© Airbus SAS

, 2014 . All rights reserved. Confidential and proprietary document. This document and all information contained herein is the sole property of A irbus SAS

. No intellectual property rights are granted by the delivery of this document or the disclosure of its content. This document shall not be reproduced or disclosed to a third party without the express written co nsent of Airbus SAS

. This document and its con tent shall not be used for any purpose other than that for which it is supplied.

Airbus SAS Société par actions simplifiée au capital de 2.704.375 Euros
RCS Toulouse 383 474 814 Registered office: 1, rond

- point Maurice Bellonte
3170 0 Blagnac, France François DUCLOS

T +33562118541
F

E françois.duclos @airbus.com
Our Reference: G28M14025456
Your Reference:

8 Dec ember 2014 U.S. Department of Transportation Docket Operations, M

- 30 1200, New Jersey Avenue S.E.

Room W12

- 140, West Bldg, Ground Floor Washington , DC 20590

- 0001
USA

Petition for a time limited e xemption f ro m section 14 CFR 25.981(a)(3) Amendment 125 and from section 14 CFR 25.901(c) Amendment 126 for the A330

- 300 Fuel Center Tank activation change to Type Desi g n

Dear Madam / Sir,

Airbus is hereby petitioning for a time limited exemption from one provision of section 14 CFR 25.981(a)(3) Amendment 125

– Fuel Tank Ignition Prevention

– and of section 14 CFR 25.901(c) Amendment 126

– Installation

- for the A330

- 300 aircraft models which will be modified to activate their fuel center tank capability (refer to FAA project n°AT10200IB

- T). In order to ease the review of this exemption request, the petition has been formated as per the

gu idelines of § FAR 11.81.

(a) Name, mailing address and other contact information

François DUCLOS A330/A340 Chief Airworthiness Engineer
Airbus SAS
D2202
1 rond

- point Maurice Bellonte 31707 Blagnac Cedex
France

(b) The specific section or sections of 14 CFR from which exemption is sought

A time limited exemption is sought from the ‘no single failure in combination with probable (i.e. with a probability greater than extremely remote) latent failure condition ’ provision as
stated in sub

- paragraph (a)(3) of section 14 CFR 25.981

– Fuel tank ignition prevention

– at amendment 125 ( ‘ Demonstrating that an ignition source could not result from [...] each single
failure in combination with each latent failure condition not shown to be extremely remote ’ )© Airbus SAS

, 2014 . All rights reserved. Confidential and proprietary document. This document and all information contained herein is the sole property of Airbus SAS

. No intellectual property rights are granted by the delivery of this document or the disclosure of its content. This document shall not be reproduced or disclosed to a third party without the express written co nsent of Airbus SAS

. This document and its con tent shall not be used for any purpose other than that for which it is supplied.

From François DUCLOS Date 8 Dec ember 2014 Reference G28M14025456 Page 2 and interpreted by the FAA for section 14 CFR 25.901(c)

- Installation

– ( ‘ it must be esta blished that no [...] probable combination of failure will jeopardize the safe operation of the airplane ’)

.

(c) The extent of the sought relief and the reason for seeking this relief

Air bus is seeking a 1 2 months relief for incorporating in production on the concerned A330

- 300 aircraft models a fuel system design that is fully and directly compliant with section 14 CFR 25.981(a)(3 ) and 25.901(c) requirement s identified above. T he design c hanges ident ified as necessary for demonstrating full compliance following reviews with the FAA will i ndeed not be ready for incorporation on the first A/C delivered to the US launch customer

, Delta Airlines (first aircraft delivery currently targeted for end of May 2015) . These design changes include: Extensive airplane wiring installation changes in the aircraft fuselage with impact on the aircraft structure in order to segregate the center tank Fuel Quantity Indicating System (FQIS) wiring from other airplane wiring with a physical separation distance Addition of a second Ground Fault Interrupter (GFI) for each of the center tank fuel transfer pumps power supply The 12 months relief is requested from the date of first A330

- 300 delivery to Delta Airline s, i.e. based on current delivery planning up until end of May 2016. At the time of petitioning, it
is estimat ed that around five aircraft would be delivered to Delta Airlines during this exem ption period. There is no intention to retrofit these first five aircraft.

(d) The reasons why granting the request would be in the public interest; that is how it would benefit the public as a whole

D enial of this petition for exemption would im ply a delay of several months in the delivery of
the first A330

- 300 with fuel c enter tank activated to the US launch customer, Delta Airlines

. This would therefore deprive Delta and its flying customers from the benefits brought by these aircraft which will allow carrying more payload on longer missions

. Denial would also
have negative impacts on the numerous US suppliers of Airbus (as an example, UTAS, A330/A340 fuel system supplier) due to the delivery delays. For these reasons, granting the request would benefit the US public as a whole.

(e) The reasons why granting the exempti on would not adversely affect safety

The baseline design for the A330

- 300 fuel center tank is the well proven design of the A330

- 200 and A340

- 200/300 aircraft models (which has now accumulated more than 30 million of revenue flight hours ) with all SFAR 88 correct ive actions mandated by the FAA including the
fitment of a Ground Fault Interrupter (GFI) on the power supply of the two fuel transfer pumps. The same Flammability R eduction System (FRS) as designed for the A330

- 200 and
A340

- 200/300 will also be in corporated, limiting the center tank flammability exposure to le vels below 0.5%, i.e. well within the requirements of 14 CFR Appendix M25.1 at amendment
125.
In addition to this already safe baseline design that will be embodied on the first aircraft d eliv ered to Delta Airlines

, Airbus has voluntarily defined additional airplane wiring design i m-© Airbus SAS

, 2014 . All rights reserved. Confidential and proprietary document. This document and all information contained herein is the sole property of Airbus SAS

. No intellectual property rights are granted by the delivery of this document or the disclosure of its content. This document shall not be reproduced or disclosed to a third party without the express written co nsent of Airbus SAS

. This document and its con tent shall not be used for any purpose other than that for which it is supplied.

From François DUCLOS Date 8 Dec ember 2014 Reference G28M14025456 Page 3 provements in the frame of the activation of the A330

- 300 fuel center tank. Th e se improv ement s , listed below, will also be incorporated in the first aircraft delivered to Delta Airlines: Addition of clamps on electrical bundles in zone adjacent to the centre tank in o rder to minimize the risk of chafing in case of an attachment point failure Additional metallic overbraiding on the centre tank FQIS wiring in ord er to limit the level of induced currents in case of lightning strike Additional electrical and mechanical protection sleeve on the centre tank FQIS wiring in order to prevent the risk of induced current from short circuits due to the

co

- routing with other low energy non intrinsically safe (28VDC) airplane wiring
For the FQIS wiring installation, t hose additional changes will already raise the level of r obustness of the A330

- 300 modified areas against the risk of creating a fuel tank ignition over
and abov e the already currently flying safe baseline. C ompliance to the higher certification
standard of section 14 CFR 25.981(a)(3) Amendt 125 and to section 14 CFR 25.901(c)
Amendt 126 will be demonstrated except for the ‘no single failure in combination with pr ob able (i.e. with a probability greater than extremely r emote) latent failure condition provision
due to the following extremely improbable specific residual risk : a foreign object or undue contact with an adjacent structure damaging the FQIS wiring protec tion sleeve and causing a short circuit between FQIS wiring and low energy non

- intrinsically safe wiring outside the fuel
tank in combination with a latent in

- tank short circuit due to the presence of foreign object that would create an ignition source due to the filament heating phenomenon

, during a period

w h ere the fuel tank is flammable (i.e. thanks to the FRS less than 0.5% of the Flammability Exposure Evaluation Time)

. Based on these considerations, it can be determined that the design changes necessar y to reach full compliance will be embodied on a design configuration whic h is considered as

pr ov iding already an adequate level of safety

. Therefore, g ranting the exemption to allow
additional time to incorporate them and to deliver the first aircraft without later retrofit action will not adversely affect safety.

As far as the fuel transfer pumps GFI are concerned, the basic design incorporated on the
first A330

- 300 with fuel center tank activated has already been d emonstrated to be compliant
with section 14 CFR 25.981(a)(3) at amendment 102 and section 14 CFR 25.901(c) (refer to
ELOS memo TD0764IB

- T

- P

- 1). Section 14 CFR 25.981(a)(3 ) at amendment 125 is u nchanged compared to amendment 102 . However compliance has been found by the FAA using an alternate (ELOS) methodology and the FAA notified Airbus that direct compliance to
section 14 CFR 25.981(a)(3) at amendment 125 and section 14 CFR 25.901(c) would be required for the A330

- 300 fuel center tank activation project

. Additional design changes (a ddition of a second GFI on each transfer pump power supply) are necessary to achieve this direct compliance

. Those changes will be embodied on a design configuration which has
been already demonstrated as safe, based on In

- Serv ice experience

. Granting this exem ption to allow additional time to incorporate them and to deliver the first aircraft without later
retrofit action will therefore not adversely affect safety.

(f) A summary that the FAA can publish in the Federal Register

Airbus seeks a time lim i ted exemption from section 14 CFR 25.981(a)(3) at amendment 125 and from section 14 CFR 25.901(c) at amendment 126

, for the activation of the A330

- 300 fuel center tank capability (FAA project n° AT10200IB

- T )

.© Airbus SAS

, 2014 . All rights reserved. Confidential and proprietary document. This document and all information contained herein is the sole property of Airbus SAS

. No intellectual property rights are granted by the delivery of this document or the disclosure of its content. This document shall not be reproduced or disclosed to a third party without the express written co nsent of Airbus SAS

. This document and its con tent shall not be used for any purpose other than that for which it is supplied.

From François DUCLOS Date 8 Dec ember 2014 Reference G28M14025456 Page 4 More precisely, Airbus seeks an exemption of 1 2 months (from first aircraft delivery date cu rrently targeted in May 2015 ) to incorporate in production the FQI wiring installation and fuel transfer pumps GFI design changes necessary to reach full and direct compliance to section 14 CFR 25.981(a)(3) and 14 CFR 25.901(c) ( ‘ no single failure in combination with probable (i.e. with a probability greater than extremely remote) latent failure condition ’ provision ).
T his request is in the public interest since it w ill enable to deliver the first concerned aircraft to the US launch customer on schedule thus benefiting the US public as a whole (Airbus US suppliers, US launch customer, Delta Airlines

, and its flying customers).
G ranting this request will no t adversely affect safety since the first few aircraft that will be
delivered during the exemption period will incorporate a center tank Flammability Reduction System (FRS) that has been demonstrated to be compliant to section 14 CFR 25.981(b) at
amendment 125 as wel l as additional airplane wiring ignition prevention improvements over an already safe design (as demonstrated by the satisfactory A330/A340 in

- service exper ience). This initial design (available at first A330

- 300 with fuel center tank aircraft delivery) is already very close to fully meet the latest certification standard, section 14 CFR 25.981(a)(3)
at amend ment 125 and FAA interpretation of section 14 CFR 25.901(c) at amendment 126

. The exemp tion will grant more time to incorporate additional changes de termined with the FAA as necessary to reach full and direct compliance

. At the time of petitioning, Airbus est imate that around five aircraft would be delivered to Delta Airlines during the exemption per iod. There is no intention to retrofit these aircraft which is acceptable f r o m a safety standpoint
for the reasons described above.

(g) Any additional information, views or arguments available to support the exemption request

Airbus request the FAA to waive the ‘publication and comment’ step in the exemption p r ocess. Indeed, Airbus consider that this petition is similar in intention and safety implications to time limited exemptions previously granted by the FAA to other applicants for section 14 CFR 25.981(a)(3) at amendment 125 and section 14 CFR 25.901(c) at amendment 126

. A quick treatment of this petition is necessary to enable timely certification of the A330

- 300 fuel ce nter tank activation project by the FAA as currently scheduled for April 2015.

(h) The reason to exercise the privileges of the request ed exemption outside the United
States if needed

Not needed, since this petition concerns a part 25 certification requirement and not an oper ational requirement

Yours faithfully,

François DUCLOS PE ARNAUD A330/A340 Chief Airworthiness Engineer Certification Manager Propulsion