OCT. 11,200? 4:OOPM TRANSPORT CANADA NO. 374 P. Transport Transports FACSIMILE TRANSMITTAL FORM Mark Sappa inearnational Regulations 330 sparks Street Ottawa, Ontario K1A OM8 (AAB.TCJ BORDEREAU DE TRANSMISSION PARTELECOPIEUR Fax to: Telecopier a : Docket Management Facility - U.S. Department of Transportation Fax number Num6ro da telscopieur Telephone number Numerc. de telephone 202-493-2251 N/A From: De: Fax number N" de tetecopieur Mark Zappa/ Transport Comments: Commenteires : ( 13) 952-3238 Please find attached Transport 's coamants concerning FAA NPRM 07-13 - Special Requirements for Private TTsa Transport Category Airplanes Ifark Zappa you for the opportunity to comment on. the above mentioned document. International Regulations (AARTC) Aircraft Certification Standards, Standards Branca Transport Civil Aviation 330 Sparks Street Ottawa, Ontario K1A ONS 613-941-6041 Number of pages including this sheet Nombre de pages induant oelle-ci Transmission date Date da transmission 1 For additional information, please contact f* me at: Pour plus de renseign&ments. composer le : 2007-10-11 (613) 941-6041 *0-*223 <(W05-02)
OCT. 11.2007 4:QOPM TRANSPORT CANADA 1374 P. 2 OPI Acknowledgement Form Consnltation - _, have reviewed this attached letter to the foreign authority and agree with its contents. OPI Technical Support Officer Date
OCT. 11.2007 4:QQPM TRANSPORT CANADA NO, 374 P. Transport Transports Ottawa, Ontario K1AON8 Your file FAA-2007-28250 Our file 5009-6-525 Thursday, October 11,2007 Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SE. West Building Ground Floor, Room W12-140 Washington, DC 20590 Fax: (202)493-2251 Reference: Subject: FAA Docket Number FAA-2007-28250 FAA NPRM 07-13 - Special Requirements for Private Use Transport Category Airplanes Dear Sir or Madam, The FAA gave notice on the availability of the subject Notice of Proposed Rulematatng (NPRM) and invited interested persons to submit their comments to the FAA. Transport would like to forward the following comments for your consideration. Comment 1 - General Transport supports the FAA rulemaldng action that will alleviate the burden on industry of preparing exemption requests and authorities processing the requests, while providing industry the flexibility to configure executive interior airplanes to meet the customer requirements and satisfy appropriate minimum standards of safety, Transport notes that application of the proposed SFAR is voluntary, however when selected by the applicant, compliance must be demonstrated with all applicable provisions. The specific items in the proposed SFAR address issues that have been processed on previous certification programs by special conditions, findings of equivalent safety and exemptions. For example, a single exit sign has been certified as meeting the requirements of 25,811 (d)( 1) and (2)
OCT. 11.2007 4:01PM TRANSPORT CANADA NO. 374 on airplanes with fewer than 20 passengers through equivalent safety findings. Cooktops have been certified using special conditions. It is likely that applicants who are only interested in those aspects previously certified under equivalent safety findings and special conditions would elect to continue to utilize these means to avoid the operational restrictions proposed in the SFAR, The voluntary nature of the SFAR will continue to permit this flexibility. Comment 2 - Paragraph 4.0s) Injury criteria for multiple occupancy side-facing seats The criteria in this section for certification of side facing seats generally reflect the conditions in FAA Policy Memorandum of November 19, 1997. This policy was revised on May 06, 2005 and provides simplified criteria to certify multiple occupancy side-facing seats. The final rule should recognize that the more recent criteria have been issued, Comment 3 - Paragraph 9.( i Exit Siens It is presumed the reference in the first sentence should be 25.812(b)(l), not 25.812(b)(2) as indicated, since the intent is to permit smaller size signs than are required by 25.812(b)(l) for passenger capacities of 10 seats to 19 seats. Airplanes with more than 19 passenger seats will be required to meet 25.812(b)(l). Comment 4 - Paragraph 10. Interior Doors The wording of Section 10 reflects FAR 25.813(e), Amendment 25-115. This section was changed at Amendment 25-116 to prohibit the installation of a door between any passenger seat that is occupiable for takeoff and landing and any passenger emergency exit, such that the door crosses any egress path. Consequently for airplanes whose certification basis will include Amendment 25-116, all of the conditions of Section 10 of the SFAR should be applied to any door that would result in non-compliance with 25.813(e) 3 not just doors between passenger compartments. This also affects paragraph 2(b) of the SFAR? which specifies the requirement for a Flight Attendant on some "Airplanes outfitted with interior doors under paragraph 10..." Additional conditions applied by Transport for exemptions to Canadian Airworthiness Manual Chapter 525, pre Change 525-12 (equivalent to FAR 25.813(e), pre Amendment 25-116), are as follows: * TCCA requires the signal to the flight crew to be integrated into aircraft Cautions, Warnings and Advisory system and to apply to any door between passengers and an emergency exit o Rationale - there needs to be consistency in the manner in which information is brought to the attention of the flight crew. The addition of a separate annunciation system may reduce the effectiveness of the means required to signal the flight crew of the door position;
OCT. 11.200] 4:01PM TRANSPORT CANADA NO. 374 P. 5 * TCCA'requires dual means to retain the door in the open position to apply to any door between passengers and an emergency exit. o Rationale - since doors between passenger compartments are prohibited the exemption should include additional conditions to mitigate the reduction in the level of safety resulting from the addition of such a dooi and thus expanding the door retention requirement to any other door between the passengers and the exits; * The exemptions issued by TCCA are applicable to executive interior airplanes with. maximum passenger seating capacities of 19. Therefore, not more than one door between passenger compartments has been permitted. o Rationale - TCCA exemptions have only been issued against relatively small business jets with limited numbers of emergency exits; * TCCA has required these doors to be operable from either side, and if a locking mechanism is installed, it must be capable of being unlocked from either side without the use of special tools. o Rationale - this condition is an extension of the normal requirements for lavatory doors as a means of preventing passengers from becoming trapped in a compartment. Comment 5 Paragraph 11. Width of Aisle Transport shares the objectives discussed by FAA with respect to the purposes for minimum aisle width. However, Transport has also certified executive interior configurations on airplanes with a maximum passenger capacity of 19, where local aisle width may be reduced to zero due to seat translation / rotation or berthing functions. All such configurations are subject to review to ensure the resulting restrictions will not prevent crewmember access to cabin, lavatory or cargo compartment areas, as necessary to accomplish emergency procedures. In a representative configuration, a flight crew member responding to a smoke indication in the Class B cargo compartment may have to pass through several doors, potentially cross local obstacles due to seats protruding into aisles, and step across, or on, divans in their berthed position. These configurations have been found acceptable in the past on both Canadian domestic products and foreign products of similar type. While such airplanes are typically operated privately, the type of operation has not been so limited in the past. Transport supports the concept of a minimum in-flight aisle width, however, for those smaller transport category airplanes, which typically have passenger capacities limited to 19 in the original type certificate, this could significantly impact the range of configurations required by customers and found acceptable in the past. For such airplanes, the FAA should consider an alternative to a minimum in-flight aisle width, such as, "There must be sufficient access in flight to enable a crewmember to effectively reach any part of any compartment where this is necessary to accomplish emergency procedures." Such an approach would require development of advisory material to ensure consistent application of the requirement. Transport would be pleased to work with the FAA on the development of appropriate guidance material.
OCT. 11.2007 4:Q1PM TRANSPORT CANADA NO, 374 An additional issue, which arises due to the ability of seats to translate and or swivel., is the potential to block a door swing path required for decompression purposes per 25.365(g), This issue is the subject of petitions for exemption to both the FAA and TCCA for executive interior airplanes. Depending on the outcome of these petitions this issue should be considered for inclusion in a future revision of the SFAR~ Comment 6 - Paragraph 13. Fire Detection In the discussion on fire detection, the FAA notes that 25.854(a) requires cabin fire detection equipment only in lavatories. Since section 25.854 only applies to airplanes with a passenger capacity of 20 or more, it is not clear whether the intention of paragraph 13 of this SFAR would be to require some detectors in lavatories on airplanes with a maximum passenger capacity of 19 or fewer. Thank you for the opportunity to comment on the subject NPRM. Youns truly, Gilles Morin Chief, Aircraft Certification Standards