March 24En , 2015 

GCF-0333/2015 - 1/4 

BAP 

-E EMBRAER 

Eimbracr S.A. 

Av. Brigade ro Faria L i ma, 2.170 

12227-9U1 - S.J. dos Campos - SP 

Brasil 

Fone: (12) 3927-2563 

Fax: (12) 3927-1184 

PC: 179 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W 12-140 

Washington, DC 20590 

Subject: EMB 550/545 - FAA Validation 

Request of amendment on Exemption 10557 - Docket No. FAA-2011-1240 - 

Requirement 14 CFR 25.791(a). 

Dear Sir: 

Please, find enclosed request of amendment on Exemption 10557 - Docket No. FAA2011-1240 - to permit type certification of similarly non-compliant derivatives of the 

current Embraer Model EMB-550 airplane. 

The original petition was sent on November 3` d , 2011 and it was granted on June 11 tn 

2012. The complete petition is available at the Department of Transportation's Federal 

Docket Management System, in Docket No. FAA-2011-1240. 

Embraer has analyzed Exemption 10557 and this was also considered applicable to 

similarly non-compliant derivatives of the current Embraer Model EMB-550 airplane 

(including, but not limited to EMB-545) once the same interior design, all the arguments 

and compensating factors are considered the same. 

Sincerely, 

r Ricardo Lavall Hollerbach ~ 

Airworthi~iess Direc#or 

izafael uustavo fassina ti,aiqu ~ 

Airworthiness Office 
GCF-0333/2015 - 2/4 -< EMBRAER 

14 CFR 11.81 (a) - Contact information: 

Ricardo Lavall Hollerbach 

Embraer Airworthiness Director 

Av. Brigadeiro Faria Lima, 2170 — PC 179 

12227-901 Sao Jose dos Campos, SP - Brazil 

Phone : 55-12-3927-3543 

Fax: 55-12-3927-1184 

14 CFR 11.81 (b) Specific section from which exemption is required 

14 CFR 25.791 (a) Passenger information signs and placards. 

(a) If smoking is to be prohibited, there must be at least one 

placard so statfng that is legible to each person seated in the 

cabin. !f smoking is to be allowed, and !f the crew compartment is 

separated from the passenger compartment, there must be at 

least one sign notifying when smoking is prohibited. Signs whfch 

notify when smoking is prohibited must be operable by a member 

of the flight crew and, when illuminated, must be legible under all 

probable conditions of cabin illumination to each person seated in 

the cabin. 

14 CFR 11.81 (c) Extent of relief and reason for seeking relief 

Petition and General Information 

SFAR 109 considers acceptable the concept of a single "NO SMOKING" placard visible 

to all occupants upon entry. Although SFAR 109 is not applicable to Model EMB-550 

and similarly derivatives models, Embraer understands that a single "NO SMOKING" 

pictorial placard is acceptable for the private or charter operations intended for that 

aircraft. This petition is applicable only to no smoking interior configurations, given that 

smoking configurations will have illuminated signs according to 14 CFR 25.791 (a). 

Embraer proposes the conspicuous installation of a single "NO SMOKING" pictorial 

placard inside the passenger compartment, approximately at the eye level of all persons 

entering the cabin, in the immediate vicinity of the Type II passenger entry single door. 

14 CFR 11.81 (d) Reason why granting relief would be in public interest 

Public Interest 
GCF-0333/2015 - 3/4 

-< EMBRAr=R 

As above mentioned, passenger of private or taxi operations have different demands for 

passenger amenities. Frequently these demands involve aesthetics aspects. The 

inclusion of design characteristics that pleases visual sense is always an issue and 

frequently set as a market requirement for manufacturers. In this manner, the 

elimination of a no smoking placard from all the positions that guarantee they will be 

seen by an occupant while seated represents a gain in terms of design for the public of 

such operation. 

Furthermore, the addition of one single placard is less costly because the installation 

local is not configurable. Thus the same installation satisfies every existent interior 

layout configuration. Providing one readable placard for each seated occupant, on the 

other hand, requires one placard installation configuration for each floor plan and 

consequently, one set of drawings (and associated processes to guarantee installation 

into the aircraft) for each layout, resulting in a higher final cost. 

14 CFR 11.81 (e) Reasons why exemption would not adversely affect safety 

Justification: 

The Model EMB-550 and similarly derivatives models will be certified for private and air 

taxi operation as scope of operation of the SFAR 109 and this profile of operation has 

several differences from commercial/carrier operations. 

Passenger of private or taxi operations have different demands for passenger amenities 

and frequently presents familiarity with cabin environment and interior features. 

The Model EMB-550 and similarly derivatives models will have a limited passenger 

capacity (11 at maximum occupancy for Model EMB-550 and 9 at maximum occupancy 

for Model EMB-545) what makes a single placard sufficient to notify passengers of the 

smoking restriction. In addition, the prohibition is reinforced due to absence of ashtrays 

and during preflight briefing conducted by flight crewmembers. 

14 CFR 11.81 (f) Summary for publication in federal register 

Embraer requests an Exemption from 14 CFR 25.791(a) Amdt. 25-72 to allow the 

certification of the installation of one placard stating that is legible to each person seated 

in the cabin on the Model EMB-550 and similarly derivatives models certificate no 

smoking interior configurations. 

14 CFR 11.81 (g) Additional information to support request 

Embraer does not have any additional information to support the Exemption Request. 

Conclusions 
GCF-0333/2015 - 4/4 -< EIVIBRAER 

Based on the above justifications and public interest, Embraer proposes the granting of 

exemption from the requirement 14 CFR 25.791 (a) Amdt. 25-116 for the Model EMB550 and similarly derivatives models to operate charter and private.