BOMBARDIER 

# LEARJET

November 21,2012 In Reply refer to: L706-11-12-2003 U. S
. Department of Transportation Tran sport A i rplane Directorate Attn: Alan S in cla ir 1601 Lind Avenue, S.W. Renton, Washington 98057 -3356 Lear,,! Inc PO. Box 7707 Wich ita. KS 67277·77 07 UIlI !ed S!ales \""Nloo mbardier corn ill 3 16·946· 2000 fAX 316·946·2809

SUBJECT: Subm ittal of Petition for Exemption - 14 CFR Part 25, Sect ion 25.809(a) Amendment 25-116 for the Typ e III Overw in g Exit View i ng 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 In c. submits this petit i on for exemption from 14 C FR Part 25 , Section 25.809(a) Amendment 25-116 , for the requi rement of viewing th e likely areas of evacuee ground contact at the Type III over-wing emergency exit when the ex it is closed
. Learjet proposes to provide a means that will allow evacuees to view the escape route on the surlace of the w in g along with the outside environment during all li ghting condi ti ons . An app li cat ion for a new type Certifica te (TC) has been submitted by Learjet In c. for this new model and FA A Project no. T C4960W I-T has been assigned to this effo rt. Th e cert ifi cat ion 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: I n November 2004, th e FAA amended 14 CFR Part 25 , Sect ion 25.809(a) to requi re a means to permit v i ewing of th e conditions o utside the exits when the exits are c losed
. The FAA in dicated that emergency evacuations a re freq uently necessary ei ther due to, or i n combination with, a hazard such as a fire outside the airp lane. Because the hazard may pose an immediate threat to the occupants of the airplane , it is often n ecessary to avo i d open in g certain otherwise useable emergency exits in order to prevent inj ury to the evacuees . In th is context , a v i ew in g window o r other means of assessing the outside condi ti ons and determin ing whether an exit s hould be opened is extremely valuable
. A viewing w in dow is commonly prov id ed in most ex i ts in service; however , it has not been required, and some exits i n se rv ice do not i ncorporate one. Howev er when this rule was amended , it appears that the FAA slid not take in to consideration aircra ft equipped wi th overw i ng exit ar rang ements
.L706 - 1 1 -12-2003 T he Learjet 200 aircraft w ill be certi f ied with two (2) emergency exi ts; one Ty pe I and one T ype III. T he Type I e m ergency exit w ill be located on th e LH side of t he aircraft approximately 4 feet behind the pilot. Th e Type III emergency exi t wi l l be located in th e aft lavatory on the AH side of the airc raft d i rec tl y ove r t h e wing
. Both e m ergency exits wi ll be equipped w i th a m eans that w ill permit view i ng of the outside condi ti ons when the exit is closed. H owever, th e viewing means at the Type III eme rg ency ex it, consisting of an a ircraft window, wi l l only permit viewing of th e li kely a reas of evacuee contact wi th t he w i ng suriace; pri mar il y the s li p resistant escape route. Once an occupant steps ou t on to t he wing, t hey w i ll th en be able to v i ew the ground whe re they would like ly m ake co ntact
. Exte ri o r light in g will provi de suff ici ent illum ination to v iew the wing surface and the ground a rea und er a ll a mb ien t li g htin g co nd iti ons and with the land i ng gea r extended as well as in all conditions of landing gear collapse. Since th e a irc raft w i ll be certif ied fo r ditching and the d itching analysis ind ica tes that th e wings will b e sub m erged under water by a pprox im ately 1 8 i nches , th e design of t h e exter ior li g hting w ill be such that evacuees will be able to v i ew th e escape route on the surface of t he wing consider ing a ll foreseeab le wate r condit ions . Statement of no Adverse Effect on Safety: Th e FAA stated that t he in ten t of the new outs ide v i ewing means requirements in troduced at Amendment 25-116 was no t to address a known safety issue, but rather to upgrade the regulations to i mp rove th e overa ll level of safety in areas where sta te-at- t he art and good des ign p r

actices have indica ted th at such upgrades are warranted. Lea r jet fully int ends to meet th e in tent of the rul e by p rovid in g a window and exter io r lighting at the Type III ove rwing eme rg ency exi t that will allow evacuees to view t he outside condi ti ons with the exit c losed. The w i ndow and lighting w ill also allow evacuees to v i ew the escape rou te on the s urface of th e w i ng inc l uding a view of the ground o nce they have stepped out o n to th e wing
. Th e evac u ees w ill be capable of viewing the escape rou te and g rou nd during all li ght in g condi ti ons. Public Interest : Grant in g this peti ti on for exemptio n wou ld clear ly be in the p ubli c interest as th e intent of the regu lati on is be in g complied with. When t he rule was amended, it appears th at the FAA d id not ta ke in to acco unt ai rcraft equ ip ped w ith overw in g e m e rg ency ex i ts. Not granting this petition for exemp ti on wou ld lead to a n unplanned design a nd manufacturing effort to relocate th e emergency ex i t forwa rd into t he main cab in
. In corpora tin g th is type of design change wou l d not enhance the leve l of safety for th e ai rc raft. Operation Outside of the United States In accordance with 14 CFR 11.81 (h) , Lear j et requests cons idera ti on be g iven to extending this exemption for operat ion outs id e 

### at the U nited States
. Learjet aircraft are routinely registered and ope rated outs i de of the U n ited States. G ranting this extension of privileges wi ll allow for operations based w it hin foreign countr i es, including E U m ember countr i es, having b il ate ra l agreements w ith the United States accep ti ng FAA 14 CFR part 25 as the ir a i rworthiness standards for transport catego ry ai rcraft
. Learjet be li eves that lim i t ing t his exemption to use with i n the U.S. would put un fair restrictions on the con ti nued marketability of th i s aircraft
.

2L706·11-12·2003 Conclusion Based on the above information , Learje! Inc . believes that granting this exe mption request 

### would be in the public interest and would not adverse l y affect sa fety of the passenger trave lin g aboard the Learjet Model LJ 

### 200
.

Yours tru ly,



# £&d -C k Robert Ca hn 

### Director, Certification and Regulatory Compliance Learje! In c . 

### One L earje! Way Wichita , 

### KS 

### 67209·2942 robert .cahn@aero.bombardier. com Tel : (316) 946·8968



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