March 24 En , 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 OfficeGCF-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 InterestGCF-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.

ConclusionsGCF-0333/2015 - 4/4 

# -< EIVIBRAER

Based on the above justifications and public interest, Embraer proposes the granting ofexemption from the requirement 14 CFR 25.791 (a) Amdt. 25-116 for the Model EMB550 and similarly derivatives models to operate charter and private.