UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

Exemption No. 11035 

Gulfstream Aerospace Corporation Regulatory Docket No. FAA-2014-0223 

for an exemption from§§ 25.562 & 25.785(b) 

ofTitle 14, Code of Federal Regulations 

GRANT OF EXEMPTION 

By letter dated April 2, 2014, Mr. Norman J. Kopesky IT, ODA Site Program Administrator, 

Gulfstream Aerospace Corporation, W6365 Discovery Drive, Appleton, WI 54914, petitioned 

for an exemption fi"om the requirements of§§ 25.562 and 25. 785(b) of Title 14, Code of Federal 

Regulations (14 CFR). The proposed exemption, if granted, would permit a medical-stretcher 

installation on Gulfstream Models GV, GV-SP, GlV-X, and GVI series airplanes. 

The petitioner requests relief from the following regulations: 

Section 25.562 at Amendment 25-64- as included by reference in Type Certificate Data 

Sheets (TCDS) A12EA for Model GV, GV-SP, and GIV-X airplanes, and TCDS 

TOOO 15A T for Model G Vl airplanes, requires compliance with the structural and 

occupant-protection requirements of§ 25.562 as adopted by Amendment 25-64. 

Section 25.785(b), at Amendment 25-88 - requires that each seat, berth, safety belt, 

harness, and adjacent part of the airplane at each station designated as occupiable during 

takeofl 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 §§ 25.561 and 25.562. 

The petitioner supports their request with the following information: 

This section quotes, in pertinent part, the petitioner's information. The complete petition is 

available at the Department of Transportation's Federal Docket Management System, on the 

Internet at http://regulations.gov, in docket no. FAA-2014-0223. 

Gulfstream Aerospace Corporation hereby petitions for an exemption from § 25 .562 and 

part of§ 25.785(b) ofthe Federal Aviation Regulations (FAR) to the extent necessary to 

permit certification of medical stretchers for transport of persons whose medical 
condition dictates such accommodations. The exemption would be for installing the 

medical beds/stretchers in the Gulfstream model GV, GV-SP, GIV-X, and GVI airplanes. 

Gulfstream Aerospace Corporation currently holds the Type Certificates for the 

Gulfstream model GV, GV-SP, GIV-X, and GVI airplanes. These airplanes are certified 

under Type Certificate A 12EA, revision 42 and TOOO 15A T, revision 4. The certification 

basis for these airplane models is: 

Gulfstream model GV: 14 CFR Part 25, Amendments 25-1 through 25-81 with the 

associated special conditions, equivalent levels of safety findings, and exemptions 

established in Type Certificate Data Sheet A12EA. 

Gulfstream model GV -SP: 14 CFR Part 25, Amendments 25-1 through 25-98 with the 

associated special conditions, equivalent levels of safety findings, and exemptions 

established in Type Certificate Data Sheet Al2EA. 

Gulfstream model GIV-X: 14 CFR Part 25, Amendments 25-1 through 25-101 with the 

associated special conditions, equivalent levels of safety findings, and exemptions 

established in Type Ce1tificate Data Sheet A 12EA. 

Gulfstream model GVI: 14 CFR Part 25, Amendments 25-1 through 25-120, 25-122, 

25-124, and 25-132 with the associated special conditions, equivalent levels of safety 

findings, and exemptions established in Type Certificate Data Sheet TOOO 15A T. 

Additionally, Gulfstream Aerospace Corporation develops and owns numerous 

supplemental type certificates (STCs) for its airplane models and wishes to expand the 

airplanes' capability and use by installing medical beds/stretchers. Currently, no medical 

bed/stretcher installations have been shown to meet the dynamic criteria as identified for 

Part 25 transport airplanes. 

The estimated cost of demonstrating compliance of stretcher installations with dynamic 

test requirements is quite high considering the limited number of units for which the cost 

could be amortized. Since none have been shown to comply with the dynamic test 

criteria, stretchers cannot currently be used on airplanes whose type certificate bases 

include the dynamic requirements without a FAA grant of exemption. 

In this case, a person who needs to travel for essential medical care can either charter an 

airplane with an existing medical bed exemption applied and fitted with stretchers, or fail 

to receive the needed treatment (the consequences of which may be fatal). Another 

alternative would be flying an alternative route on an aircraft whose certification basis 

does not require dynamic testing. This would offer no increase in safety and may not be 

available. 

Why granting this request would be in the public interest; how it benefits the public 

as a whole 

Gulfstream feels that granting the petition would be in the public interest for the 

following reasons: 

• The exemption would relieve an economic burden for a segment of those 

traveling already dealing with adversity; 

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• The level of safety that would be provided is an acceptable level of safety given 

the limited usage and exposure of the stretcher; 

• Compliance with the dynamic test requirements would be difficult at best, and 

very expensive, while returning a marginal safety benefit. In addition, 14 CFR 

25.562 is written specifically for seats and would not be easily applied to medical 

beds/stretchers. 

Due to humanitarian considerations, Gulfstream Aerospace Corporation considers the 

transportation of persons needing medical attention by air to be essential and in the pub! ic 

interest. In many instances, those persons can be transported only on medical 

beds/stretchers. 

Waiver of notice and public procedure 

Gulfstream respectfully requests that action on this petition should not be delayed by 

publication of a summary of our petition and associated comment period. We believe that 

the nature of this exemption does not set a precedent but is consistent with other similar 

exemptions identified below which were granted for medical beds/stretchers installed in 

various Gulfstream and Boeing model airplanes. 

Operation outside the United States 

This exemption is intended for operation inside and outside the U.S. as many people 

travel outside the U.S. because we are a global society seeking business with the world. 

The Gulfstream aircraft is a global type aircraft. 

Conclusion 

Gulfstream believes the aforementioned arguments suppot1 the request for exemption and 

believes that the proposed exemption is in the public interest, and provides a level of 

occupant safety consistent with the current Federal Aviation Regulations. 

Federal Register publication 

The FAA has determined that good cause exists for waiving the requirement for Federal Register 

publication for public comment because the request is identical in all material respects to 

previously granted exemptions; the exemption, if granted, would not set a precedent; and any 

delay in acting on this petition would be detrimental to Gulfstream Aerospace Corporation. 

The FAA's analysis 

For the reasons stated by the petitioner, the FAA agrees that granting this petition is in the public 

interest. We have considered the cost implications and the overall benefits resulting from the use 

of a medical stretcher. The FAA agrees that demonstrating compliance with the requirements of 

§ 25.562 would be difficult, if not impossible, and applying the existing pass/fail criteria to these 

installations is questionable. The need for medically fragile people to receive necessary and 

potentially life-saving medical attention outweighs the increase in the level of safety gained by 

requiring medical stretchers to meet dynamic testing requirements. Also, this exemption would 

permit the transportation of medically fragile people, from countries lacking the medical 

expertise or equipment to address a certain medical condition, to a country with more advanced 

medical expertise and facilities. 

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The FAA agrees that stretchers for medical use were not considered in the context of the 

dynamic-test requirements of§ 25.562 when that regulation was developed. Occupancy of other 

berths during takeoff and landing for ambulatory persons was not considered feasible under the 

conditions of§ 25.562; and for the purposes of compliance, stretchers are considered "berths.'" 

With respect to the overall level of safety, the FAA notes that full compliance with the 

requirements of§ 25.561 will be required for the medical stretcher. This is consistent with the 

standards for all seats prior to the adoption of§ 25.562. Thus, as noted by the petitioner, an 

alternative to this exemption would be to seek transportation on an airplane that does not require 

dynamic testing as part of its certification basis (i.e., an airplane with an earlier certification 

basis). While this alternative is a viable option, the FAA does not consider this a desirable 

approach. Airplanes certificated with § 25.562 included in their certification basis have 

incorporated many safety advances not found on earlier-model airplanes. It would be 

counterproductive to restrict this type of transportation to those earlier models. 

The FAA's decision 

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

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

the Administrator, Gulfstream Aerospace Corporation is granted an exemption from the 

requirements of 14 CFR 25.562 and 25.785(b) to the extent necessary to allow installation of a 

medical stretcher on Gulfstream Models GV, GV-SP, GIV-X, and GVI airplanes. The operatinglimitations section of the airplane flight-manual supplement must state that occupancy of the 

stretcher berth is limited to non-ambulatory persons. 

In addition, the following must be stated on a conspicuously located placard installed adjacent to 

the stretcher berth: 

Occupancy is limited to non-ambulatory persons. 

Issued in Renton, Washington, on JUL 3 1 2014 gff7 £.CL-~ Jeffrey E. Duven 

Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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