Petition for Exemption from 14 CFR 25.562 and 25.185(b) 

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 

In accordance with 14 CFR 11.63, L-3 Communications Integrated Systems, L.P., petitions the Federal Aviation 

Administration (FAA) for exemption from Title 14, Code of Federal Regulations (14 CFR) 25.562 and 25.785(b). 

The proposed exernption, if granted, would grant relief from 14 CFR 25.562 and 25.785(b) as currently written and 

would establish appropriate requirements to comply with its intent. The proposed exemption is specifically intended 

for application to an executive interior program on a Boeing Mode1787-8 airplane designated as 

"VVIP/Government/Head-of-State." The proposed exemption would allow certification of a medical-stretcher 

carrier for transport of persons whose medical condition dictates such accommodation. 

The petitioner repuests relief from the followin~ regulations: 

Section 25.562, Amendment 25-64 

Emergency landing dynamic conditions. 

(a) The seat and restrain system in the airplane must be designed as prescribed in this section to protect each 

occupant during an emergency landing condition when-- 

(1) Proper use is made of seats, safety belts, and shoulder harnesses provided for in the design; and 

(2) The occupant is exposed to loads resulting from the conditions prescribed in this section. 

(b) Each seat type design approved for crew or passenger occupancy during takeoff and landing must successfully 

complete dynamic tests or be demonstrated by rational analysis based on dynamic tests of a similar type seat, in 

accordance with each of the following emergency landing conditions. The tests must be conducted with an occupant 

simulated by a 170-pound anthropornorphic test dummy, as defined by 49 CFR Part 572, Subpart B, or its 

equivalent, sitting in the normal upright position. 

(1) A change in downward vertical velocity of not less than 35 feet per second, with the airplane's 

longitudinal axis canted downward 30 degrees with reapect to the horizontal plane and with the wings level. Peak 

floor deceleration must occur in not more than 0.08 seconds after impact and must reach a minimum of 14g. 

(2) A change in forward longitudinal velocity of not less than 44 feet per second, with the airplane's 

longitudinal axis horizontal and yawed 10 degrees either right or left, whichever would cause the greatest likelihood 

of the upper torso restraint system (where installed) moving off the occupant's shoulder, and with the wings level. 

Peak floor deceleration must occur in not more than 0.09 seconds after impact and must reach a minimum of 16g. 

Where floor rails or floor fittings are used to attach the seating devices to the test fixture, the rails or fittings must be 

misaligned with respect to the adjacent set of rails or fittings by at least 10 degrees vertically (i.e., out of parallel) 

with one rolled 10 degrees. 

(c) The following performance measures must not be exceeded during the dynamic tests conducted in accordance 

with paragraph (b) of this section: 

(1) Where upper torso straps are used for crewmembers, tension loads in individual straps must not exceed 

1,750 pounds. If dual straps are used for restraining the upper torso, the total strap tension loads must not 

exceed 2,000 pounds. 

(2) The maximum compressive load measured between the pelvis and the lumbar column of the 
Petition for Exemption from 14 CFR 25.562 and 25.785(b) 

anthropomorphic dummy must not exceed 1,500 pounds. 

(3) The upper torso restraint straps (where installed) must remain on the occupant's shoulder during the 

impact. 

(4) The lap safety belt must remain on the occupant's pelvis during the impact. 

(5) Each occupant must be protected from serious head injury under the conditions prescribed in paragraph 

(b) of this section. Where head contact with seats or other structure can occur, protection must be provided so 

that the head impact does not exceed a Head Injury Criterion (HIC) of 1,000 units. The level of HIC is 

defined by the equation: 

HIC ta — ta) 

1 ta 

 a(t)dt 

~ s 

Where: 

tl is the initial integration time, 

t2 is the final integration time, and 

a(t) is the total acceleration vs. time curve for the head strike, and where 

(t) is in seconds, and (a) is in units of gravity (g). 

(6) Where leg injuries may result from contact with seats or other stracture, protection must be provided to 

prevent axially compressive loads exceeding 2,250 pounds in each femur. 

(7) The seat must remain attached at all points of attachment, although the structure may have yielded. 

(8) Seats must not yield under the tests specified in paragraphs (b)(1) and (b)(2) of this section to the extent 

they would impede rapid evacuation of the airplane occupants. 

Section 25.785(b), Amendment 25-88 

"(b) Each seat, berth, safety belt, harness, and adjacent part of the airplane at each station designated as occupiable 

during takeoff and landing must be designed so that a person making proper use of these facilities will not suffer 

serious injury in an emergency landing as a result of the inertia forces specified in Secs. 25.561 and 25.562." 

Stretcher carriers are considered "berths" as far as compliance with this section is concerned. 

BaCk2roUnd 

L-3 Communications Integrated Systems has been contracted by a customer for interior completion of a 

VVIP/Government/Head-of-State business interior in a Boeing Mode1787-8 airplane. The certification basis for the 

Boeing 787-8 is 14 CFR 25, Amendment 25-1 through 25-119 with reversions, later amendments, exemptions, and 

special conditions as shown in FAA Type Certificate Data Sheet T00021 SE. The airplane is to be completed under 

ODA-750154-SW project P-14-006. L-3 proposes to install the stretcher on Boeing 787-8 serial number 44572. 

This relief is requested to permit the certification of a medical stretcher on Boeing Mode1787-8 series airplanes. 

References: 

FAA Exemption No. 10887 (Boeing 747-8) 

FAA Exemption No. 10457 (Boeing 737) 

FAA Exemption No. 10197 (Dornier 328) 

FAA Exemption No. 8832 (Boeing 737) 

FAA Exernption No. 8602 (Boeing 777) 

FAA Exemption No. 8601 (Airbus 340) 

FAA Exemption No. 8600 (Airbus 318, 319, 320, 321) 

FAA Exemption No. 8599 (Airbus 330) 
Petition for Exemption from 14 CFR 25.562 and 25.785(b) 

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. 

Medical stretcher installations were not considered in the context of FAR 25.562 when the regulation was 

developed. As a result, criteria were established that are not directly applicable to this type of installation. L-3 

Communications is not aware of a supplier that could produce a stretcher that meets the requirements. A review of 

this issue with vendors indicates that the costs associated with the dynamic testing are quite high. Further, no 

articles that have been tested have met the criteria. With this information, it was determined that the cost of 

developing a stretcher system that will meet the criteria is prohibitively high. 

The result of the high cost is that a person seeking travel for required medical care has only three alternatives. One 

is to charter an aircraft at a very significantly increased cost. Another is to simply forgo the treatment with possible 

fatal consequences. The last option is to seek travel on an aircraft with a pre Amendment 25-64 certification basis. 

This stretcher installation will be used on an airplane to be used in private service (e.g., not for US hire or common 

carriage) as a VVIP/Government Use/Foreign Head of State airplane. 

Historically, the FAA has made adjustments to specific requirements based upon specific design and operational 

factors. Numerous Exemptions and other regulatory changes have been granted to meet specific aircraft designs and 

applications. Examples include exemptions 6820/6820A and 9762. As with other exemptions, L-3 proposes to use 

mitigating design requirements and operational limitations to justify this exemption to our existing and future 787-8 

aircraft modified for VVIP/Government/Head-of-State, not-for-hire or common-carriage service. 

Justification 

The estimated cost of demonstrating compliance of stretcher installations with dynarnic test requirement is quite 

high. Since none have been shown to comply with the dynamic test criteria, stretchers cannot currently be used on 

airplanes whose type certification basis includes the dynamic requirements. The pass/fail criteria were designed to 

increase the level of safety for passengers seated in an upright position. L-3 feels that application of the existing 

pass/fail criteria for dynamic testing to stretcher installations is unreasonable and that the increase in the level of 

safety does not warrant the costs when compared with the level of safety afforded by an aircraft that does not 

include Amendment 25-64 in its certification basis. 

Basis for Exemption 

The airplane that is the subject of this petition is a Boeing Mode1787-8 outfitted for non-commercial/non-commoncarriage VVIP/Government use/Head-of-State service. These aircraft 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 exemption proposed herein is 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. 

• The Petitioner proposes previously utilized and approved mitigating requirements and conditions that 

establish acceptable safety levels for the occupants consistent with previous grants. 
Petition for Exemption from 14 CFR 25.562 and 25.785(b) 

Occupant Safety Considerations 

• Stretcher installations for part 23, 25, 27 and 29 aircraft have not been shown to meet the dynamic criteria. 

However, they have demonstrated a good service history with no adverse experience. 

• The use of the medical stretcher is limited, and on a case-by-case basis. 

• Occupancy for takeoff and landing is limited to non-ambulatory persons. 

• The medical stretcher will comply with the requirements of 14 CFR 25.561. This includes the weight of 

the occupant. An occupant weight of 170 pounds is being used. 

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. The level of safety that would be provided is an acceptable level of safety given the limited usage and 

exposure of the stretcher. 

2. A person whose situation requires this type of travel arrangement can be transported on his own Headof-State airplane instead of having to charter another airplane. 

3. Compliance with 14 CFR 25.562 is difficult since that section applies to seats and not stretchers. The 

requirements for stretcher testing do not exist. Testing is expensive to conduct and would yield 

marginal safety benefit. 

4. This aircraft is used by a Government friendly to the US government to transport their Head-of-State, 

Diplomatic Persons, other VIPs, and related staff. US Public interest is advanced by developing and 

maintaining positive influence with the country represented and governed by the aircraft's occupants. 

Ensuring this airplane perform its mission as originally intended and contracted by the operator 

achieves that goal. 

5. The VVIP/Head-of-State configured interior of the style and quality intended for this STC is not 

suitable for charter operations or Common-Carriage operations. The aircraft will be restricted from 

use in for-hire or comrnon carriage operations. 

6. The population of people who use this aircraft is very small and restricted to personnel selected by the 

operator. Members of the flying public in the US and worldwide do not have access to this aircraft and 

therefore their Public Interest is not negatively impacted. 

7. The use of US design and manufacture aircraft and interiors such as this one develops and maintains 

the worldwide positive image and influence currently enjoyed by the US Aerospace Industry. Without 

supporting cost-benefit data demonstrating a positive safety impact there can be no public benefit to 

applying this requirement, especially to a foreign aircraft. 

Nlitiaatlon 

• Occupancy of the stretcher during TT&L will be limited to non-ambulatory persons. 

• An operating limitation will be added to the limitations section of the airplane flight manual supplement 

and stated on a conspicuously located placard: "Occupancy is limited to non-ambulatory persons." 

Application of the Exemption 

This Exemption is intended for application to existing and future Boeing 787-8 interior programs by L-3 

Communications Integrated Systems L.P. 

In accordance with 14 CFR 11.81(h), we request the privilege of this exemption outside of the United States since 

the operators are located in foreign countries. 

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Petition for Exemption from 14 CFR 25.562 and 25.785(b) 

FedeNal Register Publication 

L-3 Communications requests that the requirement for Federal Register publication be waived. The exemption, if 

granted, would not set a precedent. This type of exemption has been granted before for other Large Transport 

Category Airplanes. The issue is non-controversial. Installations of this type are not new. 

Summary for Publication if Needed 

The petitioner seeks exemption from 14 CFR 25.562 and 25.785(b) to permit use of a medical stretcher in an 

executive interior designated as "VVIP/Government/Head-of-State" for a Boeing 787-8 airplane. 

Submitted on August 5, 2015 

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

Phillip T. Cr`awford, P.E. 

ODA-750154-SW Admini 

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