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27 September, 2010

Mr. Jayson Claar, 

Airframe and Cabin Safety Branch, ANM-115

Transport Airplane Directorate,

Aircraft Certification Service, 

Federal Aviation Administration, 

1601 Lind Ave. SW

Renton, Washington 98005-4056

cc: Mr. Ezra Sasson, Project Engineer

ANE-170, Special Certification Office

Subject: Amend Exemption 10133 issued to Jet Aviation Engineering Services L.P. by 

adding an exemption from the requirements of § 25.601 of Title 14, Code of 

Federal Regulations (14 CFR) for the Aft Lower Deck Alternating Tread 

Stairway.

References: 1. FAA Project no. ST5653NY-T Boeing 747-400, s/n 28343, HZ-HMI –

Saudi Arabia Head of State Aircraft, VIP Configuration.

2. FAA Exemption 10133

3. Docket number FAA-2010-0580

BACKGROUND 

Boeing 747-468, S/N 28343 is to be modified for use as a head of state VIP airplane. 

The Boeing Model 747-468 airplane is FAA approved under Type Certificate A20WE as 

a large Transport Category airplane that is limited to 660 passengers or less, depending 

on the interior configuration. The VIP interior configuration proposed for STC 

certification includes taxi, takeoff, and landing seating provisions for 72 passengers. 

One flight attendant only occupies the upper deck during taxi, take off, and landing. 

During flight nine passengers and one flight attendant can occupy the upper deck. The 

forward lower lobe passenger rest compartment is not occupied during taxi, takeoff, and 

landing. During flight 17 passengers and one flight attendant can occupy the forward 

lower lobe passenger rest compartment. These aspects have already been addressed 

in FAA exemption 10133. 

This amendment pertains to the installation of an alternating tread stair going from the 

Main Deck to the Aft Lower Galley Complex.
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Aft Lower Deck Alternating Tread Stair:

The aft lower cargo compartment is type approved as Class C. This compartment will 

be modified by removing the type approved cargo compartment container positioning 

system, cargo liner, smoke detection system and fire suppression system from the 

forward bulkhead to Fuselage Station 1720 and installing a galley complex as shown 

below that is occupiable only during flight. The remaining area of the aft lower cargo 

compartment will remain in the type-approved configuration as a Class C cargo 

compartment.

Figure 1

Aft Lower Deck Alternating Tread Stairs Plan View

The Aft Lower Deck Galley Complex is being certified to comply with 14CFR §25.819. In 

addition to §25.819, compliance with other cabin safety requirements including 

applicable portions of §25.785, §25.787, §25.789, §25.791, §25.793, §25.811, §25.812, 

§25.851, §25.853, §25.1301, §25.1359, §25.1439, §25.1441, §25.1443, §25.1445, 

§25.1447, §25.1449, §25.1451, §25.1541 and §25.1561 are in addition to compliance 

with the applicable structural and electrical requirements under 14 CFR Part 25. Smoke 

detection and smoke penetration tests are also part of the Aft Lower Deck Galley 

Complex certification §25.819. This compartment is placarded not to be occupied during 

taxi, takeoff and landing. The door leading to the Main Deck to this compartment is also

placarded to be latched closed during taxi, takeoff and landing. A double flight attendant

seat is installed between this door and Exit 4R. This compartment is restricted for 

occupancy by a maximum of four (4) flight and cabin crewmembers only. No

Cargo Door
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 passengers are permitted in this area and smoking is prohibited. Placards to that effect 

have been installed. The latching mechanism of the door leading to the Aft Lower Deck 

Alternating Tread Stairs complies with §25.783(j), Amendment 25-54. The evacuation 

routes, EXIT signage, the operation of the secondary escape hatch and evacuating a 

95th percentile male incapacitated occupant were satisfactorily demonstrated through 

both exits on 14-July-10 using the same criteria as specified in Exemption 10133 for the 

Forward Lower Lobe Passenger Rest Compartment and with the FAA observing.

Figure 2

Aft Lower Deck Alternating Tread Stairs Photo

(Aft Handrail removed for maintenance – Image annotated for visual reference)
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The Aft Lower Deck Alternating Tread Stairs consist of 8 alternating stair steps. The 

steps are slightly shallower than those on the Forward Lower Deck Alternating Tread 

Stair already covered by this exemption. With direct FAA participation, the Aft Lower 

Deck Alternating Tread Stairs were evaluated as part of the FAA interior compliance 

evaluation for the airplane interior. That compliance evaluation included evaluations of 

the nine (9) proposed limitations listed in the Basis For Exemption section below. The 

emergency lighting illumination measurements and the audio test of the PA system 

remain to be completed. Although the Aft Lower Deck Alternating Tread Stairs were 

found in general to be satisfactory and posed no inherent hazards to occupant safety, 

they were considered to be sufficiently unusual to require additional FAA scrutiny.

DISCUSSION

14CFR Part 25 of the Federal Aviation Regulations governs design certification of 

Transport Category aircraft. The primary intent of these regulations, as written, are to 

be certain that Aircraft Manufacturers provide for the appropriate design features in their 

respective aircraft 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 very clear these 

regulations are intended to regulate the certification of “commercial” aircraft, which are 

‘for hire’ to the general public.

While the greatest 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 aircraft is operated under CFR Part 91 and 91.501 and/or CFR Part 125, 

some of the 14 CFR 25 rules have acceptance criteria that are inappropriate, or are not 

compatible with this type of operation and the intended use of the aircraft.

Transport Category Aircraft intended for Private use, whether originally designed for 

private use or public, revenue-type operations and then utilized under CFR Part 91 or 

CFR Part 125, are used for personal (corporate) non-revenue operations, which 

represent significant operational differences from the typical revenue operation. The 

differences represented in these private operations can best be described as follows:

1. Operation is limited to the private use of an individual(s), Corporation, or 

Government and does not include public - for hire - operations.

2. Passenger capacity of the aircraft is significantly less than an equivalent aircraft 

in commercial operations. Typically, the capacity is less than 30% of that found in 

an airline configuration.

3. Flight and Cabin Crews are typically highly trained, and far more familiar with the 

individual aircraft they are operating, since it is normally the primary aircraft on 

which they perform their duties.
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4. Security is extremely high in terms of access to the aircraft while on the ground 

and with respect to individuals boarding the aircraft.

5. Passengers on these aircraft are typically repeat passengers, and represent 

corporate employees or individual owners and family members. As a result, the 

passengers are far more familiar with the layout of the individual aircraft and the 

associated emergency equipment and exits.

6. Custom interior layouts, furnishings, fixtures, furniture, cabinets, galleys, etc. are 

more representative of ‘Board Room’ type furnishings, than airline style interiors. 

Seat Pitch and Aisle Widths are typically substantially more spacious than an 

airline interior.

PETITION 

We respectfully request the FAA to issue an amendment to Exemption 10133 for the 

subject aircraft to 14 CFR §25.601, Amendment 25-0 by adding the Aft Lower Deck 

Alternating Tread Stairway.

This Petition is required due to the Kingdom of Saudi Arabia having determined these 

exemptions are necessary for the mission requirements for their head of state air 

transportation. 

BASIS FOR EXEMPTION

The aircraft that is the subject of this petition is a 747-400 aircraft. The aircraft is 

currently at the modification facility, Jet Aviation in Basel, Switzerland. It is a privately 

owned aircraft being modified with a head of state type interior.

In addition, Jet Aviation proposes the following conditions as part of the type design of 

the Aft Lower Deck Alternating Tread Stairway be added to Exemption 10133:

Aft Lower Deck Alternating Tread Stair:

The Aft Lower Deck Alternating Tread Stair must meet the following requirements:

1. The stairway must be straight with adequate step size to comfortably stand on 

both feet. Handrails on each side of the stairway must allow support at any 

position on the stairs and allow people to steady themselves during foreseeable 

conditions, including, but not limited to, moderate turbulence in flight. The 

handrails must be constructed, so that there will be no obstruction on them which 

will cause the user to release his/her grip on the handrail or will hinder the 

continuous movement of the hands along the handrail. Handrails must be 

terminated in a manner that will not obstruct pedestrian travel or create a hazard. 

Adequacy of the design must be demonstrated by using persons representative 

of the 5 percent female and the 95 percent male.
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2. General illumination must be provided so that, when measured along the 

centerlines of each tread of the stairway or ladder, the illumination is not less 

than 0.05 foot-candle. In normal operation, the general illumination level must not 

be less than 0.05 foot-candles. The assessment must be done under day light 

and dark of night conditions.

3. The stairway must accommodate the carriage of an incapacitated person from 

the lower lobe to the main deck. The crewmember procedures for such carriage 

must be established.

4. The stairway must be designed such that evacuees can achieve an adequate 

rate for going up under probable emergency conditions, including a condition in 

which a person falls or is incapacitated while on a stairway.

5. The stairway and ladder ends must be indicated by an exit sign visible to 

crewmembers when in the stairway. This exit sign must meet the requirements of 

§25.812(b)(1)(ii).

6. The public address system must be intelligible in the stairway during flight.

8. "No smoking" and "return to seat" signs must be installed and must be visible in 

the stairway both going up and down and at the stairway entrances.

9. Cabin crew procedures and positions must be established to manage the use of 

the stairs in flight under both normal and emergency situations. This may require 

that cabin crewmembers have specific dedicated duties for the management of 

the stairs during emergency and precautionary evacuations.

10. It should not be hazardous for crewmembers or passengers who are returning to 

their seats to use the stairway during moderate turbulence.

11. Access to the stairway will be secured when the lower lobe galley is not to be 

occupied.

IN THE PUBLIC INTEREST - The approval of this Petition to amend Exemption 10133 

would demonstrate the FAA’s willingness to deal with the issues involved with this 

Exemption, and would be in the Public Interest for the following reasons:

There is no degradation of safety involved with this request and therefore no detrimental 

impact to the public at large; and

1. Given the proliferation of Executive Configured Transport Category Aircraft 

currently taking place, and anticipated in the near future, this type of exemption 

will enable US manufacturers of transport category aircraft greater flexibility to 

effectively compete in this expanding market; and