November 13, 2015. 

GCF- 1933/2015 - 1/2 

CAS 

U.S. Department of Transportation, 

Docket Operations, 

West Building Ground Floor, Room W12-140, 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Subject: EMB-550- Extension Request for Exemption 

EMBRAER 

Embraer S.A. 

Av Bngade~ro Fana Lima. 2 170 

12227·'901 • S.J. dos Campos· SP 

Bra sal 

Fone (12)3927·5043 

Fax (12)3927·11 ~ 

PC 179 

Petition to the Extension Request for Exemption from 14 CFR 25.562 (b) 

amend 64, 25.785(b) amend 88 and Special Condition N° 25-495-SC 

number 2. (e) 

Dear Mr. Thompson: 

EMBRAER respectfully requests an Extension for Exemption from 14 CFR 25.562(a) 

amendment 25-64, 14 CFR 25.785(b) amendment 25-88 and FAA Special Condition 

25-495-SC number 2. (e), in order to allow the certification of the installation lateral 

single and multiple side facing seats in the EMB-550. 

This installation is associated with a Design Change Application (DCA) 0550-025-

00006-2015 Anti leg flail device installation. 

For details, please find attached the EMBRAER request. 

Sincerely, 

. 4~c-t 0/'~~ icir'~ ~« uerbach / 

Airworthi ess Director Ra:a~i Gu tavo Fassi11a rqu s 

Airworthinm Office 

I CC: I ANAC - Willian Tanji 
GCF- 1933/2015-212 EMBRAER 

Request for Extension for Exemption No.1 0974, Docket Number FAA-2013-081 0 

Background : 

By letters dated September 6, 2013, and November 22, 2013 EMBRAER petitioned the 

Federal Aviation Administration (FAA) for an exemption from the requirements of 

25.562(a) and 25.785 (b) of Title 14, Code of Federal Regulations (14 CFR) and from 

FAA Special Condition 25-495-SC number 2(e). 

The exemption No. 10974 was granted on April 04, 2014, that permits partial relief for 

the lower-leg flail requirement for the forward-most seat position on all side-facing seats 

on EMBRAER Model EMB-550 airplanes, serial number 1 to through 55. 

EMBRAER ANALYSIS AND ARGUMENTATION 

On September 21 , 2015, the Federal Aviation Administration informed Embraer of the 

need for an additional special condition to address the certification requirements for the 

use of airbag systems as a means to limit the axial rotation of the upper-leg on side 

facing seats, as required by Special Condition 25-495-SC. In this new special 

condition, the FAA has identified thirteen additional requirements to be satisfied. 

Because of the additional administrative time required to process the new special 

condition, including Federal Register publication and disposition of public comments, if 

any, Embraer will not be able to certify the side-facing seats in time to meet the 

limitations of Exemption 10974. Accordingly, EMBRAER request an extension of this 

exemption until January 2017. 

EMBRAER emphasizes the commitment to complete the certification of this system 

within this extended time, and all efforts are being done to bring it into production in the 

shortest feasible time. In addition, Embraer will continue to abide by all the other 

limitations in the original exemption. 

The side facing seat of the EMB-550 is one of the few that have been certified to the 

new dynamic standard, so even without complying with the new leg flail requirement it 

represents a significant increase in level of safety compared with earlier certified sidefacing seats that are still being produced. In addition, any delay in aircraft delivery to 

meet the terms of the original exemption will impose an adverse effect on our 

customers' ability to fully utilize the product they purchased and will have an adverse 

economic effect on their operations. The extension of the previously granted 

exemption to cover aircrafts until January 2017 continues to be in the public interest 

because the level of safety provided is still greater than that of our configurations being 

offered. 

EMBRAER appreciates FAA 's consideration of this extension request. If there is any 

further information required, please contact us.