# Gulfstream

A GENERAL DYNAMICS COMPANY

U.S. Department ofTransportation Docket Operations West Building Ground Floor, 'Room W12-140 1200 New JerseyAvenue, SE. Washington , DC 20590 January 30, 2015 G-ODA-15-0103

Subject: Requestfor Exemption from Section 25.813(e) ofTitle 14, Emergency ExitAccess FAA Project No: TC-01-2010-0024 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 allowfor installation ofinteriordoors in certain locations. Ifyou have any questions or need additional information please contact Robert Glasscock at (912) 965- 6817 (via e-mail at robert.qlasscock@qulfstream.com) orthe undersigned. Respectfully,

# ~~ Robert Nilson Director- GulfstreamAerospace Corporation P.O. Box2206, MIS Savannah, GA31402-2206 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.comPetition for Permanent Exemption Gulfstream Aerospace Corporation Installation ofInterior Doors Model GVII-G500

Relieffrom section 14CFR Part 25.813(e) Arndt. 25-128 Gulfstream Aerospace Corporation (Gulfstream) ofSavannah, Georgia has submitted an application to the FAA's Atlanta Aircraft Certification Office fortype certification ofa new, twinengine, transport category aircrafts to be known as the Gulfstream model GVII-G500. Project numberTC-01-2010-0024 has been assigned to this effort. The GVII cabin interior relies on installation ofvarious 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 partthat no door may be installed between any passenger seatthat is occupiable fortake-offand landing and any passenger emergency exit, such thatthe doorcrosses any egress path (including aisles, crossaisles and passageways). The GVII-G500 design incorporates two doors between the passengerseating areas and the main entry door (Referto figure 1 ). • One doorwill 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 doorwill be aforward vestibule doorand 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 doorwill also provide isolation in accordance with AC 121-31 when aflight 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 ofthe GVII-G500, will provide an overall level ofsafety 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 otherthan 14 CFR part 121, are permitted to incorporate these types ofdoor 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 interiordoor forward or aft the passenger compartment, and 2) reach the exit beyond the door in the event of failure ofthe interior doorto open. Forthe GVII-G500 aircraft, Gulfstream believes that it is possible to provide a level ofsafety consistentwith the intent ofthe 14 CFR Part 25 regulations while allowing for installation of certain interiordoors. This will be accomplished by incorporating specific design features that provide an acceptable level ofsafety. These features will ensure the design will not diminish a passengers' ability to 1) effectively identifythe exit and 2) egress the aircraft. Factors supporting the Petition 

### The design features ofthe GVII-G500 Interiordoors are identical to the ones described in Exemption 10188forthe GVI and the following characteristics ofthe GVII-G500 interiordoors and passenger cabin will ensure thatthe passengers' ability to effectively identifythe exit is not diminished:

• The doorswill 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 ofthe interiordoors will therefore not adversely affectthe passenger recognition ofthe Main Entry Door (MED).

2• The doorswill only be installed forward ofthe passengerseating area and between passengerseats and the MED. The MED is the only dooravailable to enterthe 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 complywith the criteria defined in ELOS AT5177AT-T-C-1 (ELOS to 14 CFR 25.811(d) and 14 CFR 25.812(b)).

• The overwing 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 locatorsigns and markers, as well as emergency escape path lighting. This heightened passenger awareness and ease of identification will increasethe likelihood ofpassengers utilizing the over wing exits provided in the cabin versus defaulting to the entry door. The following design features ofthe 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 doorswill be open fortaxi, take-offand landing, without requiring passenger orcrew action.

• The doorswill be designed to automatically open (stow) when the airplane has been configured for landing (gear down orflaps down).

• The operation ofthe doorto be closed (deployed) position will require manual activation. The doorswill be designed so that they can only be closed (deployed) when the gearand flaps are fully retracted (airborne configuration), orforground maintenance activity.

• The doorswill be designed so that, in case ofanyfailure ofthe closing/latching mechanism, they will defaultto the open (stowed) position.

• In accordance with Gulfstream's approach to compliance with 14 CFR 25.1309, the failure to egressthrough any individual emergency exit is classified Major. Gulfstream will demonstratethatthe probability offailure to egress through the Main Entry Door (MED), including the probability offailure ofboth interiordoors, will meetthe criteria for afailure scenario classified as Major. This will include conducting a quantitative analysis that shows the probability ofthis scenario to be less than 1

# o-5 perflight hour. This hazard criticality is based on 14 CFR 25.783(b)(2).

• The doorswill have a hold-open feature thatwill be shown to react all emergency landing loads specified under 14 CFR 25.561(b).

3• The doors will be placarded to be open and latched fortaxi, 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 forTT&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 ifan interiordoor is not properly open (stowed) position forTT&L.

• With the doors in the open (stowed) position, the critical forward emergency landing loads will not cause doorto deploy and block accesstothe main entry door.

• The overwing emergency exits have been designed so thatthey can all deployed at the same time to provide multiple, redundant egress paths for escape from the passenger compartment. Each ofthe four overwing 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, largerexits. Smooth, effective egress ofpassengersthrough the existing overwing exits will also increase the likelihood ofpassengers utilizing the overwing 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 eitherside ofthe door. In case of an emergency, this design will allow a 51 h percentile female to create an aperture large enough to allowfor 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 ofan emergency evacuation, a trained crew memberwill be responsible to ensure egress is maintained through this passagewayto 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 numberANM-115-08-02, and has demonstrated thatthe GVII exit pairwill provide equivalent egress capability to that ofa required Type Ill. The GVII-G500 emergency exits configuration is identical to the GVI emergency exits covered underthe ELOS TC8700AT-T-C-1 and Gulfstream has demonstrated that the overwing exit pairwas equivalentto the size and number ofexits required by 14 CFR 25.807(g). The GVII-G500 will comply with 14 CFR 25.807(g) for required numberofemergency exits through the overwing exits 4and Gulfstream has demonstrated that the MEDwas an emergency exit in excess ofthe minimum required on the left hand side ofthe aircraft.

• Compliance with 14 CFR 25.807(i)(2) forditching will be shown through the use ofthe overwing emergency exits as required by 14 CFR 25.807(g). The forward entry doorwill not be utilized underthis scenario foremergency evacuation and applicable placards will be provided. TheAirplane Flight Manual will define proper proceduresforexiting the aircraft in these conditions.

• Many ofthe passengers typically utilizing Executive Class aircraft are frequent passengers who are familiarwith the operation ofthe interiorfeatures and locations ofemergency exits.

ForwardVestibule Door

Acoustic Door 

### Figure 1 - GVII-G500 Emergency Egress Route

Effect ofthe Exemption on Safety Acceptance ofthe proposed GVII-G500 design will ensurethat a level ofsafety consistentwith the intent ofthe regulation has been provided. The design ofthe proposed interiordoorswill ensure the same level ofsafetyforcabin egress as is required for any emergency exit and will provide a clear egress path. This combined with other characteristics ofthe GVII such as redundancy ofemergency exits, large area overwing exits and optimal location ofemergency exits, will provide a level ofsafety exceeding that currently presribed under 14 CFR part 25. Although the current operational requirements under 14 CFR parts 91 and 135forthis type of aircraft have not been amended to correspond to the 14 CFR part 25 restriction, Gulfstream acknowledgesthatthe 14 CFR part 25 change is an important enhancementto the level of

5safety offered by newly manufactured aircraft. The design criteria proposed by Gulfstreamfor the GVII raises the current level ofsafetyto that envisioned by Amendment 25-128. Issue of Public Interest Gulfstream Aerospace Corporation designs, develops, manufactures, markets and services the world's mosttechnologically advanced businessjet aircraftto an International market. Gulfstream's leadership position in the global businessjet market is dueto 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 ofsuppliers located throughout the United States. Gulfstream competes for new business all overthe world. This exemption will directly impactthe cabin and flight deck acoustics and the effectiveness offlight crew sleeping facility design, thereby having a direct effect on GVII-G500 sales. The ability to provide additional acoustic barrierfrom external noise forthe flight deck and cabin are being requested by prospective aircraft operators who compare the GVII-G500 with products offoreign aircraft manufacturers. The inability to provide such features will ultimately cause a reduction in perspective sales. The manufacture, completion, and support ofGulfstream aircraftwould aid in the stabilization ofthejob market as well as the growth oftheAmerican economy, which is in the interest ofthe public. Since customers desireto have these interiordoors, they may opt for aircraft designed to an earlier certification basis, in the lieu ofthe GVII-G500. This will restrict advancements in safety introduced by Gulfstream with the GVII-G500, not only in the areas ofthe 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 ofaircraft safety is in the interest of the public. Operation Outsidethe United States The European Aviation SafetyAgency (EASA) Certification Standard (CS) 25.813 regulation is not currently harmonized with 14 CFR 25.813 and does not restrict these types ofdoor installations. Regardless of EASA requirements, per 14 CFR 11.81(h) Gulfstream requests consideration be given to extending this exemption for operation outside ofthe United States and projections are the same forthe Model GVII. Granting this extension ofpriviledgeswill allowfor operations based within foreign countries, having bilateral agreements with the United States accepting FAA 14 CFR part 25 as their airworthiness standard fortransport category aircraft. Gulfstream believes that limiting this exemption to use within the U.S world put unfair restrictions on the marketability ofthis aircraft.

6Conclusion: Gulfstream believes that the above arguments favor an exemption from 14 CFR 25.813(e) that would allowfor installation ofcertain interior doors on the GVII aircraft. In addition, Gulfstream believes that an exemption is in the public interest and will provide a level ofpassengersafety consistentwith the current 14 CFR part 25 regulations.

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