisle, such that the direction of motion of the door is not at a right angle to 

the longitudinal axis of the airplane, on Boeing Model 747-8 airplanes. Exemption no. 10686 

remains in effect. 

AUG 2 2 2014 

Kevin Hull 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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