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**AN EADS COMPANY** AIRBUS S.A.S

SOCI É T É PAR ACTIONS SIMPLIFI É E

AU CAPITAL DE 2.704. 375 EUROS

383 474 814 R.C.S. TOULOUSE SIÈGE SOCIAL :

1, ROND

- POINT MAURICE BELLONTE

31707 BLAGNAC CEDEX, FRANCE

PHONE +33 (0)5 61 93 33 33 FROM J

- François Petit / Marie

- Laure Moulard

DATE 29.Oct .2013

PHONE 0033561933838/0033567191732

FAX 0033561933155

E

-

MAIL marie

- laure.moulard@airbus.com

Jean

- francois.petit@airbus.com

OUR REFERENCE V25M13025866

YOUR REFERENCE N/A U.S. Department of Tran s portation

Docket Operation

Washington DC 20590

- 0001

Att: FAA T. Backmann

Cc:

European Aviation Safety Agency

Postfach 10 12 53

D

- 50452 KÖ LN

Germany

Att: PCM A350 H. Honert

SUBJECT: A3 50

– Petition for exemption from 25. 809(a ) for the flight deck emergency exit

Dear Sirs,

By present letter, Airbus petitions for an exemption from 14CFR Part 25 §25.8 09 ( a ) at Amdt.116

for outside viewi ng from the flight deck emergency exit. This requirement is appl i cable t o A350

through its certification basis which includes the requirements of 14CFR Part 25 up to Amendment

12 9

. S ince amendment 116, S ection 25.809(a) requires each emergency exit to hav e means to view the

outside conditions prior to open the exit. Th is viewing means may be on or adjacent to the exit pr ovided no obstructions exist between the exit and the viewing means. This m eans must also be pr ovided to permit viewing of the likely area s of evacuee ground contact d u r ing all lighting conditions

with the landing gear extended as well as in all conditions of landing gear c ollapse.

The A350 design does not have a dedicated means on or adjacent to the exit to view the outside

conditions at th e flight deck emergency exit. Furthermore, while the outside viewing capability pr ovided by the flight deck windows on the A350 is sufficient for an evaluation of the outside cond itions, the flight deck geometry results in a viewing area from the flight de ck windows which does

not permit the viewing of the likely area of evacuee ground contact in all conditions of landing gear

collapse . In that respect, the design does not meet the literal language of the rule.

Airbus respectfully reques ts that the FAA gra nt a partial exemption for this part of the rule on

A350

.1. Sections of the Federal Aviation Regulation (FAR) that are affected:

Partial e xemption for the flight crew emergency exit from 14 CFR Part 25 § 25.8 09 ( a) at Amen dment 1 16 which states :

“ Each emerg ency exit, including each flight crew emergency exit, must be a moveable door or

hatch in the external walls of the fuselage, allowing an unobstructed opening to the outside. In a ddition, each emergency exit must have means to permit viewing of the cond i ti ons outside the exit

when the exit is closed. The viewing means may be on or adjacent to the exit provided no obstru ctions exist between the exit and the viewing means. Means must also be provided to permit vie wing of the likely areas of eva c uee ground con tact. The likely areas of evacuee ground contact must

be viewable during all lighting conditions with the landing gear extended as well as in all co n ditions

of landing gear collapse ”

.

2. Identification of issue :

With Amendment 25

- 116, the FAA introduced r equirements to provide outside viewing means at

each emergency exit. 14 CFR 25.809(a) includes the requirement that an outside viewing means at emergency exits permit viewing of the likely area of evacuee ground contact and that the likely

area of evacuee contact be viewable during all lighting conditions with the landing gear extended

as well as in all conditions of landing gear collapse.

While the primary evacuation route for the flight crew on A350 is typically through the pa s sen ger cabin emergency exit s, an overhead escape hatch is provided in the flight deck

. Although used as

a secondary evacuation path, the overhead hatch provides a mean s for the flight crew to evacuate

the flight deck. In that respect

, the flight deck overhead hatch is considered as a flight deck eme rgency exit and needs to comply with the outside viewing requirements of 14CFRPart25

§25.809(a).

On A350, the basic design of the hatch does not have a mean on or adjacent to the exit to per mit

viewing

. But, t he large flight deck windows are provid ing an effective means to the flight crew

members to assess outside conditions when deciding whether or not they can open the hatch. So,

even though the flight deck overhead hatch does not allow a view of the outside condition s when it

is closed, the detection of a hazard directly above the A350 will be done by looking through the

flight deck wi n dows.

The rule also requires the viewing means at emergency exits to permit viewing of the likely area of

evacuee ground contact and that the likely are a of evacuee ground contact be viewable during all

lighting conditions with the landing gear extended as well as in all conditions of landing gear co llapse . On A350, the curvature of the fuselage in the vicinity of the flight deck do n o t allow direct

viewi ng of the ground through the window where the evacuees would normally be expected to

make their initial ground contact . It is very unlikely that a hazard will not be detected while viewing

out the flight deck windows and in darkness conditions, the flight crew members will have the po ssibility to use the flashlight to assess the general outside area when no external light sources (e.g.,

runway and/or airport lighting) is available

. Partial relief from § 25.809(a) at Amendment 25

- 116 is then necessary becau se the design of the

A350 does not li t erally comply with the rule as it is written

.3. Requested regulatory relief:

The main objective of this request for exemption is to permit relief from the requirement that flight

deck emergency exits have a means t o view outside conditions under all lighting situation for the

A350

.

4. Supporting Argumentations:

The primary evacuation route for the flight crew on A350 is typically through the passen ger ca b in

emergency exits. If the overhead escape hatch is used to evacuate the flight deck, the flight crew

members will be able to assess the outside conditions:

- The large flight deck windows installed on A350 flight deck provide an accurate means for a ssessing the outside conditions

.

- Even though the ground contact a rea where the evacuees would normally be e x pected to make

their initial ground contact is not visible from the flight deck windows

, the hazard directly above the

ai r plane could be detected.

- In night conditions, the flight crew members will have the possi bility to use the flashlight that is

installed on the flight deck to ascertain the outside conditions through the flight deck window.

In night conditions, other emergency exits on A350 are equipped with a dedicated external lighting

system in line with th e requirements of 14CFR 25 Part 25.809(a). These lights will also help the

flight deck members to assess the ou t side conditions through the flight deck windows, in addition

to the flashlight.

Based on these arguments, Airbus consider that the grant of th at partial exemption will not affect

the level of safety compare to aircraft that would have a dedicated flight deck emergency exit vie wing means compliant to 14CFR 25 Part 25.809(a) as it is literally written. The design standards

pr o vided in the A350 fli ght deck, flight deck emergency exit are all consistent with the intent of the

rule.

5. Public interest

Airbus present s the argument that the granting of this exemption will be in the public inte r est by

proposing an adequate level of safety for the A350. Not granting this exemption w ou l d lead Airbus

to launch extensive design changes and manufacturing efforts to install a dedicated outside vie wing means and an external lighting system without impro v ing materially the level of safety for the

flight crew. T hen, t he design complexity plus weight penalties and maintenance costs involved in

by these changes represent a real burden for operators and additional fuel consumption . T he grant

of this exemption is in the public interest as it will contribute to operat or’s competitiveness as well

as to reduce d fuel consumption and emi s sions

.

6. Request for waiver of publicationThe A350 is intended to enter in to service in September 2014 .S imilar exemptions have a l ready

been granted by other manufacturers on similar d esign s , and Airbus requests FAA that the public

comment period be kept as short as permiss i ble.

Best Regards,

Jean

- François Petit J

- C Nanche

Cabin Safety Certification Manager Chief Airworthiness Eng i neer A 350

N ote:

Similar exemption has already been granted on B787 . See Boeing Exemption No. 10114