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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 Exempt ion 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 passenge r emergency exit, such that the door crosses any egress path (i ncluding aisles, crossaisles and passageways).

14 CFR 11.81 (c) Extent of Relief and Reason for Se eking 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 passen ger compartments and the emergency exits in the ERJ 190-100 ECJ. This hybri d 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 b e In Public Interest

Public Interest:

The public interest established by the original pet ition that was granted by Exemption 9458 is equally applicable to the hybrid door and a dding a different mode of door actuation does not affect the public benefits provi ded by the capability to provide a more comfortable and useful interior by dividing the cab in into rooms that provide more privacy.

14 CFR 11.81 (e) Reasons Why Exemption would Not Ad versely 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 fo llowing safety features to ensureGCF

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that the addition of electrical actuation does not adversely affect emergency egress capability or pose any risk of physical injury to t he passenger or crew:

1. The hybrid door is a typical mechanical door wit h the addition of an electrical actuator and a control box. The system w ill 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 a nd another push to stow it. Aside from the electrical components, the door behaves as a typical mechanical door, i.e., whether the electric al mechanism is operational (Powered) or not, it is possible to sto w 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 s towed position. And in case the door blade is blocked during stowin g, its motion is stopped. Afterwards it is necessary to press the sw itch again in order to move the door blade into the stowed position.

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

automatic door.

These safety requirements will maintain the same le vel of safety as that provided by the original issue of Exemption 9458 for the manual doo r and will ensure emergency egress capability even in cases of system failure or failu re 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 a ddressed by the above additional safety features and by the existing safety paramete rs inherent in the operation of private use airplanes. EMBRAER also believes that even if s ome extreme condition should result in a door being closed or partially closed a fter 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 t o 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 Exempt ion 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 w ould 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-2007-27 903) issued to EMBRAER on August 2, 2007. This exemption is provided as evide nce that the FAA has previouslyGCF

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granted exemption from the same regulation, with th e same provisions, for the same type aircraft which is being requested by this peti tion for an amendment to the Exemption. In addition the contents of this petiti on are similar in the relevant aspects to that of Exemption 10188.

Conclusions

EMBRAER believes that the combination of the interi or design of this airplane, which is specifically for private use and the proposed occup ant 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 accept able level of safety for the intended use of this airplane.