GCF-1344/2012 – 2/4

14 CFR 11.81 (a) - Contact Information: 

Sérgio Augusto Viana de Carvalho 

EMBRAER Airworthiness Manager 

Av. Brigadeiro Faria Lima, 2170 – PC 179 

12227-901 São 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 25.813 Emergency exit access. 

(e) No door may be installed between any passenger seat that is 

occupiable for takeoff and landing and any passenger emergency 

exit, such that the door crosses any egress path (including aisles, 

crossaisles and passageways). 

14 CFR 11.81 (c) Extent of Relief and Reason for Seeking Relief 

Petition and General Information

EMBRAER is requesting an amendment to the Exemption N° 9458 to allow installation 

of electrical actuation of the doors between passenger compartments and the 

emergency exits in the ERJ 190-100 ECJ. This hybrid door system allows passengers 

on either side of the door to select the door open or close by pushing a button on a 

control panel. 

14 CFR 11.81 (d) Reason Why Granting Relief would be In Public Interest 

Public Interest:

The public interest established by the original petition that was granted by Exemption 

9458 is equally applicable to the hybrid door and adding a different mode of door 

actuation does not affect the public benefits provided by the capability to provide a more 

comfortable and useful interior by dividing the cabin into rooms that provide more 

privacy. 

14 CFR 11.81 (e) Reasons Why Exemption would Not Adversely Affect Safety 

Justification:

The actuation system is being designed to maintain the same level of safety as that 

afforded by the existing manual door and has the following safety features to ensure 
GCF-1344/2012 – 3/4

that the addition of electrical actuation does not adversely affect emergency egress 

capability or pose any risk of physical injury to the passenger or crew: 

1. The hybrid door is a typical mechanical door with the addition of an 

electrical actuator and a control box. The system will be equipped with 

2 PAX operation switches per door: one FWD and one on the AFT 

side. It is necessary one push to deploy the door and another push to 

stow it. Aside from the electrical components, the door behaves as a 

typical mechanical door, i.e., whether the electrical mechanism is 

operational (Powered) or not, it is possible to stow or deploy it 

manually. 

2. In case the door blade is blocked during deploying, its motion is 

stopped. Afterwards the door blade moves into the stowed position. 

And in case the door blade is blocked during stowing, its motion is 

stopped. Afterwards it is necessary to press the switch again in order 

to move the door blade into the stowed position. 

The other conditions required by the existing Exemption 9458 will still be met by the 

automatic door. 

These safety requirements will maintain the same level of safety as that provided by the 

original issue of Exemption 9458 for the manual door and will ensure emergency egress 

capability even in cases of system failure or failure to properly stow the door prior to 

taxi, takeoff, and landing. EMBRAER believes that the basic issues of a passenger 

finding and reaching an exit in the emergency are addressed by the above additional 

safety features and by the existing safety parameters inherent in the operation of private 

use airplanes. EMBRAER also believes that even if some extreme condition should 

result in a door being closed or partially closed after an accident, there are simple 

means to get through the door to reach the exit(s). For this reason, the amendment to 

the exemption, as requested, would provide a level of safety for passengers in the 

EMBRAER Model ERJ 190-100 ECJ that would be equal to that required for 

passengers of airplanes in commercial operation. 

14 CFR 11.81 (f) Summary For Publication In Federal Register 

EMBRAER requests an amendment to the granted Exemption N° 9458, from 14 CFR 

25.813(e) Amdt. 25-88 to allow the installation of an electrical actuation feature in the 

doors between passenger’s compartment and emergency exits in the EMBRAER Model 

ERJ 190-100 ECJ aircraft. Certain design features would be required to ensure that the 

door would not adversely affect safety. 

14 CFR 11.81 (g) Additional Information to Support Request 

Exemption No 9458 (Regulatory Docket No FAA-2007-27903) issued to EMBRAER on 

August 2, 2007. This exemption is provided as evidence that the FAA has previously 
GCF-1344/2012 – 4/4

granted exemption from the same regulation, with the same provisions, for the same 

type aircraft which is being requested by this petition for an amendment to the 

Exemption. In addition the contents of this petition are similar in the relevant aspects to 

that of Exemption 10188. 

Conclusions

EMBRAER believes that the combination of the interior design of this airplane, which is 

specifically for private use and the proposed occupant safety features, should justify the 

grant for an amendment for this Exemption No 9458. EMBRAER also notes that the 

proposed occupant safety features provide an acceptable level of safety for the 

intended use of this airplane.