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AN EADS COMPANY AIRBUS S.A.S

SOCIÉTÉ PAR ACTIONS SIMPLIFIÉE 

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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 Transportation 

Docket Operation

Washington DC 20590-0001

Att: FAA T. Backmann

Cc: 

European Aviation Safety Agency

Postfach 10 12 53

D- 50452 KÖLN

Germany

Att: PCM A350 H. Honert

SUBJECT: A350 – 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 §25.809(a) at Amdt.116 

for outside viewing from the flight deck emergency exit. This requirement is applicable to A350 

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

129. 

Since amendment 116, Section 25.809(a) requires each emergency exit to have means to view the 

outside conditions prior to open the exit. This viewing means may be on or adjacent to the exit provided no obstructions exist between the exit and the viewing means. This means must also be provided to permit viewing of the likely areas of evacuee ground contact during all lighting conditions 

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

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

conditions at the flight deck emergency exit. Furthermore, while the outside viewing capability provided by the flight deck windows on the A350 is sufficient for an evaluation of the outside conditions, the flight deck geometry results in a viewing area from the flight deck 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 requests that the FAA grant a partial exemption for this part of the rule on 

A350.
1. Sections of the Federal Aviation Regulation (FAR) that are affected:

Partial exemption for the flight crew emergency exit from 14 CFR Part 25 §25.809 (a) at Amendment 116 which states: 

“Each emergency 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 addition, each emergency exit must have means to permit viewing of the conditions outside the exit 

when the exit is closed. The viewing means may be on or adjacent to the exit provided no obstructions exist between the exit and the viewing means. Means must also be provided to permit viewing of the likely areas of evacuee ground contact. The likely areas of evacuee ground contact must 

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

of landing gear collapse”. 

2. Identification of issue:

With Amendment 25-116, the FAA introduced requirements 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 passenger 

cabin emergency exits, an overhead escape hatch is provided in the flight deck. Although used as 

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

the flight deck. In that respect, the flight deck overhead hatch is considered as a flight deck emergency 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 permit 

viewing. But, the large flight deck windows are providing 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 conditions when it 

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

flight deck windows. 

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 area of evacuee ground contact be viewable during all 

lighting conditions with the landing gear extended as well as in all conditions of landing gear collapse. On A350, the curvature of the fuselage in the vicinity of the flight deck do not allow direct 

viewing 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 possibility 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 because the design of the 

A350 does not literally 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 to 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 passenger cabin 

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 assessing the outside conditions.

-Even though the ground contact area where the evacuees would normally be expected to make 

their initial ground contact is not visible from the flight deck windows, the hazard directly above the 

airplane could be detected.

- In night conditions, the flight crew members will have the possibility 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 the requirements of 14CFR 25 Part 25.809(a). These lights will also help the 

flight deck members to assess the outside conditions through the flight deck windows, in addition 

to the flashlight. 

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

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

provided in the A350 flight deck, flight deck emergency exit are all consistent with the intent of the 

rule.

5. Public interest 

Airbus presents the argument that the granting of this exemption will be in the public interest by 

proposing an adequate level of safety for the A350. Not granting this exemption would lead Airbus 

to launch extensive design changes and manufacturing efforts to install a dedicated outside viewing means and an external lighting system without improving materially the level of safety for the 

flight crew. Then, the design complexity plus weight penalties and maintenance costs involved in 

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

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

as to reduced fuel consumption and emissions.

6. Request for waiver of publication
The A350 is intended to enter into service in September 2014.Similar exemptions have already 

been granted by other manufacturers on similar designs, and Airbus requests FAA that the public 

comment period be kept as short as permissible.

Best Regards,

Jean-François Petit J-C Nanche

Cabin Safety Certification Manager Chief Airworthiness Engineer A350

Note: 

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