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G D C T E C H N I C S , L T D

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www. gdcte ch nics.c o m

November 7, 2014

U.S. Department of Transportation

Docket Management Facility

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12-140

Washington, DC 20590

SUBJECT: Petition for Exemption from §25.813(e) doors between passenger

compartments on a Boeing 787-8 airplane.

Ref: FAA STC Project no. ST09858SC-T

BACKGROUND:

GDC Technics, Ltd (GDC) has been contracted for the completion of a VIP interior in a

Boeing 787-8 airplane and has applied for a Supplemental Type Certificate (STC) for

this modification. The certification basis of the Boeing 787-8 is 14 CFR Part 25, Amendment 25-119

and Amendments 25-120, 25-124, 25-125, and 25-128 with the following exception:

14 CFR §25.1309, Amdt 25-119. There are also numerous exemptions, special

conditions and equivalent safety findings.

There are good technical arguments to support special consideration for private use

airplanes: Customers are buying these large airplanes as an extension of the office and

are requiring privacy areas within the airplane sometimes spanning the whole cabin,

such as board rooms, bedrooms, lavatories, and lounges rather than traditional airline

type seating. The airplanes are not for public hire and they are configured to carry a

fraction of the passengers carried in airline service. For these reasons, GDC Technics, Ltd. has prepared a petition for exemption to the following regulation:

14 CFR §25.813(e), Amendment 25-128 - No door may be installed between any

passenger seat that is occupiable for takeoff and landing and any

passenger emergency exit, such that the door crosses any egress path

(including aisles, crossaisles and passageways). DISCUSSION:

14 CFR Part 25 governs design certification of transport category airplanes. The

primary intent of these regulations, as written, are to be certain that airplane
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manufacturers provide the appropriate design features to meet the standards necessary

to protect the traveling public. Clearly, there is a requirement “in the public interest” and

in the interest of safety to provide regulatory guidelines for certification. However, it is

also clear these regulations are intended to regulate the certification of “commercial”

airplanes, which are “for hire” to the general public.

While the majority of these regulations represent a common sense inclusion for any

aircraft regardless of its intended use, a few are obviously intended to regulate

situations that are specific to an airline, or for hire operation. When a transport category

airplane is operated under 14 CFR Part 91 or Part 125, some of the Part 25 rules have

acceptance criteria that are inappropriate, or are not compatible with the type of

operation and the intended use of this airplane. The FAA recognizes these differences as evidenced by the issuance of exemptions

which eliminate many of the more onerous regulations when applied to “private use,

not-for-hire” operations under 14 CFR Part 91 and Part 125. BASIS FOR EXEMPTION:

The airplane that is the subject of this petition is a Boeing 787-8. It is privately owned

and will be operated in compliance with Part 125 operational requirements. 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

Saudi Arabia. The interior configuration being installed in this airplane is planned to provide seating for

fifty three (53) passengers (see addendum for floor plan drawing) for taxi, takeoff, and

landing (TTL) – 2 passengers in the forward passageway, 4 passengers in the private

majlis, 12 passengers in the main majlis, 10 passengers in the dining lounge and 25

passengers in the staff seating area.

The remaining nine seats in the cabin are for use by cabin attendants – one seat at door

L1, two seats at door L2, one seat each each at doors L3 and R3, and four seats in the

door 4 area. The maximum certified passenger count for this airplane, as noted in type

certificate data sheet (TCDS) T00021SE is 300 seats with two pairs of Type C and two

pairs of Type A exits. The passenger count of the subject airplane represents 18% of

the capacity allowed for this airplane.

Since the passenger count on the airplane is less than sixty, GDC has chosen to

comply with the applicable provisions of Special Federal Aviation Regulation

(SFAR) 109.
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G D C T E C H N I C S , L T D

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Regulation 14 CFR §25.813(e)

The master bedroom, master bathroom and private majlis comprise the VVIP suite of

the aircraft. The private majlis contains 4 TTL seat positions and is located at Type A

exit R2. The private majlis is accessed from the main entry area through a 40 inch wide

opening in the bulkhead assembly between the compartments. This 40 opening also

serves as the unobstructed cross aisle between exits L2 and R2 during TTL conditions.

A double pocket type door installed across the 40 inch entry can be closed during non- TTL conditions to provide privacy for the occupants of the VVIP Suite and is thus an

integral feature of the configuration.

SFAR 109 does not address doors installed across a lateral aisle. The double pocket

type door translates longitudinally across the lateral aisle between exits L2 and R2. This

door will meet the conditions of SFAR 109, section 10, paragraphs (a)(b)(c)(e)and (f),

and will have additional features to compensate for the requirements of SFAR 109,

section 10, paragraph (d). The additional features are described in the “Occupancy

Safety Considerations” section and are intended to restore the level of safety provided

by SFAR 109 by eliminating the possibility that one or both of the doors could block the

cross aisle during a forward-crash loading condition.

OCCUPANT SAFETY CONSIDERATIONS:  14 CFR §25.813(e)

The risk for occupants due to the location of the door between the main entry and

private majlis should be considered acceptable for the following reasons:  The door will have cockpit annunciation to indicate the door is in the stowed

position for TTL (SFAR 109, section 10, paragraph (a)).  The AFMS will provide procedures and limitations to ensure that the door is in

the proper position for takeoff and landing, and the door will have a placard

providing instructions that the door is to be secured in the stowed position for

takeoff and landing (SFAR 109, section 10, paragraph (b)).  Both of the moveable door panels will have dual means to secure the door panel

in the stowed position for takeoff and landing, each of which will be capable of

withstanding the inertia loads specified in 14 CFR §25.561 (SFAR 109, section

10, paragraph (c)).  It will be substantiated by demonstration that if the doors are in a deployed

position, a 95th percentile male and a 5th percentile female can still exit through

the door without additional assistance (SFAR 109, section 10, paragraph (e)).
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 The door will be operable from either side, and if a locking mechanism is

installed, it will be capable of being unlocked from either side without the use of

special tools (SFAR 109, section 10, paragraph (f)).  Electrical power will be disabled when door is stowed during TTL conditions.  It will be demonstrated that the doors can be readily stowed manually for TTL if

electrical power is lost, or in case of mechanical failure.  As an additional feature to compensate for the requirements of SFAR 109,

section 10, paragraph (d), the door installation will provide dual bolts to secure

the door panels to their adjacent bulkheads for TTL conditions. These bolts will

be such that a seated and belted occupant would not be able to operate them. The bolts will be shown by demonstration or analysis that the door panels will

remain secured under conditions of rough landing or inadvertent abuse, or due to

distortion of the fuselage or furnishings. This will insure the minimum 36 inch

cross aisle between exits 2R and 2L, and preserve the egress capability of the

Type A exit configuration. The bolts will have the dual cockpit annunciation

required by SFAR 109, section 10, paragraph (a) and are an addition to the dual

latches required by SFAR 109, section 10, paragraph (c).  The airplane will comply with 14 CFR Part 125 operational requirements and will

not be operated for hire or offered for common carriage.  The systems and procedures described above will ensure the door will be open

and remain open for TTL and that the safe evacuation of passengers will not be

compromised.  The petition proposes and alternate method for achieving an appropriate level of

safety while providing the operator with a comfortable and private VIP suite

consistent with other aircraft in their fleet.

PUBLIC INTEREST:

Granting this petition for exemption would be in the public interest for the following

reasons:  It allows efficient and safe carriage of Head of State and executives in the sought

for environment providing a very high level of privacy and comfort on long haul

flights. There is no degradation of safety involved with this request, which applies

to a private use aircraft. There is no detrimental impact to the public at large,
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 Increased sales of these executive configured transport airplanes will ultimately

result in some portion of those airplanes being completed at GDC, providing

improved financial performance and work force stability for the organization,  Improved financial performance of GDC and increased work force stability

translates into continued and improved tax revenue for all governmental

organization involved,  Improved financial performance will permit GDC to continue to invest in new

research, development and workforce training which will allow GDC to maintain

or improve its competitive position in the industry,  A large number of these types of sales can be predicted to be to “offshore”

clients, improving the US balance of trade deficit. Although the aircraft may be

foreign registered, the operators recognize that a modification approved via an

FAA supplemental type certificate (STC) meets the highest airworthiness

standards and helps to insure the aircraft would be eligible for future U.S.

registration.

PUBLIC COMMENT:

In accordance with 14 CFR 11.87, GDC Technics, Ltd., requests that the period for

public comment be waived because of numerous similar exemptions that have

previously been granted.

Sincerely,

Mark Creager

Certification Manager

GDC Technics, Ltd.

Phone: 210-496-5614 Ext 5222

Cell: 210-616-1825

Email: mark.creager@gdctechnics.com

cc: Bill Vickers, ASW-190, Special Certification Office

Enclosure: Floor Plan, Door Latch Layout
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G D C T E C H N I C S , L T D

607 N .F ra nk L uke D r ive -Sa n Anto nio T X 7 8226 -US A-210. 496 .5 614-F AX 210.9 23 -3 3 28

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ADDENDUM
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G D C T E C H N I C S , L T D

607 N .F ra nk L uke D r ive -Sa n Anto nio T X 7 8226 -US A-210. 496 .5 614-F AX 210.9 23 -3 3 28

www. gdcte ch nics.c o m
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G D C T E C H N I C S , L T D

607 N .F ra nk L uke D r ive -Sa n Anto nio T X 7 8226 -US A-210. 496 .5 614-F AX 210.9 23 -3 3 28

www. gdcte ch nics.c o m