Exemption No. 10686A
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION RENTON, WASHINGTON 98057-3356

In the matter ofthe petition of L-3 Communications Integrated Systems, L.P. for an exemption from§ 25.813(e) ofTitle 14, Code ofFederal 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
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. 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 ofFederal Regulations (14 CFR). The proposed exemption, ifgranted, would permit relieffrom the requirements and limitations specified in exemption no. 10686 that permit the installation ofinterior 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 ofan executive interior on Boeing Model 747-8 airplanes designated as "private use, not for hire, not for common carriage:· The petitioner requests relieffrom 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 ofTransportation·s Federal Docket Management System. on the Internet at http:/lt-c!!ulations.Qov, in Docket No. FAA-2012-0707.Discussion L-3 Communications Integrated Systems has been contracted by customers for interior completions ofVVIP/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 ofthe 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 ofa different population ofmore 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 tojustify 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 ofdoors that translate at right angles to the longitudinal aisle ofthe aircraft. L-3 's latest customer's design contains a rotunda-type entryway that has multiple aisles to other parts ofthe aircraft. Those aisles are not necessarily longitudinal aisles but are aisles to other compartments. Reliefis needed to allow the use ofstraight or curved pocket-type doors that translate across the direction oftravel. Basis for Exemption The aircraft that are the subjects ofthis 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 offoreign 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 ofthis 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
2experienced 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 ofthe original CFR. The exemption proposed herein arejustified 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 ofthe originally Type-Approved passenger load.

• SFAR I09, Special Requirementsfor Private Use Transport CategmyAircrqft, was issued in 2009 to address these issues among others. This SFAR is limited to aircraft with passenger counts of60 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 thesejustifications 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 ofthe 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 ofdoors 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-offand landing, each ofwhich will be capable of withstanding the inertia loads specified in 14 CFR 25

.561 ,



### 3• 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-offand 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-otTand landing. Requested Relief L-3 proposes to meet the requirements as stated in SFAR I09 and various Exemptions as:
• In lieu ofthe requirements ofSec. 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-offand landing.

o Each door between any passenger seat and any exit must have a dual means to retain it in the open position, each ofwhich is capable ofreacting the inertia loads specified in Sec. 25.561.

o The direction ofmotion ofany straight or curved doors installed across an aisle must be across the direction ofmotion ofthe occupant, e.g., pocket doors are one example ofsuch 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 ofintercompartment 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 ifa locking mechanism is installed, it must be capable of being unlocked from either side without the use ofspecial 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 offlight 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 ofthe airplane to ensure the safety ofthe passengers and crew. Public Interest 

### As in the cases ofnumerous already established Exemptions, granting this petition for exemption would be clearly in the public interest ofthe people ofthe 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 ofthese exemptions will enable the United States manufacturers ofTransport Category Airplanes to effectively compete in this expanding market. 2. Additional sales ofUnited States VVlP/Government use/Head-of-State Configured interiors outside ofthe traditional airline market will serve to increase manufacturer's profitability and that oftheir supplying/supporting companies. 3. Stability and improved financial performance ofthese United States companies gives greaterjob 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 ofUnited 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 ofthe 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 ofthese types ofairplanes will probably be sold to foreign clients, improving the United States balance oftrade. 7. This grant supports positive relations with the Heads-of-State offoreign countries operating US-built aircraft.

58. 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, ifgranted, 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 ofthe 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 ofthe 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 ofthis 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 ofthis exemption outside the United States since the operator ofthe first airplane is located in a foreign country. 

### FederalRegister publication A summary ofthe petition was published in the Federal Register on April 28, 2014 [79 FR 2340I]. No comments were received. The 

### FAA's analysis The FAA has issued numerous exemptions for installation ofinterior 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 I09 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 ofmotion ofthe door must be at a right angle to the longitudinal axis ofthe 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 ofsafety for these types ofairplanes operated for private use only.



### 6In a forward-crash event, the major loading force is in the forward direction along the longitudinal axis ofthe airplane. When the direction ofmotion ofthe door is at a right angle to the longitudinal axis ofthe airplane, this forward-crash loading condition does not tend to close the doors

. For the configurations the petitionerproposes, a forward-crash loading condition would tend to close the entire door or one halfofthe 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 offuselage 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 ofsafety 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 ofsafety the FAA requires for these "private-use only" airplanes with curved interior doors installed across the main cabin. 

### The FAA's decision In consideration ofthe foregoing, I find that a grant ofamended exemption is not in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701 , delegated to me by the Administrator, Ideny L-3 Communications Integrated System·s petition for an exemption from§ 25.813(e) that would have allowed installation ofinterior doors installed across the main-cabin aisle, such that the direction ofmotion ofthe door is not at a right angle to the longitudinal axis ofthe 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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