## Petition for Exemption from 14 CFR §§ 25.785(h)(2) 9 25.7850), 25.791(a),

25.795, 25.813(e), 25.815, and 25.853(d).

Petitioner: L-3 Communications Integrated Systems, L.P.

7601 Maehr Road P.O. Box 154580 Waco, Texas 76715-4580

Attn: Mr. Phillip T. Crawford, P.E. ODA Administrator (254) 867-4514 phillip.t.crawford@L-3com.com

L-3 Communications Integrated Systems, L.P., petitions the Federal Aviation Administration (FAA) for exemption from the following sections of Title 14, Code of Federal Regulations (14 CFR): 25.785(h)(2), 25.7850), 25.791(a), 25.795, 25.813(e), 25.815, and 25.853(d). The proposed exemption, if granted, would permit relief from the requirements of flight-attendant direct view, firm handholds in the passenger cornpartment, no-smoking placards, security considerations, interior doors between passenger compartments, aisle width, and maximum heat-release and smoke-emissions flammability requirements for large interior panels. The proposed exemption is specifically intended for application to executive interiors on Boeing Mode1787-series airplanes designated as "private use, not for hire, not for common carriage."



### TjZe ])etltlolZel" Y'ef/LtestS 1"eZlef f/"o11Z th8 {olZOwlt2L' reE'LllfLtlolZS: Section 25.785(h)(2), Amendment 25-88 "To the extent possible, without compromising proximity to a required floor level emergency exit, located to provide a direct view of the cabin area for which the flight attendant is responsible" Section 25.7850), Amendment 25-88 "If the seat backs do not provide a firm handhold, there must be a handgrip or rail along each aisle to enable persons to steady themselves while using the aisles in moderately rough air." Section 25.791(a), Amendment 25-72 "If smoking is to be prohibited, there must be at least one placard so stating that is legible to each person seated in the cabin. If smoking is to be allowed, and if the crew compartment is separated from the passenger compartment, there must be at least one sign notifying when smoking is prohibited. Signs which notify when smoking is prohibited must be operable by a member of the flightcrew and, when illuminated, must be legible under all probable conditions of cabin illumination to each person seated in the cabin."

Section 25.795, Amendment 25-106 "Protection of flightcrew compartment . . ." Section 25.813(e), Amendment 25-128 "No door may be installed in any partition between passenger compartments."

0Section 25.815, Amendment 25-38 "The passenger aisle width at any point between seats must equal or exceed the values in the following table: Minimum passenger aisle width

Passenger seating (inches) Less than 25 25 inches and capacity inches from more from floor

floor 10 or less---------------- 12* 15 11 through 19---------- 12 20 20 or more-------------- 15 20 *A narrower width not less than 9 inches may be approved when substantiated by tests found necessary by the Administrator." Section 25.853(d), Amendment 25-116 "Except as provided in paragraph (e) of this section, the following interior components of airplanes with passenger capacities of 20 or more must also meet the test requirements of parts IV and V of appendix F of this part, or other approved equivalent method, in addition to the flammability requirements prescribed in paragraph (a) of this section: (1) Interior ceiling and wall panels, other than lighting lenses and windows; (2) Partitions, other than transparent panels needed to enhance cabin safety; (3) Galley structure, including exposed surfaces of stowed carts and standard containers and the cavity walls that are exposed when a full complement of such carts or containers is not carried; and (4) Large cabinets and cabin stowage compartments, other than underseat stowage compartments for stowing small items such as magazines and maps."

Discussion L-3 Communications Integrated Systems has been contracted by a customer for an interior completion of a VVIP/Government/Head-of-State business interior in a Boeing Model 787-8 airplane. L-3 ODA-750154-SW has submitted an STC application to conduct the program under Project Number P-14-006. The certiflcation basis for the Boeing 787-8 is 14 CFR 25, Amendment 25-1 through 25-119 and 25-120, 25-124, 25-125 and 25-128 with reversions, later amendments, Exemptions, and Special Conditions as shown in FAA Type Certificate Data Sheet T00021SE. 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 service (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 rnitigating design requirements and operationallimitations to justify similar exemptions to 787-series aircraft modified for VVIP/Government/Head-of-State, notfor-hire-or-common-carriage service.

NBasis for Exemption

The aircraft that are the subject of this petition are Boeing Model 787-series airplanes modified for noncommercial/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 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 exemptions proposed herein are justified based upon the following facts: • These aircraft are intended for VVIP/Government/Head-of-State use and are 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 TypeApproved passenger load. • SFAR 109 Special Requirements for Private Use Transport Category Aircraft was issued in 2009 to address these issues among others. This SFAR is limited to aircraft with passenger counts of 60 or less. This exemption will apply similar requirements to the larger aircraft. • Similar exemptions have been routinely granted for VIP transport category aircraft for many years. For example: Exemptions 10686, 10339, 6820/6820A, 6881, 7317/7317A, 7609, and 8765 as well as others have been either fully or partially granted by FAA. • These exemptions have been granted to both domestic and foreign applicants and applied equally to both domestically-produced aircraft and foreign-produced 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 requeats relief from and proposes a petition for exemption from the listed regulations.

14 CFR 25.785(h)(2): Direct View

Discussion This aircraft interior is designed to accommodate VVIP/Government use/Head-of-State personnel and staff members. These types of passengers require amenities such as meeting rooms, offices, bedroorns, lavatories, and lounges rather than tradational airline type seating. Furthermore they require a high level of privacy and security that is normally not available in airline-style interiors. An exemption to the flight attendant direct view requirement is therefore needed to allow the interior to meet these needs. As discussed in FAA Exemption 6820, the Direct-View requirement was incorporated into the FAA rules at amendment 25-51. During the rulemaking process FAA concluded that the ". .. location of the flight attendant seats near the floor level exits ... is more important than the requirement to have a direct view of the cabin." The fmal rule was revised from the NPRM proposal to state this. Further SFAR 109 set more flexible standards for this type of intended usage. Occupant Safety Considerations Considering the smaller number of occupants in the VVIP/Government use/Head-of-State aircraft, the familiarity of the flight and cabin crews with the specific airplane, its passengers and its interiorarrangement, and the wording of the existing rale that places the emphasis for safety on the proximity of the exit to the attendant over the ability of the attendant to view the cabin area, there should be no degradation in the passenger safety as a result of this requested exemption. Requested Relief L-3 proposes to meet the requirements as stated similarly in SFAR 109 and various Exemptions as: In lieu of the requirements of Sec. 25.785(h)(2), to the extent practical without compromising proximity to a required floor level emergency exit, the majority of installed flight attendant seats must be located to face the cabin area for which the attendant in responsible.

14 CFR 25.785(i): Firm Handholds

Discussion The current layout for the proposed VVIP/Government use/Head-of-State interior in some areas is quite different from the airliner-type interior envisioned by the original rule. The proposed interior includes some large rooms or meeting areas where the originally envisioned requirernent for firm hand hold along the aisles cannot be met. A typical airliner interior rneets this requirement by the relying on the individual seat backs along the main aisle(s). Any ceiling mounted handhold would ruin the appearance of the high quality interior and has the potential to create additional safety concerns. Occupant Safety Considerations The risk for occupants due to the reduced number of direct hand holds in certain areas of the airplane should be considered acceptable for the following reasons: • In the various compartments seat backs, divan arms, tables, and farniture are readily within reach with one or two steps, • All furniture in the passenger cabin will not have sharp corners and edges in order to avoid serious injury in case of contact during turbulence, • The installed seat[s] and divans are heavily upholstered and will not cause injuries when contacted, • The Airplane Supplemental Flight Manual will contain a recommendation that passengers remain seated with their seat belts fastened in case of announced turbulence during flight, • Occupants are experienced travelers and are generally familiar with this aircraft's interior. Requested Relief L-3 proposes to meet the requirements as stated similarly in SFAR 109 and various Exemptions as: In lieu of the requirements of Sec. 25.7850), there must be means provided to enable persons to steady themselves in moderately rough air while occupying aisles that are along the cabin sidewall, or where practicable, bordered by seats (seat backs providing a 25-pound minimum breakaway force are an acceptable means of compliance).

14 CFR 25. 791(a): No Smokinz Placards

Discussion The proposed VVIP/Government use/Head-of-State aircraft is intended as a NO SMOKING aircraft. The aircraft are declared to be "No Smoking" aircraft and are placarded as such in accordance with applicable

4regulations and exemptions. The Passenger pre-flight briefing will include an announcement that the aircraft is a". .. No Smoking ..." aircraft. Occupant Safety Considerations There is no safety risk for occupants due to the special placement requirements of NO SMOKING placards. Requested Relief L-3 proposes to meet the requirements as stated similarly in SFAR 109 and various Exemptions as: Compliance with Sec. 25.791 is required except that for Sec 25.791(a), when smoking is to be prohibited, notification to the passengers may be provided by a single placard so stating, to be conspicuously located inside the passenger compartment, easily visible to all persons entering the cabin in the immediate vicinity of each passenger entry door. A statement that the aircraft is a". .. No Smoking Aircraft ..." will be added to the pre-takeoff passenger briefing.

14 CFR 25. 795: Securitp Considerations Discuss'ion and Occupant Safety ConsiderationsThe current usage of the proposed VVIP/Government use/Head-of-State aircraft is not-for-hire and not-forcommon-carriage. The requirements of 25.795 are intended for the safety of the airline public and not for users whose security levels are maintained at much higher than airline levels. SFAR 109 exempts Private use aircraft from this paragraph entirely. For these reasons the requirements of this paragraph are unnecessary and non-applicable. Requested Reflef L-3 proposes to meet the requirements as stated similarly in SFAR 109 and various Exemptions as:The requirements of Sec. 25.795 are not applicable to airplanes limited to VVIP/Government use/Head-ofState usage.

14 CFR 25.813(e): Doors Between Passenger Comnartments

Discussion This discussion covers doors that separate passenger compartments throughout the aircraft. This discussion does not include doors or folding partitions that separate non-passenger 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 of which are able to withstand the forces defined 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. This exemption request is different from existing Boeing 787 Exemption 10879 which permits doors on mini-suites in the passenger compartment but has many of the same mitigating features. Occupant Safety Considerations The risk for occupants due to the use of doors between passenger compartments should be considered acceptable for the following reasons:

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### 7• Any door between passenger comparhnents 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, • Doors to compartments that are unoccupied during Taxi/Takeoff/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 AFMS will provide procedures and limitations to ensure that the doors are in the proper position for takeoff and landing. Requested Relief L-3 proposes to meet the requirements as stated sirnilarly in SFAR 109 and various Exemptions as: o In lieu of the requirements of Sec. 25.813(e), interior doors may be installed between passenger seats and exits, provided the following requirements are met: • Each door between any passenger seat, occupiable for taxi, takeoff, and landing, and any emergency exit must have a means to signal to the flightcrew, at the flightdeck, that the door is in the open position for taxi, takeoff and landing. • Appropriate procedures/limitations must be established in the AFM to ensure that any such door is in the open configuration for takeoff and landing. • Each door between any paasenger seat and any exit must have dual means to retain it in the open position, each of which is capable of reacting the inertia loads specified in Sec. 25.561. • Doors installed across a longitudinal aisle must translate laterally to open and close, e.g., pocket doors. • 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 inter-compartment door installation in the aircraft using a 5th percentile female subject. • Each door between any passenger seat and any exit must be operable 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. o When the aircraft is equipped with interior doors under this Exernption: • 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.

14 CFR 25.81 S: Width ofAisle Discussion and Occupant Safety Considerations This discussion covers the requirements for maintaining appropriate width of aisle during operation L-3 is installing seats that translate laterally and longitudinally and also recline. Translating and/or reclining of seats will occur in flight only but can encroach on the aisle width required by Section 25.815. The risk for occupants in the passenger cabin due to reduced width of aisle in-flight should be considered acceptable for the following reasons: • The number of passengers is substantially less than the aircraft was originally certified for.



### 2• The passengers who use these aircraft are a small population with higher-than-usual familiarity with the aircraft interior and systems. • The number of Flight Attendants and Staff is high relative to typical airline operations. • Aisle width is only to be reduced during in-flight operation. • Reduced aisle width does not restrict access to any cabin area because each area is accessible from multiple directions. • Procedures will be established to ensure that the cabin can be restored to proper configuration for Taxi, Takeoff, and Landing. • The aircra$ will not be operated for hire or common carriage. Requested Relief L-3 proposes to meet the requirements as stated similarly in SFAR 109 and various Exemptions as: Compliance is required with Sec. 25.815, except that the aisle width may be reduced to zero (0.00) inches between passenger seats during in-flight operations only, provided that the applicant demonstrates that (1) All areas of the cabin are easily accessible by a crew member in the event of an emergency (e.g. inflight fire, decompression), (2) Instructions are provided at each passenger seat for restoring the aisle width required by Sec. 25.815, (3) The operation to return the cabin furnishings to their proper TT&L positions has been demonstrated as being easily accornplished by naive test subjects, (4) Procedures must be established and documented in the AFM to ensure that the required aisle widths are provided during Taxi, Takeoff, and Landing.

14 CFR 25.853(d): HeatRelease and Smoke Emission Cornpletion centers have been able to simultaneously satisfy both the styling requirements of customers and the interior material flammability requirements of § 25.853(a) and (c); however, many of the materials required in these aircraft interiors do not comply with the heat release and smoke emission requirements of § 25.853(d). Occupant Safety Considerations The vast majority of the heat release and smoke portion of the rule was driven by the post-crash fire experiences in airline operations. The 65/65 heat release regulation was specifically developed to reduce the likelihood of the flash-over phenomenon which was proven by tests to be a prime contributor to the rapid propagation of post-crash cabin interior fires and the generation of blinding smoke. Rapid fire propagation combined with the relatively slow rate of passenger evacuation from densely packed air carrier airplanes has proven to be a deadly combination during actual airline accidents. Since it is clear that material selection is being controlled by aesthetics in this application, we cannot exercise any real control over the actual heat release but the exposure time to this heat release is still within our control. Therefore, it is proposed as a flrst step in mitigating the fare hazard that an evacuation analysis be performed to show that all souls on board can be safely evacuated in less than 45 seconds. Requested Relief L-3 proposes to meet the requirements as stated similarly in SFAR 109 and various Exemptions as: Compliance is required with the applicable provisions of Sec. 25.853, except that compliance with appendix F, parts IV and V, need not be demonstrated if it can be shown by analysis that the maximum time for evacuation of all occupants does not exceed 45 seconds under the conditions specified in appendix J to part 25.



### ©Public Interest

As in the cases of numerous already established Exemptions, granting this petition for exemption would be clearly in the public interest of the people of the United States of America for the following reasons:

1. Given the proliferation of WIP/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 of Transport Category Airplanes to effectively compete in this expanding market. 2. Additional sales of United States WIP/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 Reaearch 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. 8. Foreign Heads-of-State operating US-manufactured aircraft strengthens the preeminent global position of the 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 787-series interior programs by L-3 Cornmunications 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 specific 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 airplane is located in a foreign country.

Public Comment In accordance with 14 CFR 11.87, L-3 requests that the period for public comment be waived because numerous similar exemptions have previously been granted. Granting this petition will not set a precedent, the relief requested is identical to exemptions granted previously, and this petition has been filed in a timely manner.

E:3SUMMARY OF LIMITATIONS AND ADDITIONAL REQUIREMENTS

Limitations applicable to all exemptions petitioned for herein. When this Exemption is used for any of the regulations covered by this Exemption the following limitations are required: • The aircraft may not be offered for common carriage or operated for hire. The Operating Limitations section of the AFM must be revised to prohibit any operations involving the carriage of persons or property for compensation or hire. The operators may receive remuneration to the extent consistent with 14 CFR 125 and 14 CFR 91 Subpart F. • A placard is required stating that "Operations involving the carriage of persons or property for compensation or hire are prohibited", rnust be located in the area of the Airworthiness Certificate holder at the entrance to the flightdeck. • In order for the airplane to be placed in 14 CFR 135 or 14 CFR 121 operations, the airplane must be brought back into full compliance with the applicable operational part.

Limitations applicable to rule-specific exemption requirements. In addition to the general limitations listed above the following specific limitations and requirements apply when making use of this exemption related to a specific rule. • 14 CFR 25.785(h)(2) Direct View o In lieu of the requirements of Sec. 25.785(h)(2), to the extent practical without compromising proximity to a required floor level emergency exit, the majority of installed flight attendant seats must be located to face the cabin area for which the attendant in responsible. • 14 CFR 25.7850) Firm Handholds o In lieu of the requirements of Sec. 25.7850), there must be means provided to enable persons to steady themselves in moderately rough air while occupying aisles that are along the cabin sidewall, or where practicable, bordered by seats (seat backs providing a 25-pound minimum breakaway force are an acceptable means of compliance). 14 CFR 25.791(a) No Smoking Placards o Compliance with Sec. 25.791 is required except that for Sec 25.791(a), when smoking is to be prohibited, notification to the passengers may be provided by a single placard so stating, to be conspicuously located inside the passenger compartment, easily visible to all persons entering the cabin in the immediate vicinity of each passenger entry door. A statement that the aircraft is a ". .. No Smoking Aircraft ..." will be added to the pre-takeofPpassenger briefing. • 14 CFR 25.795 Security Considerations o The requirements of Sec. 25.795 are not applicable to airplanes limited to VVIP/Government use/Head-of-State usage. 14 CFR 25.813(e) Doors Between Passenger Compartments o In lieu of the requirements of Sec. 25.813(e), interior doors may be installed between passenger seats and exits, provided the following requirements are met. • Each door between any passenger seat, occupiable for taxi, takeoff, and landing, and any emergency exit must have a means to signal to the flightcrew, at the flightdeck, that the door is in the open position for taxi, takeoff and landing. • Appropriate procedures/limitations must be established in the AF1V1 to ensure that any such door is in the open configuration for takeoff and landing.• Each door between any passenger seat and any exit must have dual means to retain it in the open position, each of which is capable of reacting the inertia loads specified in Sec. 25.561. • Doors installed across a longitudinal aisle must translate laterally to open and close, e.g., pocket doors. • 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 inter-compartment door installation in the aircraft using a 5th percentile female subject. • Each door between any passenger seat and any exit must be operable 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. o When the aircraft is equipped with interior doors under this Exemption: • The airplane flight manual (AFM) rnust 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 lirnitation(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.

14 CFR 25.815 Width of Aisle o Compliance is required with Sec. 25.815, except that the aisle width may be reduced to zero (0.00) inches between passenger seats during in-flight operations only, provided that the applicant demonstrates that • All areas of the cabin are easily accessible by a crew member in the event of an emergency (e.g. in-flight fire, decompression), • Instructions are provided at each passenger seat for restoring the aisle width required by Sec. 25.815, • The operation to return the cabin furnishings to their proper TT&L positions has been demonstrated as being easily accomplished by naive test subjects, • Procedures must be established and documented in the AFM to ensure that the required aisle widths are provided during Taxi, Takeoff, and Landing. • 14 CFR 25.853(d) Heat Release and Smoke Emission o Compliance is required with the applicable provisions of Sec. 25.853, except that compliance with appendix F, parts IV and V, need not be demonstrated if it can be shown by analysis that the maximum time for evacuation of all occupants does not exceed 45 seconds under the conditions specified in appendix J to part 25.

Submitted on November 19, 2014 For L-3 Comm nications Integrated Systems, L.P. 

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ODA-750154-SW

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