9' 

ANAC 

Agencia Nacional de Aviagao Civil 

Of. 980/2010/GGCP/SAR-ANAC 

Sao Jose dos Campos, 28 Jul^ 2010 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

USA 

Subject: 

Enclosure: 1 - Petition for exemption - Embraer letter GCF-0818/2010 dated 26 July 2010. 

EMB-135BJ - MAJOR CHANGE DCA 0145-000-00020-2008/FAA -

PETITION FOR EXEMPTION AMENDMENT - 14 CFR § 25.901 (c). 

Dear Sir/Madam, 

1. ANAC received and endorsed a petition to amend an exemption, from Embraer, 

for 14 CFR § 25.901 (c). 

2. The original signed copy of the petition is enclosed. 

3. Mr. Fabiano Hemandes is the project officer assigned for this program. For 

additional information on this subject, he may be contacted directly by telephone at 

55 (12) 3797-2623, by fax at 55 (12) 3797-2330 or by email at fabiano.hemandes@anac.gov.br. 

Yours sincerely, 

FH/fh 

Copias: 

LSE 1 

Embraer (by e-mail) 

Ademir Antojiio da Silva 

GeneraTManager 

Aeronautical Product Certification Branch 

PROTOCOLO ANAC 

00800.103078/2010-40 

SuperintendSncia de Aeronavegabilidade - SAR 

GerSncia-Geral de Certifica9ao de Produto Aeroniutico - GGCP 

Avenida Cassiano Ricardo, 521 - Ed. Aquarius Center - Bloco B - 2^ andar - Parque Residencial Aquarius 

12246-870 - Sao Jos6 dos Campos - SP - Brasil - Tel.: 55 (12) 3797-2525 - Fax: 55 (12) 3797-2330 

www.anac.gov.br/certificacao 
July 26,2010. -< EMBRAER 

GCF-0818/2010-1/5 

JOB/job 

Embraer 

Empresa Brasileira 

de Aeron^utica S.A. 

Av. Brigadeiro Faria Lima, 2.170 

12227-901 - S.J. dos Campos - SP 

Brazil 

Phone: (5512)3309-0714 

Fax:(55 12)3927-1184 

PC:179 U.S. Department Transportation 

Docket Management System 

400 7th Street, SW, Room PL 401 

Washington, DC 20591-0001. 

USA 

Subject: EMB-135BJ- FAA Validation 

Embraer Petition to amend the exemption granted by document (FAA 

Exemption no. 7933), from the requirement of 14CFR 25.901(c), for the 

EMB 135 BJ (Legacy Enhanced) equipped with the AE3007A2 engines. 

Gentlemen: 

1 Please find enclosed Embraer's petition to amend the exemption granted by document 

i (FAA Exemption no. 7933), from the requirement of 14CFR 25.901 (c), for the EMB 135 

j BJ (Legacy Enhanced) equipped with the AE3007A2 engines. 

Best Regards, 

RiGiKioiBMeMlontaAndfft 

FOB. Sergio Augusto Viana de Carvalho 

Ainvorthlness Manager 

C.c: FAA - Mr.Sanjay Ralhan - Program Manager - EMB 135 BJ 

ANAC - Mr. Fabiano Hemandes - Program Manager - EMB-135 BJ 
GCF-0818/2010-2/5 - ^ EMBRAER 

Petition to amend the exemption granted by document (FAA Exemption no. 7933) 

Summary 

Petitioner: EMBRAER Empresa Brasileira de Aerondiutica S/A 

Sections of the Regulation Affected: 14 CFR § 25.901 (c) Amendments 25-1 through 25-

84, and additional requirements as per IP G-1 originated from the significant major 

modification presented in the DCA 0145-000-00020-2008 "EMB-135BJ Performance 

Enhancements". 

I Description of Relief Sought: Exemption of EMBRAER EMB 135 BJ Aircraft from the no 

I single failure requirements of 14CFR 25.901 (c) as it relates to uncontrollable high thrust 

^' failure conditions. 1 I 

i 

I I I f 
GCF-0818/2010-3/5 - ^ EMBRAER 

Embraer respectfully submits the enclosed Petition for an exemption for the EMB-135BJ 

model with the modifications presented in the DCA 0145-000-00020-2008/FAA, herein 

called EMB-135BJ Enhanced, from the no single failure requirements of 14CFR 

25.901 (c) as it relates to uncontrollable high thrust failure conditions. 

Embraer proposes to amend the FAA Exemption no. 7933 granted to EMB-135BJ 

equipped with engine AE3007A1E from requirement 14CFR 25.901(c) for the EMB135BJ Enhanced equipped with the AE3007A2 engine. 

TEXT OF REQUIREMENT FOR WHICH EXEMPTION IS SOUGHT 

14 CFR § 25.901(c) "Installation" 

(c) For each powerplant and auxiliary power unit installation, it must be established that 

no single failure or malfunction or probable combination of failures will jeopardize the 

safe operation of the airplane except that the failure of structural elements need not be 

considered If the probability of such failure is extremely remote. 

GROUNDS SUPPORTING EXEMPTION 

The EMB-145XR and EMB-135BJ, previous models of the Legacy Enhanced, have 

received partial exemption of compliance with the requirement since there were three 

scenarios, all of them on ground, not successfully demonstrated to be entirely in 

accordance with the requirement. FAA have granted exemption to these models 

through Exemptions No. 7908 (October 21, 2001, for EMB-145XR) and No. 7933 

(December 12, 2001 for EMB-135BJ). 

The EMB-135BJ Enhanced is equipped with Rolls-Royce AE3007A2 engines, a 

modification over the previous engine model, the AE3007A1E. This engine modification 

consists of a new fan module with fewer fan blades (22 instead of 24 on A1E) and new 

spinner among other components of fan module. Please see the figure below with the 

main differences from A1E and A2 engines. A1E parts are represented In green and A2 

ones in blue. 
GCF-0818/2010-4/5 - ^ EMBF^AE R 

All the rest of the engine is maintained the same as the A1E engine, including 

compressor, combustion chamber, turbines, exhaust, FPMU (Fuel Pump and Metering 

Unit) & FADEC hardware, FADEC software is being updated to receive A2 thrust tables 

among other modifications/improvements. 

The AE3007A2 engine Max TO (Take Off) thrust (9022 Ibf) has increased about 14%, 

comparing to the AE3007A1E (7974 Ibf) engine currently used on EMB135 BJ, but the 

maximum peak thrust during a MMV (Main Metering Valve) position failure (fully open) 

in the AE3007A2 is 10,501 Ibf, against the 10,150 Ibf. 

Aircraft handling qualities analysis for the Uncontrollable High Thrust (UHT) scenarios 

(MMV fully open), for the EMB135BJ with AE3007A2 engines showed that with the 

additional thrust increase (3.5%), the results are similar to the ones obtained with 

AE3007A1E engines. Small differences were found between the required flight control 

surfaces deflections for the EMB-135BJ (Legacy 600) and EMB-135BJ Enhanced 

(Legacy 650) (less than 1 degree) and the deflections are far from any detent. 
GCF-0818/2010-5/5 - ^ EMBRAER 

Therefore, all UHT analysis results from the EMB135BJ with AE3007A1E engines are 

applicable to the EMB135BJ with AE3007A2 engines. 

The UHT protection logic and corrections Implemented in the EMB145 family FADEC 

since first certification have shown positive results with almost 13 million flight hours 

accumulated with no safety issues since the last UHT event in 2003. AE3007A2 FADEC 

is inheriting all EMB145 family FADEC improvements and corrections implemented 

during its history. 

During a meeting held during May 2010 at FAA facilities in Seattle with FAA, Embraer 

and Rolls Royce it was discussed that the existing exemption should be amended and 

stay valid for a period of four years after FAA validation. During this period, Embraer 

and Rolls-Royce will develop and make available improved UHT logic which will 

shutdown engines upon detecting high N1 and with a TLA command at or less than idle. 

This improved UHT logic is the only known practical action (cost beneficial and 

technologically feasible) to address the scenarios exempted by the memo, in order to 

minimize the adverse effects on safety associated with granting exemption from 14CFR 

25.901 (c) for the EMB-135BJ Equipped with AE 3007A2 engines. 

Based on the above considerations Embraer respectfully proposes to amend the 

exemption granted by document (FAA Exemption no. 7933), from the requirement of 

14CFR 25.901(c), for the EMB 135 BJ (Legacy Enhanced) equipped with the 

AE3007A2 engines.