Petition for Exemption from 14 CFR 25.813(e). 

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

7601 Maehr Road 

P.O. Box 154580 

Waco, Texas 76715-4580 

Attn: Loyd R. Hamilton 

ODA Administrator 

(254) 867-4277 

Loyd.R.Hamilton@L-3com.com 

L-3 Communications Integrated Systems, L.P., submits to the Federal Aviation Administration (FAA) this petition 

for exemption from the following section of Title 14, Code of Federal Regulations (14 CFR) 25.813(e). 

The proposed exemption, if granted, would permit relief from the requirements of interior doors between passenger 

compartments. The proposed exemption is specifically intended for application to executive interiors on Boeing 

Model 747-8 airplanes designated as "private use, not for hire, not for conunon carriage." 

The petitioner reguests relief frorn the following rezulation: 

Section 25.813(e), Amendment 25-46 

"No door may be installed in any partition between passenger compartments." 

Discussion 

L-3 Communications Integrated Systems has been contracted by customers for interior completions of 

VVIP/Government/Head-of-State business interiors in more than one Boeing Model 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 P-12-001. The certification basis for the Boeing 747-8 is 14 CFR 25, Amendment 25-1 

through 25-120 with reversions, 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 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 comrnon 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 mitigating design requirements and operational 

limitations to justify similar exemptions to 747-8 aircraft modified for VVIP/Government/Head-of-State, not-forhire-or-common-carriage service. 
Basis for Exemution 

The aircraft that are the subjects of this petition are Boeing Model 747-8s modified for non-commercial/noncornmon-carriage VVIP/Government use/Head-of-State service. They are typically in the service of foreign Headsof-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 exemption proposed herein are justified 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 of the originally TypeApproved passenger load. 

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 requests relief from and proposes a 

petition for exemption from the listed regulations. 

14 CFR 25.813(e): Doors Between Passen2er Compartments 

Discussion 

This discussion covers curved pocketing doors that separate passenger compartments throughout the 

aircraft and do not operate transversely to the longitudinal axis of the airplane. This discussion does not 

include doors or folding partitions that separate non-passenger compartments and, therefore, these doors do 

not apply to this exemption request. Curved pocketing doora between passenger compartments will have 

the following design features: independent means to couple (mechanically fasten) the wall panels to the 

door to account for crash loads specified in 14 CFR 25.561 or gust loads, whichever is more critical, using 

static pull test as the means of compliance and account for deformation of local structure to secure them in 

the open position; cockpit annunciation of the positive engagement of the means for taxi, take-off and 

landing; the means must have positive retention in the locked position; and the doors will be frangible to 

allow egress in the event that they should become stuck in the closed position. 

The design provides a single point of coupling for each section of the door. The coupling mechanism can 

be released by pulling on the mechanism key and does not require a tool. The mechanism key is spring 

loaded with a plate that ensures the key remains in a locked position and prevents the pin from disengaging 

and the door closing. With the pin engaged in the door, the switch is activated to signal to the Flight Deck 

that the door is locked in an open position. To disengage the lock, the key must be pulled allow the pin to 

drop out the locked position. The locking mechanism allows for the doors to be pinned in an open position 

for takeoff and landing. The door sections also contain dual latching mechanisms to retain them in the 

open position for takeoff and landing, each of which will be capable of withstanding the inertia loads 

specified in 14 CFR 25.561. 

Occupant Safety Considerations 

The risk for occupants due to the use of doors between passenger compartments should be considered 

acceptable for the following reasons: 

2 
• Any curved pocketing door between passenger compartments will have an independent means to 

couple (mechanically fasten) the wall panels to the door to account for crash loads specified in 14 

CFR 25.561 or gust loads, whichever is more critical, using static pull test as the means of 

compliance and account for deformation of local structure to secure them in the open position, 

• The means to couple (mechanically fasten) the wall panels to the door will have positive 

retention in the locked position, 

• 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 and cockpit annunciation will be given of the positive engagement of the 

curved pocket door coupling means for taxi, 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 following requirements for curved pocket doors which cross the main cabin aisle 

and that open and close at an angle that is not transverse to the longitudinal axis of the aircraft: 

o In lieu of the requirements of Sec. 25.813(e), curved interior pocketing doors may be installed 

between passenger seats and exits, provided the following requirements are met: 

• Each curved pocketing door between any pasaenger seat and any exit will have an 

independent means to couple (mechanically fasten) the wall panels to the door to account 

for crash loads specified in 14 CFR 25.561 or gust loads, whichever is more critical, 

using static pull test as the means of compliance and account for deformation of local 

structure to secure them in the open position. The means to couple (mechanically fasten) 

the wall panels to the door will have positive retention in the locked position. 

• The direction of motion of any curved door installed across an aisle must be across the 

direction of motion of the occupant, e.g., pocket doors are one example of such a design. 

• Bach door between any passenger seat, occupiable for taxi, takeoff, and landing, and any 

emergency exit must have a means to signal to the flight crew, at the flight deck, that the 

door is in the open position for taxi, takeoff and landing. Also, cockpit annunciation will 

be given of the positive engagement of the curved pocket door coupling means for taxi, 

take-off 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 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 per Advisory Circular 25-17A, 

Transport Airplane Cabin Interiors Crashworthiness Handbook, paragraph 43b(2). 

• 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) 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 fanctions to be performed by the passengers and the relevant 

features of the airplane to ensure the safety of the passengers and crew. 
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 VVIP/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 VVIP/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 revenue 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 Research 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 747-8 interior programs by L-3 Communications and its 

subsidiaries. Use and applicability of the Exemption wi11 be controlled in the Project Specific Certification planning 

subrnitted to the applicable FAA Certification Office. 

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 first airplane is located in a foreign country. 

Public Comment 

In accordance with 14 CFR 11.87, L-3 requests that the period for public comrnent be waived. If posting to the 

Federal Register is required, L-3 suggests this summary. The petitioner requests an exernption from the 

requirements of Section 25.813(e) for Boeing Model 747-8 airplanes modified with executive interiors designated 

for private use that will not be operated for hire or offered for common carriage under parts 121 or 129. 

SUMMARY OF LIMITATIONS AND ADDITIONAL REQUIREMENTS 

4 
Limitations applicable to exemptions petitioned for herein. 

When this Exemption is used for the regulations covered by this Exemption the following lamitations 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", must 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. 

• Compliance 14 CFR 25.813(e) Doors Between Passenger Compartments will be as follows: 

o In lieu of the requirements of Sec. 25.813(e), curved interior pocketing doors rnay be installed 

between passenger seats and exits, provided the following requirements are met: 

• Each curved pocketing door between any passenger seat and any exit will have an 

independent means to couple (mechanically fasten) the wall panels to the door to account 

for crash loads specified in 14 CFR 25.561 or gust loads, whichever is more critical, 

using static pull test as the means of compliance and account for deformation of local 

stracture to secure them in the open position. The means to couple (mechanically fasten) 

the wall panels to the door will have positive retention in the locked position. 

• The direction of motion of any curved door installed across an aisle must be across the 

direction of motion of the occupant, e.g., pocket doors are one example of such a design. 

• 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. Also, cockpit annunciation will 

be given of the positive engagement of the curved pocket door coupling means for taxi, 

take-off and landing. 

• Appropriate procedurestlimitations 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 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) 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. 

Submitted on January 28, 2016 

For L-3 Communications Integrated Systems, L.P. 

t W 

Loyd R. Hamilton 

ODA-750154-SW Administrator