Cathy Scheu Flight Service Managing Director Policies, Training and Administration



### February 9, 2015 Docket Management Facility U.S. Department ofTransportation 1200 NewJerseyAvenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590 

### RE: Requested Relieffrom 14 CFR § 121.311(b) 

# AmericanAirlines'\...

American Airlines is writing to request an exemption from 14 CFR § 121.311(b) to the extent required for infants/children traveling on American Airlines to be able to use an FAA-approved Child Restraint System (CRS) in an obliquely oriented seat (notforward facing) on Boeing 777 and Boeing 787 aircraft during all phases offlight. The pertinent section from 14 CFR part 121 Seats, safety belts, and shoulder harnesses from which American Airlines seeks relief is: §121.311 Seats, safety belts, and shoulder harnesses. (b) (2) (iii) The certificate holder complies with the following requirements: (A) The restraint system must be properly secured to an approved forward-facing seat or berth; 

### Background: Title 14, Code of Federal Regulations (CFR) § 25.785(d) requires that each occupant ofa seatthat makes more than an 18° angle with thevertical plane containing the airplane centerline must be protected from head injury by a safety belt and an energy absorbing rest thatwill supportthe arms, shoulders, head, and spine, or by a safety belt and shoulder harnessthatwill prevent the head from contacting any injurious object. This provision, adopted in 1969, reflected the FAA's conclusion that a maximum 18-degree angle would provide an adequate level ofsafety based on tests thatwere performed at that time. This requirement clarified the definition ofsideward-facing seats.

4255 Amon Carter Blvd MD 4290 FortWorth, TX 76155 817-963-6952 Office 817-931-9215 Fax cathy.scheu@aa.com

# AmericanAirlines"'-..

The seating configuration, forthe o'blique.:facing premium class passenger seats in Boeing model 777 and 787 aircraft operated by American Airlines and approved by the FAA may result in up to a maxirnumangle of28° to the aircraft centerline forthe seat occupant. Therefore, these.seats are. not forward facing as defined by regulation. An Equivalent Level of Safety Finding was made forthe following regulations relative to the ZSUS Z938 model oblique-facing Business Class Passenger Seats on the AAfleetto address the classification ofthis seat model design as forward 

### & aft facing for purposes of meeting 14 CFR 25.652 & 25.785 requirements. 14 CFR 121.311(b)(2)(iii)(A) requires certificate holders to ensure that CRS are properly secured to an approved forward-facing seat or berth. Because the oblique-facing premium class passengerseats in l3oei.ng rnodel 777-200 :and 787 aircraft operated by American Airlines are notforward facing, FAA approved CRS cannot be used in those seats. As a result ofthis, safety is diminished for children traveling with parents in the premium cabin in that they would have to be held in the parent's lap. This restriction also creates operational challenges in tJ;\e,event ofaircraft equipment changes should a parent traveling with a child in a CRS have bookeda flight on an ·aircraft type that c;illows use of CRS in premium cabins. · · · 

### Proposal: Based on the equivalent level of$afety demonstrated during certification ofthe ZSUS Z938 model seats, American Airlines proposes allow use ofCRS in the obliquely oriented toward the forward ofthe cabin seats premium cabin seats. American Airlines does not propose allowing CRS in obliquely oriented seatstoward the aft ofthe aircraft. 

### Equivalent level ofsafetyto thatofthe affected regulation: American Airlines understands the regulation is written to createa high ievel ofsafetyfor each individual passenger by ensuring thatthey are securely restrained in an aircraft during all phases offlight.. Theregulation also ensures that the operational use of FAA approved CRS, only in a forward facing seat, is consistent with the certification basis and performance testing·fo'rCRS.·'

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### .

**~** ' ' -•. . This proposal will prOvide an ·eguivalenflevel ofsafetyto that ofthe affected regulation er\ • ", ·'' • • based on the equivalent



### l~vel'6f safetyju$fifications documented in TAD ELOS Memorandum



### BY31'3~c-Yci~tedMarch.5, 2014.and approved forthe Type Design certification ofthe seat designand installation. B1313-C-1 established an ELOS forthe forward oblique angled seats with respect to occupant injury testing. Specifically, this

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means ofcompliance established thatthe design ofthe ZSUS:Z938 model forward side- .facing seats are such thatthe reactions ofthe occupant to dynamic loads are the same as those for an occupant in a standard facing seat'installed at an angle 18 degrees or less from the airplane centerline. STC ST10498SC approved compliance to the ELOS forthe design and installation ofthese seats on the AA 777-200.· Installation ofthis mQd_el seat on theAA 

### 781-8 was accomplished via a



### siinil~r ELOS issued to the Boeing 9ompany and Type Design approval underTC T00021SE. 

### Public Interest: Enhancing safety is ih the public interest. All<:>wing use of CRS in obliqu.ely oriented seats · enhances the level ofsafety by

**allowing~**children underthe age oftwo to be secured in a

CRS ratherthan on a parent's lap. · ·· lfit is necessaryto put a·summary ofthis petition inthe Federal Register, we submitthe ·following: ; · ..-. ·· .::

This is a request for an exemption from FAR 121.311 (b) to the extent required for infants/children traveling on American Airlines to be able to use an FAA-approved Child Restraint System (CRS) in a obliquely oriented seat (notforward facing) on Boeing 777 and Boeing 787 aircraft during all phases offlight. sfncerely,



# Ca~~ American Airlines
· · Flight Service

.. Managing DirectorAdministration, Training andProcedures' · Ecc: Calvin 

### R. Lett, Principal Operations Inspector DFWCMO Travis G

.. Blower, Aviation Safety Inspector DFWCMO Thomas J. Rocha, Aviation Safety lnspectpr QlfW

### CMO,

. Ronny G. Moon, Aviation Safety

**lnspe<?tO..~.** DFvv.CMO .·· .. HectorAdler, Vice Presiaent Flight 

### Se1Vic$' American

**Airline~** Leanne Risley, Sr. Manager Flight Service

**Safe~y_** and Regulatory American Airlines _.,;.

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