Gulfstream 

A GENERAL DYNAMICS COMPANY 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, 'Room W12-140 

1200 New Jersey Avenue, SE. 

Washington , DC 20590 

January 30, 2015 

G-ODA-15-0103 

Subject: Request for Exemption from Section 25.813(e) of Title 14, Emergency Exit Access 

FAA Project No: TC-01-201 0-0024 

Attachment: Petition for Exemption- Installation of Interior Doors, Model GVII 

Dear Sirs: 

In accordance with 14 CFR Part 11, Gulfstream Aerospace Corporation requests consideration of the 

enclosed petition for exemption. This petition is being submitted to relieve the Gulfstream GVII model 

aircraft from full compliance with 14 CRF 25.813(e) at amendment 25-128, Emergency exit access, to 

allow for installation of interior doors in certain locations. 

If you have any questions or need additional information please contact Robert Glasscock at (912) 965-

6817 (via e-mail at robert.qlasscock@qulfstream.com) or the undersigned. 

Respectfully, 

~~ Robert Nilson 

Director- Gulfstream Aerospace Corporation 

P.O. Box 2206, MIS 

Savannah, GA 31402-2206 

robert.nilson@qulfstream.com 

(912) 965-6006 

Cc: N. Berryman, ACE-120A (via email) 

B. Whitton, Gulfstream ODA (via email) 

C. Underwood, ACE-120A (via email) 

M. Gordon, ANM-113 (via email) 

J. Nyberg, EASA (via email) 

P.O. Box 2206 • Savannah, GA 31402-2206 USA • Telephone (912) 965-3000 • gulfstream.com 
Petition for Permanent Exemption 

Gulfstream Aerospace Corporation 

Installation of Interior Doors 

Model GVII-G500 

Relief from section 14 CFR Part 25.813(e) Arndt. 25-128 

Gulfstream Aerospace Corporation (Gulfstream) of Savannah, Georgia has submitted an 

application to the FAA's Atlanta Aircraft Certification Office for type certification of a new, twinengine, transport category aircrafts to be known as the Gulfstream model GVII-G500. Project 

number TC-01-201 0-0024 has been assigned to this effort. 

The GVII cabin interior relies on installation of various doors to provide certain amenities and 

configuration options that have become the standard for Executive Class aircraft. 

14 CFR 25.813(e), Amendment 25-128- States in part that no door may be installed between 

any passenger seat that is occupiable for take-off and landing and any passenger emergency 

exit, such that the door crosses any egress path (including aisles, crossaisles and 

passageways). 

The GVII-G500 design incorporates two doors between the passenger seating areas and the 

main entry door (Refer to figure 1 ). 

• One door will be an acoustic door provided between the forward vestibule and 

the main entry door. Its purpose is to maintain an acceptable acoustic level in the 

passenger cabin and pilot compartment and will be standard equipment. 

• The second door will be a forward vestibule door and is offered on certain interior 

configurations. Its purpose is to provide separation between passenger and crew 

area including the galley, flight crew sleeping facility (when installed) and cockpit. 

The forward vestibule door will also provide isolation in accordance with 

AC 121-31 when a flight crew sleeping facility is installed. 

In accordance with the provisions of 14 CFR 11.81, Gulfstream requests an exemption to 

14 CFR 25.813(e) for installations of these cabin interior doors for the GVII-G500 and its 

derivatives. This will allow the GVII aircraft to provide safe, quiet operating environment for the 

crew and passengers, and meet the requirements for flight crew sleeping facility (when 

installed). Gulfstream proposes that specific design features, combined with the unique 

configuration of the GVII-G500, will provide an overall level of safety beyond that intended when 

FAA promulgated Amendment 25-128. 

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Based on these features, Gulfstream proposes that this exemption be applicable to both private 

use aircraft (14 CFR part 91) and those used for hire (14 CFR part 135). The information 

provided herein outline this rationale. 

Supportive information 

At Amendment 25-1, 14 CFR 25.803(e) was revised to restrict installation of doors between 

passenger compartments. This did not restrict the installation of doors forward and aft of 

passenger compartments. As such it continued to be common practice for business class 

aircraft to install doors which isolate the passenger seating areas from crew working areas. 

These doors lower noise levels in the passenger cabin and create effective work environments. 

On October 27, 2004, Amendments 25-116 and 121-306, titled "Miscellaneous Cabin Safety 

Changes", were published in the Federal Register. This revised 14 CFR 25.813(e) to restrict the 

installation of any interior door between a passenger seat and. any emergency exit, effectively 

restricting the use of all interior doors. In addition, the FAA revised 14 CFR 121.310(f)(6), to 

prohibit these doors in airplanes manufactured after November 27, 2006, and operated under 

14 CFR part 121. However, at that time the FAA chose not to amend 14 CFR part 135 or 

14 CFR part 91. As a result, aircraft certified prior to Amendment 25-116, and operating under 

other than 14 CFR part 121, are permitted to incorporate these types of door installations. 

When Amendment 25-116 was issued, the FAA noted that this change was incorporated due to 

concerns over passengers' ability to 1) recognize that an exit exists beyond an interior door 

forward or aft the passenger compartment, and 2) reach the exit beyond the door in the event of 

failure of the interior door to open. 

For the GVII-G500 aircraft, Gulfstream believes that it is possible to provide a level of safety 

consistent with the intent of the 14 CFR Part 25 regulations while allowing for installation of 

certain interior doors. This will be accomplished by incorporating specific design features that 

provide an acceptable level of safety. These features will ensure the design will not diminish a 

passengers' ability to 1) effectively identify the exit and 2) egress the aircraft. 

Factors supporting the Petition 

The design features of the GVII-G500 Interior doors are identical to the ones described in 

Exemption 10188 for the GVI and the following characteristics of the GVII-G500 interior doors 

and passenger cabin will ensure that the passengers' ability to effectively identify the exit is not 

diminished: 

• The doors will be designed to automatically open (stow) based on the airplane 

being configured for landing and will remain open until the airplane has returned 

to an airborne flight configuration. The installation of the interior doors will 

therefore not adversely affect the passenger recognition of the Main Entry Door 

(MED). 

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• The doors will only be installed forward of the passenger seating area and 

between passenger seats and the MED. The MED is the only door available to 

enter the aircraft and its location is inherently established for all passengers upon 

boarding. 

• Emergency exit locator, marking signs and emergency lighting will be provided. 

Gulfstream will comply with the criteria defined in ELOS AT5177AT-T-C-1 (ELOS 

to 14 CFR 25.811(d) and 14 CFR 25.812(b)). 

• The over wing emergency exits are optimally located in the passenger 

compartment, in clear and obvious view, and are in an area of high passenger 

density. These exits will also be indicated via locator signs and markers, as well 

as emergency escape path lighting. This heightened passenger awareness and 

ease of identification will increase the likelihood of passengers utilizing the over 

wing exits provided in the cabin versus defaulting to the entry door. 

The following design features of the GVII-G500 interior doors and passenger cabin will ensure 

that the passenger's ability to effectively egress the aircraft is not diminished by ensuring that 

the doors will be open for taxi, take-off and landing, without requiring passenger or crew action. 

• The doors will be designed to automatically open (stow) when the airplane has 

been configured for landing (gear down or flaps down). 

• The operation of the door to be closed (deployed) position will require manual 

activation. The doors will be designed so that they can only be closed (deployed) 

when the gear and flaps are fully retracted (airborne configuration), or for ground 

maintenance activity. 

• The doors will be designed so that, in case of any failure of the closing/latching 

mechanism, they will default to the open (stowed) position. 

• In accordance with Gulfstream's approach to compliance with 14 CFR 25.1309, 

the failure to egress through any individual emergency exit is classified Major. 

Gulfstream will demonstrate that the probability of failure to egress through the 

Main Entry Door (MED), including the probability of failure of both interior doors, 

will meet the criteria for a failure scenario classified as Major. This will include 

conducting a quantitative analysis that shows the probability of this scenario to 

be less than 1 o-5 per flight hour. This hazard criticality is based on 14 CFR 

25. 783(b)(2). 

• The doors will have a hold-open feature that will be shown to react all emergency 

landing loads specified under 14 CFR 25.561 (b). 

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• The doors will be placarded to be open and latched for taxi, take-off, and landing 

{TT&L). Manual operation to the open (stowed) position is the primary means by 

which the doors should be open and stowed for TT&L. The automatic opening 

feature will ensure egress paths in the event that manual operation has not 

occurred. 

• An amber CAS message will alert pilots if an interior door is not properly open 

(stowed) position for TT&L. 

• With the doors in the open (stowed) position, the critical forward emergency 

landing loads will not cause door to deploy and block access to the main entry 

door. 

• The over wing emergency exits have been designed so that they can all 

deployed at the same time to provide multiple, redundant egress paths for 

escape from the passenger compartment. Each of the four over wing emergency 

exits require single file egress and have been sized to provide substantial egress 

area. This reduces the problems caused by passenger panic and congestion 

typical in single, larger exits. Smooth, effective egress of passengers through the 

existing over wing exits will also increase the likelihood of passengers utilizing 

the over wing exits as opposed to seeking alternate escape routes further away 

(MED). Reference Figure 1, GVII-G500 Emergency Egress Routes. 

• Both doors will be designed to be frangible from either side of the door. In case of 

an emergency, this design will allow a 51

h percentile female to create an aperture 

large enough to allow for a 951

h percentile male to escape. 

Additional GVII Design Considerations: 

• The main entry door is also the flight crew emergency exit. In the event of an 

emergency evacuation, a trained crew member will be responsible to ensure 

egress is maintained through this passageway to the MED. 

• Through ELOS TC8700AT-T-C-1 to 14 CFR 25.807(a)(3), 14 CFR 

25.807(g)(2)(3) and 14 CFR 25.807(i)(2), Gulfstream has addressed FAA policy 

number ANM-115-08-02, and has demonstrated that the GVII exit pair will 

provide equivalent egress capability to that of a required Type Ill. 

The GVII-G500 emergency exits configuration is identical to the GVI emergency 

exits covered under the ELOS TC8700AT-T-C-1 and Gulfstream has 

demonstrated that the over wing exit pair was equivalent to the size and number 

of exits required by 14 CFR 25.807(g). The GVII-G500 will comply with 14 CFR 

25.807(g) for required number of emergency exits through the over wing exits 

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and Gulfstream has demonstrated that the MED was an emergency exit in 

excess of the minimum required on the left hand side of the aircraft. 

• Compliance with 14 CFR 25.807(i)(2) for ditching will be shown through the use 

of the over wing emergency exits as required by 14 CFR 25.807(g). The forward 

entry door will not be utilized under this scenario for emergency evacuation and 

applicable placards will be provided. The Airplane Flight Manual will define 

proper procedures for exiting the aircraft in these conditions. 

• Many of the passengers typically utilizing Executive Class aircraft are frequent 

passengers who are familiar with the operation of the interior features and 

locations of emergency exits. 

Forward Vestibule Door 

Acoustic Door 

Figure 1 - GVII-G500 Emergency Egress Route 

Effect of the Exemption on Safety 

Acceptance of the proposed GVII-G500 design will ensure that a level of safety consistent with 

the intent of the regulation has been provided. The design of the proposed interior doors will 

ensure the same level of safety for cabin egress as is required for any emergency exit and will 

provide a clear egress path. This combined with other characteristics of the GVII such as 

redundancy of emergency exits, large area over wing exits and optimal location of emergency 

exits, will provide a level of safety exceeding that currently presribed under 14 CFR part 25. 

Although the current operational requirements under 14 CFR parts 91 and 135 for this type of 

aircraft have not been amended to correspond to the 14 CFR part 25 restriction, Gulfstream 

acknowledges that the 14 CFR part 25 change is an important enhancement to the level of 

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safety offered by newly manufactured aircraft. The design criteria proposed by Gulfstream for 

the GVII raises the current level of safety to that envisioned by Amendment 25-128. 

Issue of Public Interest 

Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the 

world's most technologically advanced business jet aircraft to an International market. 

Gulfstream's leadership position in the global business jet market is due to the efforts of its 

nearly ten thousand employees in the manufacturing plants, completion centers, and services 

centers access North America. The corporation utilizes numerous products, such as avionics 

and environmental control systems, from scores of suppliers located throughout the United 

States. Gulfstream competes for new business all over the world. This exemption will directly 

impact the cabin and flight deck acoustics and the effectiveness of flight crew sleeping facility 

design, thereby having a direct effect on GVII-G500 sales. The ability to provide additional 

acoustic barrier from external noise for the flight deck and cabin are being requested by 

prospective aircraft operators who compare the GVII-G500 with products of foreign aircraft 

manufacturers. The inability to provide such features will ultimately cause a reduction in 

perspective sales. The manufacture, completion, and support of Gulfstream aircraft would aid in 

the stabilization of the job market as well as the growth of the American economy, which is in 

the interest of the public. 

Since customers desire to have these interior doors, they may opt for aircraft designed to an 

earlier certification basis, in the lieu of the GVII-G500. This will restrict advancements in safety 

introduced by Gulfstream with the GVII-G500, not only in the areas of the cabin safety, but 

throughout the airplane. This is counterproductive to both Gulfstream and the FAA's goal of 

continuous improvement in overall safety. The advancement of aircraft safety is in the interest of 

the public. 

Operation Outside the United States 

The European Aviation Safety Agency (EASA) Certification Standard (CS) 25.813 regulation is 

not currently harmonized with 14 CFR 25.813 and does not restrict these types of door 

installations. 

Regardless of EASA requirements, per 14 CFR 11.81 (h) Gulfstream requests consideration be 

given to extending this exemption for operation outside of the United States and projections are 

the same for the Model GVII. Granting this extension of priviledges will allow for operations 

based within foreign countries, having bilateral agreements with the United States accepting 

FAA 14 CFR part 25 as their airworthiness standard for transport category aircraft. Gulfstream 

believes that limiting this exemption to use within the U.S world put unfair restrictions on the 

marketability of this aircraft. 

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Conclusion: 

Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.813(e) that 

would allow for installation of certain interior doors on the GVII aircraft. In addition, Gulfstream 

believes that an exemption is in the public interest and will provide a level of passenger safety 

consistent with the current 14 CFR part 25 regulations. 

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