1/5 

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

DIRECTION GÉNÉRALE TECHNIQUE 

Mérignac, October 23rd, 2014 

DGT-DTC/CEP 369796 

RL/FA 

TO : 

 Federal Docket 

Management System 

(transmitted 

electronically) 

 

Please contact Rémy LAMELOT Tél : +33 (0) 556 13 4156 Fax : +33 (0) 556 13 9187 

SUBJECT: Falcon 7X Series - Petition for exemption regarding 14 CFR Part 25.1447(c)(1)

Applicable to: passenger oxygen dispensing units 

1. Name and Address of the Petitioner [as per 14 CFR 11.81 a]

Rémy Lamelot, Certification Manager 

Dassault Aviation 

54 avenue Marcel Dassault – BP 24 

33701 Mérignac Cedex, France 

Phone: +33 556 13 4156 

Email: remy.lamelot@dassault-aviation.com 

2. Specific Section from which Exemption is Sought [as per 14 CFR 11.81 (b)]

To whom it may concern: 

DASSAULT AVIATION is officially applying for a permanent exemption to the following rule: 14 

CFR Part 25.1447(c)(1). 

14 CFR section 25.1447(c)(1) requires that “there must be an oxygen dispensing unit connected to 

oxygen supply terminals immediately available to each occupant, wherever seated”. It further states in 

part that “If certification for operation above 30,000 feet is requested, the dispensing units providing 

the required oxygen flow must be automatically presented to the occupants before the cabin pressure 

altitude exceeds 15,000 feet.” 

3. Summary of the Petition [as per 14 CFR 11.81 (f)]

In accordance with the provisions of 14 CFR 11.81, DASSAULT AVIATION respectfully petitions 

for a permanent exemption from FAR 25.1447(c)(1) to allow the installation of a passenger oxygen 

system which, when operating into or out of an airfield with a pressure altitude greater than 14,000 ft 

but lesser than 15,000 ft, ensures the automatic presentation of oxygen dispensing units to occupants 

before cabin altitude exceeds 16,000 ft, rather than 15,000 ft as required per FAR 25.1447(c)(1). 

09004000808007dd - RELEASED - Certification Repository
 DGT-DTC/CEP 369796 2/5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

When operating into or out of an airfield with a pressure altitude less than or equal to 14,000 ft, the 

oxygen system complies with FAR 25.1447(c)(1) and ensures that passengers oxygen masks are 

automatically presented before cabin altitude reaches 15,000 ft. 

In support of this request, DASSAULT AVIATION is proposing alternative design requirements to 

provide a level of safety appropriate to the operation of Falcon 7X aircraft on airfields with pressure 

altitude up to 15,000 ft. DA proposition takes benefit from previous certificates of exemption issued by 

FAA that permit the installation of an oxygen system with a setpoint higher than 15,000 ft for 

automatic presentation of oxygen masks. 

4. Background / Extent of relief and reason [as per 14 CFR 11.81(c)]

Dassault Aviation has submitted an application for FAA validation of a type design change to the 

Falcon 7X model aircraft to allow operations into / out of airfields up 15,000 ft pressure altitude. This 

project is managed under change number M1315. The US certification basis for F7X is 14 CFR part 

25, effective February 1, 1965, including Amendments 25-1 through 25-111 in entirety as documented 

in Type Certification Data Sheet A59NM. 

The Falcon 7X Series is designed to meet the requirements of 14 CFR Part 25 for Transport Category 

aircraft. These rules were written at a time when all airfields accessible to such aircraft were located 

below 14,000 ft. As a result, the aircraft cabin altitude was never supposed to reach 15,000 ft under 

normal circumstances, and having an oxygen system that automatically presents oxygen masks when 

cabin altitude reaches 15,000 ft was an adequate compromise between occupants’ safety and the 

conduct of operations on high-altitude airfields. 

The Falcon 7X is already certified for high Landing Field Elevation operations, with a maximum 

airfield pressure altitude of 14,000 ft. However a few airfields with a LFE between 14,000 ft and 

15,000 ft above mean sea level exist in the Chinese regions of Tibet and Sichuan. This means that 

under standard atmospheric conditions, pressure altitude on these airfields will be between 14,000 ft 

and 15,000 ft. These airfields are accessible to Transport Category aircraft. 

When operating out of or into such airfields, the cabin altitude may thus reach values close to or even 

equal to 15,000 ft before takeoff or after landing. This could result in unwanted presentation of oxygen 

masks and the need for a maintenance operation in order to store them back into their boxes, plus a 

possible cancellation or delay of the planned flight. 

The change proposed is designed to maintain an equivalent level of safety while minimizing the 

possibility of such unwanted deployment of oxygen masks. 

The current design of the passenger oxygen system has one pressure altitude setpoint of 14,500 ft +/- 

500 ft (accounting for sensor tolerance), thus ensuring automatic presentation of oxygen masks before 

cabin altitude reaches 15,000 ft. 
 DGT-DTC/CEP 369796 3/5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

In the proposed design, a second setpoint of 15,500 ft +/- 500 ft is implemented in the oxygen system. 

The Cabin Pressure Control System automatically commands the Oxygen System to use this second 

setpoint when aircraft pressure altitude is below 24,800 ft and one of the following conditions is true: 

- Aircraft is on ground and aircraft pressure altitude is above 14,000 ft, OR 

- Aircraft is in climb and the pressure altitude at take off was above 14,000 ft, OR 

- Aircraft is in descent and the selected Landing Field Elevation is above 14,000 ft. 

Under all other conditions, the mask deployment setpoint remains at the current value i.e. 14,500 ft +/- 

500 ft. 

The manual mask deployment control (“Override” position of the oxygen control rotactor) is 

unchanged and remains available at any moment whatever the setpoint value. 

Note that the maximum cabin pressure altitude reached in flight under normal operating conditions is 

not modified compared to current certified design, which was found compliant with FAR 25.841 (a). 

When takeoff airfield pressure altitude is between 14,000 ft and 15,000 ft, the cabin pressure control 

system will pre-pressurize the aircraft before take-off and set the cabin pressure altitude to 13,542 ft 

(same value as today when operating from a 14,000 ft airfield). During climb, the CPCS will let the 

cabin pressure increase, ensuring that a cabin altitude not more than 7,950 ft is reached before the 

aircraft climbs above 25,000 ft pressure altitude. This behavior is identical to current design already 

certified for operations up to 14,000 ft airfield altitude. 

As a result, the setpoint for the cabin high altitude warning CAS message is unchanged and remains set 

at 14,200 ft for high LFE operations. The high cabin altitude warning is inhibited on ground in order to 

avoid nuisance warnings. The high cabin altitude warning setpoint is reset to the normal value of 8,000 

ft when the aircraft altitude climbs above 24,800 ft. This feature (changing the setpoint of the cabin 

altitude warning message) is already part of the existing design for high LFE operations. 

Conversely, when LFE is between 14,000 ft and 15,000 ft, the CPCS will keep cabin pressure altitude 

below 7,950 ft until the aircraft descends below 24,800 ft pressure altitude. At that point, the high 

altitude warning threshold will be shifted from 8,000 ft to 14,200 ft, and the CPCS will let the cabin 

pressure altitude increase until it reaches 13,542 ft. The CPCS will keep the aircraft pressurized at 

13,542 ft cabin pressure altitude until landing is completed. This behavior is identical to the existing 

aircraft when landing at an airfield with LFE equal to 14,000 ft. 

As a result, this proposed design change does not degrade the level of safety as far as FAR 25.841 (a) 

is concerned. It will be demonstrated by System Safety Analysis that cabin pressure altitude always 

remains below 15,000 ft under any reasonably probable failure condition. 

5. Public Interest [as per 14 CFR 11.81(d)]

DASSAULT AVIATION performs the completion and interior furbishing of most of the aircraft it 

produces in Dassault Falcon Jet manufacturing plant of Little Rock, AR. Falcon aircraft are fitted with 

many products such as avionics, auxiliary power units, environmental control systems, from several 

suppliers based in the United States. The exemption will directly impact the utility of the Falcon 7X 

for high-altitude operations and will allow fulfilling an explicit request from customers for such 

capability, thus having a direct effect on sales. These extra sales will benefit the economy in all 

communities where Dassault Falcon Jet and its suppliers are located, which is in the public interest. 
 DGT-DTC/CEP 369796 4/5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

6. Reasons why granting the exemption will not adversely affect safety [as per 14 

CFR 11.81(e)]

The safety features described above (cf. §4) will ensure the avoidance of unwanted oxygen mask 

deployment during operations on high altitude airports, while still providing for automatic deployment 

in case of cabin depressurization or lack of pressurization (the highest possible cabin altitude for mask 

deployment being 16,000 ft), and for manual deployment in case of failure of the automatic mode. 

It will be demonstrated by System Safety Analysis that proposed design for pressurization and 

passenger oxygen systems meets or exceeds all failure probability requirements. 

The exemption requested would thus have no adverse impact on current level of safety for the Falcon 

7X aircraft. 

7. Additional information [as per 14 CFR 11.81(g)] 

In the scope of this petition, DASSAULT AVIATION takes benefit from previous grant of exemptions 

issued by FAA dealing with the setting of oxygen mask deployment setpoint above 15,000 ft for high 

airfield operations. Please note that FAA has previously granted such exemptions to several models 

with much larger passenger capacity than the DASSAULT Falcon 7X Series. 

Exempt. 

No 

Issue Date Expir. 

Date 

FAA 

Office 

Disp. Regulation Petitioner Aircraft 

6076 04/26/1995 (NoExpire) (NA) Granted 25.841(a) 

25.1447(c)(1) 

The Boeing 

Company 

B757 

6994 09/16/1999 (NoExpire) (NA) Partially 

Granted

25.1447(c)(1) Airbus 

Industrie

A319, 

A320, A321 

8668 12/02/2005 (NoExpire) (NA) Granted 25.1447(c)(1) The Boeing 

Company

B737 

9801 12/12/2008 (NoExpire) (NA) Granted 25.1447(c)(1) The Boeing 

Company

B787 

10044 04/01/2010 (NoExpire) (NA) Granted 25.1447(c)(1) Gulfstream 

Aerospace 

Corporation

GIV-X 

GV-SP 

8. Request for waiver from publication and comments [as per 14 CFR 11.87]

Considering the above listed exemptions, it is Dassault Aviation opinion that the requested exemption 

is identical to exemptions granted previously and that granting this petition would not set a precedent. 

As a result Dassault Aviation respectfully requests that action on this petition should not be delayed by 

publication and comment procedures. 
 DGT-DTC/CEP 369796 5/5

This document is the intellectual property of DASSAULT AVIATION. It may not be used, reproduced, modified or disclosed without its authorization. DASSAULT AVIATION Proprietary Data. 

9. Exercise of exemption privileges and Operation outside US [as per 14 CFR 

11.81(h) and 11.83]

Considering the multitude of countries in which Falcon 7X Series are sold and operated, it is very 

likely that this exemption should be recognized by some other countries usually agreeing with FAA 

position. 

Moreover, all the existing airfields with altitude higher than 14,000 ft are located outside the United 

States. Dassault Aviation thus requests extension of this exemption outside the United States. 

10.Conclusion 

Dassault Aviation believe that the above arguments favor an exemption from 14 CFR 25.1447(c)(1) 

that would allow operations into / out of airfields up to 15,000 feet for F7X aircraft. Additionally, 

Dassault Aviation believes that such an exemption is in the public interest and does not adversely 

affect current level of safety of the aircraft. 

Please do not hesitate to ask for any additional information which you may require in order to respond 

to this petition. 

Respectfully submitted, 

Rémy LAMELOT Laurent FRANZONI

Certification Manager F7X Program Certification Manager 

Evidence of signature is provided by a red electronic stamp on the first page left hand margin.