December 20 th , 2013.

GCF- 1 939/2013

– 1 /5 GNS/ra **EMBRAER S.A.**  Av. Brigadeiro Faria Lima, 2.170 12227-901 - S.J. dos Campos - SP Brasil Fone: (12) 3927 -0544 Fax: (12) 3927 - 1184 PC: 179 US Department of Transportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W1 2- 140 Washington, DC 20590 Subject: EMB-550 - FAA Type Validation

Petition to the Exemption from 14 CFR 25.1317(a) Amdt. 25- 127

Embraer respectfully su bmits the enclosed Petition for a time- limited exemption for the EMB-550 from the requirement of 14 CFR Part 25.1317(a) as it relates to Powerplant control systems. Best Regards,

Sérgio Augusto Viana de Carvalho Airworthiness Director c .c.: ANAC - GPC EMB-550GCF- 1 939/2013

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**14 CFR 11.81 (a) -**  **Contact Information**  **:** Sérgio Augusto Viana de Carvalho Embraer Airworthiness Director 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** § 25.1317 High-intensity Radiated Fields (HIRF) Protection. (a) Except as provided in paragraph (d) of this section, each electrical and electronic system that performs a function whose failure would prevent the continued safe flight and landing of the airplane must be designed and installed so that

— (1) The function is not adversely affected during and after the time the airplane is exposed to HIRF environment I, as described in appendi x L to this part; (2) The system automatically recovers normal operation of that function, in a timely manner, after the airplane is exposed to HIRF environment I, as described in appendix L to this part, unless the system's recovery conflicts with other operational or functional requirements of the system; and (3) The system is not adversely affected during and after the time the airplane is exposed to HIRF environment II, as described in appendix L to this part. **14 CFR 11.81 (c) Extent of Relief and Rea son for Seeking Relief**  The engine control system is Level A classified and thus, needs to have its function not adversely affected during and after the time the airplane is exposed to HIRF environments I and II, also it should automatic recover its normal operation in a timely manner after the airplane is exposed to HIRF environment I unless this conflicts with other operational or functional requirements of that system. In the case of the EMB-550, aircraft electrical and electronic systems which perform Level A functions were subjected to laboratory tests to verify that the systems and associated Level A functions are not adversely affected when the system is tested to the internal HIRF environment. Systems that perform Level A Control functions were also subjected to "on -aircraft" HIRF low level testing during the full aircraft HIRF test. The resulting internal HIRF environments for level A systems are determined by aircraft attenuation to the external HIRF environments I and II. The attenuation is zone-specific and is established by aircraft test. Motivation for exemptionGCF- 1 939/2013

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During the aircraft development EMBRAER has used its own past experience, Guidance Materials such as ARP 5583, DO 160 E, AC 20- 158 and the engine supplier experience to define the HIR F levels for which the Engine Control System would be required to be qualified. Based on this assessment it was defined that it should follow DO 160 E Cat Y, which presents the highest level for component qualification. This assumption was to be validated by the aircraft tests, showing that the Control System had been qualified to a higher level than the one obtained on the aircraft test results. However, despite EMBRAER and its supplier knowledge on this subject, during conducted and radiated susceptibility tests in the aircraft, some higher levels were identified. So, EMBRAER conducted some additional tests to identify possible solutions to improve the installation protection against HIRF effects. As a result of these tests and complementary analysis so me potential solutions were identified: 1. ECU (Engine Control Unit) re-qualification to the higher level obtained on the certification test; or 2. Inclusion of overbraid protection to all ECU harnesses; or 3. Inclusion of overbraid protection to ECU W1 a nd W2h arn esses and conduction of a partial re-qualification test of the FADEC system. Due to the current phase of the aircraft development and certification process, EMBRAER has evaluated the impacts of each one of these design changes and requalifications activities, as follow: a. ECU re-qualification to the higher level obtained on the certification test: 12 months after original engine Type Certification b. Inclusion of overbraid protection to all ECU harnesses: 24 months after original engine Type Certification c. Inclusion of overbraid protection to ECU W1 a nd W2h arnesses and conduction of a partial requalification test of the FADEC system: 12 months after original engine Type Certification Based on the engine FADEC system qualification and results obtained on the complementary tests, an interim configuration is being proposed herein in order to allow certification schedule adherence. **14 CFR 11.81 (d) Reason Why Granting Relief**  **would be**  **i n Public Interest**  **Public Interest:** The Embraer EMB-550 is designed to meet the business aviation market and Embraer respectfully submits this petition for exemption. Preventing this aircraft from competing in this market by denying this exemption, and thereby denying the required Type Certificate, would serve to eliminate competition in this aviation segment and would also drive up the costs to the operators in acquiring executive jets.GCF- 1 939/2013

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Wh ile the EMB-550 is not manufactured in the United States, a significant portion of the airplane, including the engines, mechanical systems, avio nics, and interiors are manufactured by American suppliers. Denial of this exemption request would result in the loss of revenue for the American suppliers and have an adverse impact on the American balance of trade, both of which are counter to the public interest. Finally, granting this exemption would not result in any reduction in the level of safety of the EMB-550/AS907-3- 1E engine in comparison to other engines used in current fleet of transport category aircraft, especially when compared to earlier engines that were certified to a less severe HIRF environment. Since these earlier engines have shown a high level of safety in HIRF immunity, and since, even with the grant of this exemption petition, the level of immunity of the EMB-550 will be higher still, it is respectfully submitted that the requested conditional exemption would not be counter to the public interest on safety grounds. In case of additional improvements are required, EMBRAER will issue a service bulletin recommending that all airplanes delivered during the effective dates of the time- limited exemption be retrofitted by December 31, 2018. The service bulletin will be available no later than December 31, 2016, such that all EMB-550 airplanes delivered under this exemption can order parts and install a compliant configuration. The relief sought is limited to EMB-550 airplanes delivered prior to incorporation of the compliant solution to production, which will be accomplished no later than December 31, 2016. **14 CFR 11.81 (e) Reasons Why E** **xemption w ould Not A** **dv ersely A**  **ffect Safety** As a condition for the granting of the requested time- limited exemption, Embraer will take the following actions to mitigate, as much as practicable, thrust control failures and to demonstrate that the risk of exempting such failures from the provisions of 14 CFR Part 25.901(c) is no greater than the risk from this failure that exists in the current air transport fleet of similar engine applications. EMBRAER will include an overbraid on the W1 a nd W2h arnesses, which allows the outboard ECU to be within the HIRF levels for which it has been qualified, and also assure considerable reduction of the HIRF levels for the inboard ECUs, being marginally out of the qualification levels in a very limited range of frequen cies, as demonstrated during aircraft certification tests. The architecture of the Engine Control system provides robustness for a safe engine operation with only one ECU channel working. If a specific condition of HIRF affects one ECU channel, the FADEC system is designed to detect faults and accommodate them using the redundant signals from the other channel, not affecting the system safe operation. Embraer offers the following justification in support of its Petition for exemption, substantiating how the proposed type design provides an acceptable level of safety andGCF- 1 939/2013

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wh y granting the exemption will be in the public interest, as required by 14 CFR Part 11.25. 1. The AS907 is a family of turbofan engines manufactured by Honeywell. The engine AS907-3- 1E, wh ich will be installed in the EMB-550 aircraft, is a derivative of the AS907- 1 - 1A engine, which was initially certified by FAA in 25/Jun/2002. a. The configuration of the EMBRAER installation is quite similar to other AS907 certified applications, which do not have overbraid on the ECU harnesses. b. The current certified AS907 applications have not experienced any event related to HIRF during more than 1,300.000 hours of engine operation. 2. During the exemption effectiveness period, dispatch with one channel ino perative will not be allowed. **14 CFR 11.81 (f) Summary for Publication i**  **n Federal Register** EMBRAER requests to the time- limited exemption from 14 CFR Part 25.1317(a) Amdt. 25- 127 to allow certification schedule adherence

. Certain design features would be required to ensure that the engine control system would not adversely affect safety. **14 CFR 11.81 (g) A dditional Information to Support Request**  Justification to Bypass Notice of Exemption Petition in the Federal Register Because this petition requests only a time- limited exemption, the granting of this petition would not set any legal precedent. A delay in the granting of this exemption would delay certification and adversely affect operators who have made business plans based on the previously planned entry into service date of June 2014. For these reasons, Embraer requests that the FAA not wait to publish a Federal Register summary and solicit comments prior to the granting of this exemption. **Operation Outside of the United States** In accordance with 14 CFR Part 11.81(h), Embraer requests that the privilege of exercising this exemption for operation outside of the United States be approved. EMB 550 are expected to be registered and operated in various countries throughout the world. 

### Conclusions: In summary, EMBRAER believes that a time- limited exemption to 14 CFR Part 25.1317(a) is the option which best serves the public interest and which provides an adequate level of safety which is not less than that of existin g transport category airplanes.