Inside One Suite 787 Exemption Request

Mention petitions for exemption and the vision of industry's technological march trampling a regulator's antiquated regulations often comes to mind. Usually, the issues at hand are technical; the 787's novel designs required more than a dozen exemptions covering everything from a composite fuel tank's crash survivability to the now all-too-familair large, high-capacity lithium ion batteries.
 
Boeing is looking for another exemption--albeit one that is not nearly as technical as the ones that helped get the 787 airborne. 
 
This petition seeks an exemption from part of 14 CFR 25.785, which requires--among other things--that flight attendant seats be configured to provide direct views of cabin areas and their occupants. Premium suite walls prevent seated flight attendants from seeing some passengers, which means exemptions are needed--and usually granted.
 
Boeing has them for the 747 and 777, but none of the 787 operators have anything more fancy than a mini pod, similar to what Air Canada has going in:

blog post photo
(Photo: Air Canada)
 
But if Boeing gets its way--and there's no reason to think it won't--some future 787 will be a tad fancier up front. From the petition:
 
Operators are requesting Boeing to install premium mini-suite systems . . . . A typical mini-suite consists of a seat, an ottoman, and personal stowage units. To provide additional comfort, convenience and care for the passenger, every seat is surrounded by partial height partitions and doors.
 
Those seat surrounds, Boeing notes, are "integral" to making the whole configuration work. They're also what violates the rule in question.
 
Oh, but the benefits of violating said rule! Summarizing a few salient points from the petition:
 
* A suited-out 787 is expected to have 12 first-class places, compared to a maximum of 36 standard seats. Fewer passengers means an easier (and safer) evacuation!

* Lots of foreign operators are buying 787s, and in some countries, taking photos or videos of people without their consent is not legal. Mini suites eliminate this problem, which in turn improves the 787's marketability!

* Other manufacturers of long-haul widebody airliners have approvals to put suites in their planes. Not granting the same opportunity to Boeing would create an unfair competitive advantage in the global airliner marketplace and could lead to sales losses, which will reduce the balance of trade, U.S GDP, and overall U.S. economic health!

* And last but not least, putting very expensive mini pods up front will lower travel costs by allowing carriers to lower fares elsewhere onboard without sacrificing too much profit. Downright Robin Hood-esque, they are! (Okay, so the petition may not contain that last little bit....)

There's a lot more in the overly convincing but otherwise routine 10-page request
 
And while its importance pales in comparison to, say, keeping the plane's fuel tanks whole in case a tire shreds itself bit-by-bit during a takeoff role, it's much more entertaining reading than a typical safety equivalence report. 

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