UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

Exemption No. 17064 

L-3 Communications Integrated 

Systems, L.P. Regulatory Docket No. FAA-2016-0328 

for an exemption from § 25.8 13(e) ofTitle 

14, Code ofFederal Regulations 

GRANT OF EXEMPTION 

By letter dated January 28, 2016, Mr. Loyd R. Hamilton, ODA-750154-SW Administrator, L-3 

Communications Integrated Systems, L.P., 7601 Maehr Road, P.O. Box 154580, Waco, Texas, 

76715-4580, petitioned the Federal Aviation Administration (FAA) for an exemption from 

section 25.813(e) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption. if 

granted, would permit relief from§ 25.813(e) to penn it the installation of interior doors between 

passenger compartments. Specifically, the petition requests removing the requirement in 

exemption no. 10686 that doors installed across the main aisle must open and close in a 

transverse direction. The proposed exemption is specifically for the installation of executive 

interiors on Boeing Model 747-8 airplanes designated as "private use, not for hire, not for 

common carriage.,. 

The petitioner requests relief from the following regulation: 

Section 25.813(e) at Amendment 25-46 - Requires that no door may be installed in any 

partition between passenger compartments. 

The petitioner supports their request with the following information. 

This section quotes, in pertinent part, the relevant information from the petitioner's request, with 

minor edits for clarity. The complete petition is avail able at the Department ofTransportation's 

Federal Docket Management System, on the Internet at http://regulations.r!ov, in Docket No. 

FAA-2016-0328. 

Discussion 

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

completions of VVIP/Govemment/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-750 154-SW to conduct the program under Project 

Number P-1 2-001. 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 appli ed 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 common 

carriage), it is appropriate to take into consideration the specific needs of a diffe rent 

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 

VVJP/Government/Head-of-State, not-for-hire, not-fo r-common-carriage service. 

Basis for Exemption 

The aircraft that are the subjects of this petition are Boeing Model 747-8s modified for 

non-commercial/non-conunon carriage VVIP/Government use!Head-of-State service. 

They are typically in the service of foreign Heads-of-State friend ly 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 fl y 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 is justified based upon the fo llowing facts: 

• This aircraft is intended for VVIP/Govemment/Head-of-Statc 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 Type Approved 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. 

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14 CFR 25.813(e): Doors Between Passenger 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 nonpassenger compartments and, therefore, these doors do not apply to this exemption 

request. Curved pocketing doors 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 

• the door-coupling means must have positive retention in the locked position 

• the doors will be frangible to allow egress in the event that they should become 

stuck in the closed position 

• cockpit annunciation of the doors' positive engagement of the door-coupling 

means for taxi, take-off and landing 

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 docs 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 to allow the pin 

to drop out of 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: 

• Any curved pocketing door between passenger compat1mcnts 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 

defonnation of local structure to secure them in the open position, 

• The means to couple (mechani call y 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 

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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 9 1114 CFR 125 or foreign equivalent 

and will not be operated for hire or offered for common carriage, 

• The airplane f1ight manual (AFM) will provide procedures and limitations to 

ensure that the doors are in the proper position for takeoff and landing. 

Requested Relief 

L-3 Communications requests relief from§ 25.813(e), and the requirements and 

limitations specified in exemption no. I 0686, to permit the installation of curved interior 

doors between passenger compartments. 

Public Interest 

As in the cases of numerous already established Exemptions, granting this exemption 

would be clearly in the public interest of the people of the United States of America for 

the following reasons: 

l. 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 ofTransport 

Category Airplanes to effectively compete in this expanding market. 

2. Additional sales ofUnited 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 linancial performance of United States owned and operated 

corporations, and increased workforce stability translates into continued and 

improved local, state, and federal tax revenue whi ch 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. 

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8. Foreign Heads-of-State operati ng 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 fl ying public. 

l 0. The exemption request, if granted, allows the F /\A to expend resources on this 

subject only this one time, not for each interior arrangemeut, cu1d tl u::n::aller lu 

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 will be 

controlled in the Proj ect Specific Certification planning submitted to the applicable FAA 

Certification Office. 

In accordance with 14 CFR 11 .81 (h), we request to exercise the privilege ofthis 

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 comment be 

waived. 

Federal Register publication 

A summary of the petition was published in the Federal Register on May I 1, 20 16 (8 1 FR 

293 19). No comments were received. 

T he FAA's analysis 

The FAA has issued numerous exemptions for installation of interior doors on airplanes that are 

operated for private use only. We have been consistent with the requirement that the doors 

installed across the main cabin aisle must open and close in a transverse direction. This is 

consistent also with Special Federal Aviation Regulation (SF AR) 109 paragraph 1 O(d), which 

requires, "Doors installed across a longitudinal aisle must translate laterally to open and close, 

e.g., pocket doors." That is, the direction of motion of the door must be at a right angle to the 

longitudinal axis of the airplane. This was included in the FAA analysis in exemption no. 10686. 

In a forward-c rash event, the major loading force is in the forward direction along the 

longitudinal axis of the airplane. When the direction of motion of the door is at a right angle to 

the longitudinal axis of the airplane, this forward-crash loading condition does not tend to close 

the door. For the configurations the petitioner proposes, a forward-crash loading condition would 

tend to close the entire door or one half of the door opening for the doors across the main-cabin 

aisle. The FAA considers this an important consideration due to the possibility that, during a 

crash event, the doors could become unlatched as the result of fuselage deformations or 

structural fai lures. 

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The petitioner has proposed and incorporated additional compensating features for the door 

design that are in addition to those required by previous exemptions and the operating 

regulations for the airplane. The compensating features added to the petitioner's proposed design 

restores the level of safety provided by the existing exemption conditions and limitations. 

Curved pocket doors must have an independent means to couple (mechanically fasten) the door 

to the wall panel, and that coupling means must account for crash loads specified in § 25.561 , or 

gust loads, and the doors must have positive retention in the locked position. 

The FAA finds this petition to be in the public interest as it provides the level of safety the FAA 

requires for these "private use only" airplanes with curved interior doors installed across the 

main cabin. 

The FAA's decision 

In consideration of the foregoing, I find that a grant of exemption is in the pub! ic interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701, delegated to me by 

the Administrator, 1 grant the petition of L-3 Communications Integrated Systems, L.P., for an 

exemption from § 25.813(e) to the extent necessary to a llow installation of curved interior doors 

on private, not-for-hire, not-for-common-carriage Boeing 747-8 airplanes. 

This exemption is subject to the following conditions and limitations: 

I. The airplane may not be offered for common carriage or operated for hire. The Operating 

Limitations section of the airplane flight manual (AFM) must be revised to prohibit any 

operations involvi ng the carriage of persons or property for compensation or hire. The 

operators may receive remuneration to the extent consistent with 14 CFR 91 subpart F 

and 14 CFR 125. 

2. A placard stating "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. 

3. Compliance with § 25.813(e), Doors Between Passenger Compartments, will be as 

follows: 

a. In lieu of the requirements of§ 25.8 l 3(e), curved interior pocket doors may be 

installed between passenger seats and emergency exits, provided the following 

requirements are met: 

1. Each curved pocket door between any passenger seat and an y exit will 

have an independent means to couple (mechanically fasten) the wall 

panels to the door to account for crash loads specified in§ 25.561 or gust 

loads, whichever is more critical, using static pull test as the means of 

compliance, and to account for deformation of local structure to secure 

them in the open position. The means to couple the wall panels to the door 

will have positive retention in the locked position. 

n. The direction of motion of any curved door installed across an aisle must 

be across the direction of motion of the occupant. 

111. Each door between any emergency exit, and any passenger seat that is 

occupiable for taxi, takeoff, and landing (TT &L), must have a means to 

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signal to the flightcrew, at the flightdeck, that the door is in the open 

position for TT &L. Also, cockpit annunciation will be given of the 

positive engagement of the curved pocket-door coupling means for TT&L. 

1v. Appropriate procedures and limitations must be established in the AFM to 

ensure that any such door is in the open configuration for TT &L. 

v. 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 intercompartment door installation in tht: airplane using a 5'h-percentile female 

subject. 

VI. 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. 

vn. The door sections must 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§ 25.561. 

b. When the airplane is equipped with interior doors under this exemption: 

1. The AFM must include an appropriate limitation that the airplane must be 

staffed with at least the number of fli ght attendants required by 

§ 91.533(a) who meet the requirements of§ 91.533(b). 

11. The AFM must include appropriate limitations 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. 

Issued in Renton, Washington, on AUG 1 1 2016 

Paul Bemado 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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