# PLANEANTENNAS &

# SEcuRITYSrsTEMS Robert Wagner Vice President 3020RockbridgeRd McGregor TX, 76657



### P-13-00001 U.S. Department ofTransportation Docket Operations, M-30 1200 New Jersey Avenue, S.E. Room W12-140, West Bldg. Ground Floor Washington, DC 20590-0001 

### Subject:
Modei: Request the existing 12 month exemption from 25.571 related to "Normal Flight Envelope"for Birdstrike be revised toa24 monthexemption 737- 900 

### FAAProjectNo.: ST09645SC-T 

### Reference(s): N/A 

### Special Instructions: N/A · 

### This letter submits: (X) Request for Exemption 

### This letter is sent for: (X) Review and Approval As one ofthe large antenna installation projects that is currently on a 12 month exemption being based on previously approved aircraft, Plane Antennas and Security Systems Inc (P.A.S.S.) respectfully requests that the public comment period be waved.



### Please contact me if you have further questions: Sincerely, 

## Robert Wagner (812) 204-4616
Enclosure: Petition for Exemption from 14 CFR25.571(e)(1) at Amendment 25-132

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### A. Name andAddress ofthe Petitioner Robert Wagnei 3020 Rockbridge Rd McGregor TX 76657 

### B. Section ofthe Code ofFederalRegulations (CFRs) thatareAffected As provided for in §11.61(b), Boeing hereby petitions for exemption from the following 14 CFRfor the model 737-900:

Regulation 

# I Amendment Requirement 25.571(e)(l) 25-132 the airplane is capable of successfully completing aflightfollowingtheimpactwith a4---pound bird when the velocity ofthe airplane relative to the bird along the airplane's flight path is equal to Vc 

# I at sea level or .85Vc at 8,000 feet, whichever is I more critical. However, this requirement need 

## I 

# Inot be considered if it can be demonstrated that 

# I 1 a bird cannot strike the radome within the normal 

# Iflight envelope up to the design speeds required 

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by § 25.571(e)(l). 

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C. The ExtentofReliefBeingSought Regulation Requirement Why reliefis necessary 25.571 Per the federal regulation 91,117(a) aircraft are not to fly (e)(l) beyond 250 knots at an altitude below 10,000 feet and this project expected to use the "normal flight envelope" enlisting the 250 knot limit. Ithas recently been clarified by the FAA that the cruise velocity should be used for the normal flight envelope when looking at the potential for bird strike. This clarification takes the radome from a worst case condition where the aircraft would fly with a nose up attitude, thereby shielding the radome from a bird strike, to a 0 degree alpha in which the radome and antenna would be exposed to the bird. This antenna and radome are scheduled to be completed by the end of May, 2013, and therefore may not have the changes required to satisfy the bird strike The proposed configurationwill therefore not comply with the requirement of 14 CFR 25.571(e)(l).

### C. The ExtentofReliefBeing Sough

Regulation Requirement Why reliefis necessary

DescriQtion ofreliefsought: P.A.S.S respectfully requests that the FAAgrant a 24 month exemptionfor the bird strike clarification to ensure P.A.S.S has time to continueto work toward compliance with the regulation. Thistime period also allows the aircraft to return to the United States for routine scheduled maintenance at which time any modifications needed will be accomplished.



### D. Description ofthe Issue

14CFR 25.571(e)(l) states "The airplane must be capable ofsuccessfully completing a flight during which likely structural damage occurs as a result of- (1) Impact with a 4-pound bird when the velocity ofthe airplane relative to the bird along the airplane's flight path is equal to Vc at sea level or0.85Vc at 8,000 feet, whichever is more critical" The original FAA issue paper template stated the following: "To meet this requirement, the applicant must show that a bird strike ofthe radome will not result in a catastrophic condition. However, this requirement need not be considered ifit can be demonstrated that a bird cannot strike the radome within the normal flight envelope." 14 CFR 91.117(a) states "no person may operate an aircraft below 10,000 feet MSL at an indicated airspeed ofmote than 250 knots (288 m.p.h.)." Therefore 250 knots was used to generate a "normal flight envelope" which resulted in a nose up attitude sufficient to ensure the bird could not strike the radome. Recently the FAA became aware ofthe industry interpretation and notified this applicant of the clarification on the issue paper that requires the "normal flight envelope" consider velocities up to Vc.

### D. Description ofthe Issue The revised issue paper template now states the following: "The applicant must show that the airplane is capable ofsuccessfully completing a flight following the impact with a 4-pound bird when the velocity ofthe airplane relative to the bird along the airplane's flight path is equal to Vc at sea level or .85Vc at 8,000 feet, whichever is more critical. However, this requirement need not be considered ifit can be demonstrated that a bird cannot strike the radome within the normal flight envelope up to the design speeds required by § 25.57l(e)(l). The applicant must consider all phases of climb-out, cruise, descent and approach, from sea level to 8000 ft, at the full range of certified design weights and CG limits. Section 91.117 is not applicable to the bird strike requirement of§ 25.571(e)(!), and may not be used as a means ofaltering the requirement of§ 25.571(e)(1)." At cruise velocity the aircraft will be flying at a zero degree angle of attack and therefore not shield the radome from a bird strike. P.A.S.S. is working diligently With Delta G Design to provide design changes to ensure the regulation is met The notification ofthis change to the issue paper was provided on March 4th , 2014, The current exemption ends on 7/2/2014. This may not allow time for the applicant to institute changes to the design that can be institutedprior to the expected certification date. Therefore P.A.S.S. respectfully requests the exemption be extended from 12 months to 24 months. 

### E. StatementofPublic Interest Timely completion ofthe STC ensured delivery ofa head ofstate aircraft to the nation ofKuwait and maintained harmonious relations, and have a positive impact on the trade balance with this nation thereby enhancing the social balance, the gross domestic product, and the economic health ofthe United States. Granting ofthis revisions to existing petitions/exemptions serves the public interest by ensuring continued sales within the United States for this nations aircraft as well as the modifications performed after the initial sale. This serves the public interestby serving economic interests ofthe United States in general, and welfare ofresidents, employment and improvedtax revenues.

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### F. Statement

### ofNoAdverse EffeCton Safety The current design wiH have no adverse effect on safety and is designed to the same standaras a& previously certified antennas. At the FAA regulated speed of250 knots, the antenna can notbe hit with a bird due to the noseup attitude ofthe aircraft and will poseno additional risk. The FAA has indicated that aircraft currently certified to the original is.sue paper, will not currently be subject to an Airworthiness Directive, which supports the applicant position that an no adverse effect on safety exists. ·


### G. 

### SummaryofPetition In response to a customerrequest, P.A.S.S requests a revision t9 theexisting exemptionof12monthsto 24 months from 14 CFR 25.57l(e)(i), Amendment 25-132, for the ability to complete a flight after a bird strlke under a "norlnal flight envelope" that includes Vc at sea level.
Itis not envisionedtaatthe aircraftwill fly beyond 250 knots below 10,000 feet and will therefore not have any increase in risk from. a bird strike.

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## H. RequestforReducedPublic,CommentPeriod

.· The aircraft has delivered under the existing exemption, and with no increased risk to ·; the public, P.A.S.S fbspectfully**req~ests** that the public comment period be waived. 

# \V ·,: 1. Privileges ofthls Exemptibn Outside the UnitedStates Per § 11.81(h), P.A.S.S. requests that the privileges ofthis Exemptionbe extendedoutside ofthe United States. This extension ofprivileges is necessary for operationsbased *ithin foreign countries having bilateral agreements with the United States accepting FAA 1 CFR Part 25 as their airworthiness standards for transport category aircraft. This aircraft is intended for the global marketplace.