1 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. g dcte ch nics .c o m November 7 , 201 4 U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Floor Room W12
- 140 Washington, DC 2059 0 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: G DC 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. T he airplanes are not fo r public hire and they are configured to carry a fraction of the passenge rs carried in airline service. For these reasons, G DC Technics , Ltd. has prepared a petition for exemption to the following regulation: 14 CFR §25. 813 (e) , Amendment 25
- 128
- No door m ay 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 ce rtification of transport category airplanes

. The primary intent of these regulations, as written, are to be certain that air plane2 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. g dcte ch nics .c o m manufacturers provide the appropriate design features to meet the standards necessary to protect the traveling public. Clearl y, 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 regard less 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 th e type of operation and the intended use of th is airplane

. The FAA recognizes these differences as evidenced by the is suance of exemptions which eliminate many of the more onerous regulations when applie d 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 req uirements

. 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 airplan e 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 L 1, two seats at door L2 , one seat each each at doors L3 and R3, and four seats in the doo r 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 th e 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) 109.3 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. g dcte ch nics .c o m Regulation 14 CFR §25. 813(e) T he master bedroom, m aster bathroom and private m ajlis comprise the VVIP suite of the aircraft. The private m ajlis contains 4 TTL seat positions and is located at Type A exit R2 . The private m ajlis is accessed from the main e ntry area through a 40 inch wide opening i n 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 condition s 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 ai sle. The double pocket type door translates longitudinally a cross 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 de scribed in the “Occupancy Safety Considerations” sect ion 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 betwee n the main entry and private m ajlis 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 s pecified 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)).4 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. g dcte ch nics .c o m  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 ma nually 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), t he 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 condition s 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:

 I t 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 degra dation of safety involved with this request , wh ich applies to a private use aircraft. There is no detrimental impact to the public at large,5 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. g dcte ch nics .c o m  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 stand ards and helps to insure the aircraft would be eligible for future U.S. registration.
PUBLIC COMMENT: In accordance with 14 CFR 11. 87, G DC 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 G DC Technics , Ltd. Phone : 210
-496
-5614 Ext 5222 Cell : 210
-616
- 1825 Email : mark.creager@g dctechnics .com
cc: Bill Vickers, ASW
- 190, Special Certification Offi ce Enclosure: Floor Plan , Door Latch Layout6 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. g dcte ch nics .c o m 

### ADDENDUM7 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. g dcte ch nics .c o m8 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. g dcte ch nics .c o m