BOMBARDIER 

LEARJET 

November 21,2012 

In Reply refer to: L706-11-12-2003 

U.S. Department of Transportation 

Transport Airplane Directorate 

Attn: Alan Sinclair 

1601 Lind Avenue, S.W. 

Renton, Washington 98057-3356 

Lear,,! Inc 

PO. Box 7707 

Wich ita. KS 67277·7707 

UIlI!ed S!ales 

\""Nloombardier corn 

ill 316·946·2000 

fAX 316·946·2809 

SUBJECT: Submittal of Petition for Exemption - 14 CFR Part 25, Section 25.809(a) 

Amendment 25-116 for the Type III Overwing Exit Viewing Means on a Learjet 

Model LJ 200 

REF: FAA Project Number TC4960WI-T 

Dear Sir or Madam: 

In accordance with 14 CFR Part 11, Learjet Inc. submits this petition for exemption from 14 CFR 

Part 25, Section 25.809(a) Amendment 25-116, for the requirement of viewing the likely areas of 

evacuee ground contact at the Type III over-wing emergency exit when the exit is closed. 

Learjet proposes to provide a means that will allow evacuees to view the escape route on the 

surlace of the wing along with the outside environment during all lighting conditions. 

An application for a new type Certificate (TC) has been submitted by Learjet Inc. for this new 

model and FAA Project no. TC4960WI-T has been assigned to this effort. The certification basis 

for the Leariet Model LJ-200-1 A 10 is 14 CFR Part 25, Amendment 25-1 through 25-127. 

The request is supported by the following information: 

In November 2004, the FAA amended 14 CFR Part 25, Section 25.809(a) to require a means to 

permit viewing of the conditions outside the exits when the exits are closed . The FAA indicated 

that emergency evacuations are frequently necessary either due to, or in combination with, a 

hazard such as a fire outside the airplane. Because the hazard may pose an immediate threat 

to the occupants of the airplane, it is often necessary to avoid opening certain otherwise 

useable emergency exits in order to prevent injury to the evacuees. In this context, a viewing 

window or other means of assessing the outside conditions and determining whether an exit 

should be opened is extremely valuable . A viewing window is commonly provided in most exits 

in service; however, it has not been required, and some exits in service do not incorporate one. 

However when this rule was amended, it appears that the FAA slid not take into consideration 

aircraft equipped with overwing exit arrangements. 
L706-11-12-2003 

The Learjet 200 aircraft will be certified with two (2) emergency exits; one Type I and one Type 

III. The Type I emergency exit will be located on the LH side of the aircraft approximately 4 feet 

behind the pilot. The Type III emergency exit will be located in the aft lavatory on the AH side of 

the aircraft directly over the wing . Both emergency exits wi ll be equipped with a means that will 

permit viewing of the outside conditions when the exit is closed. However, the viewing means at 

the Type III emerg ency exit, consisting of an aircraft window, will only permit viewing of the likely 

areas of evacuee contact with the wing suriace; primarily the slip resistant escape route. Once 

an occupant steps out on to the wing, they will then be able to view the ground where they 

would likely make contact. Exterior lighting will provide sufficient illumination to view the wing 

surface and the ground area under all ambient lighting conditions and with the landing gear 

extended as well as in all conditions of landing gear collapse. Since the aircraft will be certified 

for ditching and the ditching analysis indicates that the wings will be submerged under water by 

approximately 18 inches, the design of the exterior lighting will be such that evacuees will be 

able to view the escape route on the surface of the wing considering all foreseeable water 

conditions. 

Statement of no Adverse Effect on Safety: 

The FAA stated that the intent of the new outside viewing means requirements introduced at 

Amendment 25-116 was not to address a known safety issue, but rather to upgrade the 

regulations to improve the overall level of safety in areas where state-at-the art and good design 

practices have indicated that such upgrades are warranted. Learjet fully intends to meet the 

intent of the rule by providing a window and exterior lighting at the Type III overwing emerg ency 

exit that will allow evacuees to view the outside conditions with the exit closed. The window and 

lighting will also allow evacuees to view the escape route on the surface of the wing including a 

view of the ground once they have stepped out on to the wing . The evacuees will be capable of 

viewing the escape route and ground during all lighting conditions. 

Public Interest: 

Granting this petition for exemption would clearly be in the public interest as the intent of the 

regulation is being complied with. When the rule was amended, it appears that the FAA did not 

take into account aircraft equipped with overwing emerg ency exits. Not granting this petition for 

exemption would lead to an unplanned design and manufacturing effort to relocate the 

emergency exit forward into the main cabin. Incorporating this type of design change would not 

enhance the level of safety for the aircraft. 

Operation Outside of the United States 

In accordance with 14 CFR 11.81 (h), Learjet requests consideration be given to extending this 

exemption for operation outside at the United States. Learjet aircraft are routinely registered and 

operated outside of the United States. Granting this extension of privileges wi ll allow for 

operations based within foreign countries, including EU member countries, having bilateral 

agreements with the United States accepting FAA 14 CFR part 25 as their airworthiness 

standards for transport category aircraft. Learjet believes that limiting this exemption to use 

within the U.S. would put unfair restrictions on the continued marketability of this aircraft. 

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L706·11-12·2003 

Conclusion 

Based on the above information, Learje! Inc. believes that granting this exemption request 

would be in the public interest and would not adversely affect safety of the passenger traveling 

aboard the Learjet Model LJ 200. 

Yours truly, 

£&d-Ck 

Robert Cahn 

Director, Certification and Regulatory Compliance 

Learje! Inc. 

One Learje! Way 

Wichita, KS 67209·2942 

robert.cahn@aero.bombardier. com 

Tel: (316) 946·8968 

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