November 13 , 2015. GCF- 1933/2015

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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

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**Bngade~ro** Fana Lima. 2 170 12227·'901 • S .J. dos Campos· SP Brasal 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 flai l device installation. For details , please find attached the EMBRAER request.
Sincerely,



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- Willian TanjiGCF- 1933/2015-212



## EM **BRAE R**  Request for Extension for Exemption No.1 0974, Docket Number FAA-2013-081 0
Backg round : 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 Regulation s (14 CFR) and from FAA Special Condition 25-495-SC number 2(e). The exempt ion 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 pub lication and disposition of public comments , if any, Embrae r 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 comp lete 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 leve l of safety compared with earlier certified sidefacing seats that are sti ll being produced. In addition, any delay in aircraft delivery to meet the terms of the o rig inal exempti on will impose an adverse effect on our customers' ability to fully utilize the product they purchased and wi ll have an adverse economic effect on their operations. The extension of the previously granted exemption to cover ai rcrafts 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.