Row44 

Exemption Extension Request 

B777-200 

Exemption No. 11071B 

Regulatory Docket FAA-2014-0402

1050 Oak Creek Drive 

Lombard, IL 60148 

Page 1 

February 17, 2017 

U.S. Department of Transportation 

Docket Operations 

West Building, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590-0001 

Re: Exemption No. 11071B - Regulatory Docket FAA-2014-0402: Petition of Row 44 for Time Limited 

Exemption from § 25.571(e)(1) of Title 14, Code of Federal Regulations (CFR). Row 44 Wireless 

Broadband System Antenna Provisions Installation in Boeing 777-200 Series Aircraft, ODA Project 

ODA-GED-P143: Extension from 12 to 36 months 

In accordance with 14 CFR Part 11, Row 44 hereby petitions for an extension to the referenced exemption 

from 14 CFR § 25.571(e)(1) (Amendment 25-132) as it relates to the above referenced certification project. 

For the reasons detailed below, Row 44 requests an immediate extension to this exemption from this rule 

and that it remain in effect for a period of an additional 6 months from the amended date of approval. This 

six-month extension from the FAA bird-strike damage tolerance requirement is required to ensure that Row 

44 has time to complete its development of a full compliance methodology with § 25.571(e)(1) that is 

acceptable to the FAA. 

The specific regulation, § 25.571(e)(1) is as follows: 

Section 25.571(e)(1) – Damage tolerance (discrete source) evaluation. The airplane must be 

capable of successfully completing a flight during which likely structural damage occurs as a result 

of –

(1) Impact with a 4-pound bird when the velocity of the airplane relative to the bird along the 

airplane’s flight path is equal to Vc at sea level or 0.85 Vc at 8,000 feet, whichever is more 

critical. 

This section defines required structural requirements for damage to the airframe from a bird strike. 

Safety and the Public Interest 

This petition for an extension to this exemption would not adversely affect safety because of two primary 

factors. First, there have never been any documented bird strikes for large fuselage mounted satellite 

antenna radomes installed on Part 25 Transport Category Aircraft. Secondly, in the normal operational flight 

envelope, the fuselage shadows the radome and a bird strike is not possible due to the positive angle of 

attack of the airplane. 

Row 44 currently has approximately 7500 satellite antenna radomes installed on Southwest’s 737 aircraft 

fleet. These aircraft are accumulating substantial flight hours per year with no reported bird strikes to the 

radome. Additionally, the following table below lists all the exemption extensions granted for § 25.571(e)(1) 

for calendar years 2014/2015. 

 
Row44 

Exemption Extension Request 

B777-200 

Exemption No. 11071B 

Regulatory Docket FAA-2014-0402

1050 Oak Creek Drive 

Lombard, IL 60148 

Page 2 

Exemption No. Applicant Aircraft type Regulatory Docket No. 

10814B Plane Antennas and Security Systems Boeing 737-900 FAA-2013-0433 

10817B Gogo, LLC Boeing 767 FAA-2013-0562 

10845A Standard Aero Airbus A330 FAA-2013-0563 

10847A Standard Aero Boeing 757 FAA-2013-0564 

10848A Gogo, LLC Boeing 767-400 FAA-2013-0567 

10850A DRB Aviation Consultants Boeing 777 FAA-2013-0660 

In each exemption case listed above, the applicant has presented data that indicates on satellite antenna 

radome installations, which are similar to the satellite radome installed by Row 44 in both size and 

installation location, there has never been a documented bird strike to the radome. This includes well over 

10 million flight hours with satellite antenna radomes installed on all types of Part 25 Transport Category 

Aircraft. 

In previous efforts to substantiate the Row 44 satellite antenna radome installation for bird strike, it was 

shown analytically that for normal flight operations below 10,000 feet, the fuselage shadows the radome 

and a bird strike was not possible. Per 14 CFR 91.117(a), aircraft are not to fly beyond 250 Knots at an 

altitude below 10,000 feet. This project had expected to use this “normal flight envelope” velocity when 

showing compliance to § 25.571(e)(1). It has been clarified by the FAA that the cruise velocity should be 

used for the flight envelope when investigating the potential for bird strike. This increased the speed used 

in the analysis from 250 Knots to Vc (Aprox.360 Knots). This clarification changes the attitude of the aircraft 

when investigating the radome for bird strike potential. Under the operational rule for max velocity below 

10,000 feet (§ 91.117(a)), the aircraft would fly in a “nose up” attitude thus shielding the satellite antenna 

radome from a bird strike. However, under the language of § 25.571(e)(1), the aircraft design speed at sea 

level is used. This changes the attitude of the aircraft to level thus exposing the satellite antenna radome to 

a potential bird strike. This project’s STC was approved on December 18, 2014 and the updated analysis 

and testing required to show compliance to § 25.571(e)(1) has not been completed. Since the grant of 

extension, Row 44 had initiated multiple Bird Strike Test activities including A320 aircraft (EASA Approved) 

and B767 aircraft (FAA Approved) and are accumulating a data base to validate our compliance 

methodology using a basis of similarity and analysis as all of our current installations use a common 

Radome and Antenna. We are currently in the final stages of completion of this validation for the B777 

aircraft installation, due to interpretation of the results generated, it is believed an additional data point/data 

set is required to complete the analysis package to ensure compliance, this extension will allow Row 44 to 

complete the required testing and documentation of these compliance criteria. 

The public interest is served in granting this exemption extension for the following reasons. There is keen 

interest, by the flying public, in having connectivity services while flying, particularly on long domestic and 

international flights. These services enable business travelers to remain engaged in their trade while flying, 

thus enhancing efficiency and productivity. The connectivity services are also of great benefit to the leisure 

traveler by providing valuable connectivity and entertainment options. 

Bird Strike Substantiation: 

Row 44 has been reviewing § 25.571(e)(1) compliance options with the Chicago Aircraft Certification Office 

(ACO) and the Transport Aircraft Directorate (TAD) for over a year. A coordination meeting held in early 

November 2013 resulted in a method of showing compliance to § 25.571(e)(1) that was tentatively agreed 

to by all parties present and is summarized below. 

Row 44 is developing an analytical model to predict the effects of bird strikes on our satellite antenna 

radome and antenna installation methodology. The model will be developed by creating a modeled (digital 

simulation) and performing an actual bird strike test on a satellite antenna radome and antenna installed on 
Row44 

Exemption Extension Request 

B777-200 

Exemption No. 11071B 

Regulatory Docket FAA-2014-0402

1050 Oak Creek Drive 

Lombard, IL 60148 

Page 3 

a rigid instrumented test fixture. After testing, the digital model response will be updated to incorporate the 

results obtained from the physical test. Next, the updated model will be validated by performing a bird strike 

analysis on a second (simulated) satellite antenna radome and antenna installation (different from the initial 

testing) and comparing this result with actual results of a second physical test of the actual structure with 

the satellite antenna radome and antenna mounted. Phase one of this testing (initial testing on a rigid test 

fixture) is complete with positive results. Phase two has also been completed with digital simulation and 

validation via physical testing of the actual aircraft structure with positive results and predictable simulation 

prediction. The intent is to now use these data sets to apply the bird strike results by similarity to other 

aircraft types showing the results of the initial tests are applicable to other aircraft model types by 

comparative analysis. The remaining task is demonstrating how the FAA witnessed test results for one 

aircraft type can be shown applicable to another aircraft type. 

Once the compliance methodology is validated, the simulation data along with the previous FAA witnessed 

test results can be used to show compliance to § 25.571(e)(1) on this and new FAA STC projects 

employing this particular satellite antenna radome and antenna installation methodology and allow the 

reuse of this methodology on new installations across multiple fleets with consistent acceptance criteria. 

International Operations: 

Per § 11.81(h), Row 44 requests that the privileges of this Exemption be extended outside of the United 

States. This extension of privileges is necessary for operations based within foreign countries having 

bilateral agreements with the United States accepting FAA 14 CFR Part 25 as their airworthiness standards 

for transport category aircraft. The Boeing 777-200 aircraft is intended for the global marketplace. 

The initial aircraft that has been modified has China registration and is currently the only aircraft operating 

under this exemption. The local airworthiness authorities are insistent that the United States airworthiness 

standards along with the CAAC airworthiness standards be followed for all modifications. This extension is 

requested to allow this aircraft to continue operation in its installed configuration. 

Commercial Impact: 

Row 44 will incur significant loss of revenue as a result of a not obtaining an extension of this exemption 

and will end our trial operations of the FAA approved Satellite System Installation on Boeing 777-200 series 

aircraft operated by China Airlines. 

Good Cause Exists to Issue the Extension to this Exemption without Notice and Comment: 

Row 44 requests that the FAA issue the exemption extension without publication for comment in the 

Federal Register. Section 11.87 lists four factors considered by the FAA in deciding whether or not to 

publish a summary of the petition and request comments. Row 44’s response to each condition is shown 

below in italics. 

(a) Whether granting the petition would set a precedent. 

According to the FAA’s Exemption database, at least five (5) exemption extensions have been 

granted to § 25.571(e)(1) in calendar year 2014/2015 which allowed aircraft to operate for a limited 

period of time pending the successful resolution of a compliance issue. 

(b) Whether the relief requested is identical to exemptions granted previously. 
Row44 

Exemption Extension Request 

B777-200 

Exemption No. 11071B 

Regulatory Docket FAA-2014-0402

1050 Oak Creek Drive 

Lombard, IL 60148 

Page 4 

The majority of the exemptions granted were for the same reason as stated in requesting this 

exemption. The applicant, Row 44 needs additional time to develop a specific comparative analysis 

coupled with current test data to demonstrate full compliance with the provisions of § 25.571(e)(1). 

(c) Whether our (FAA) delaying action on your (Row 44) petition would affect you (Row 44) 

adversely. 

The importance of the SATCOM Antenna radome installation to Row 44’s core business cannot be 

overstated. Due to the rapidly changing technology involved in this modification, coupled with the 

project’s advanced stage and the disruption to operator that have contracted for the Row 44 

system, any delay would adversely affect Row 44. 

(d) Whether you (Row 44) filed your petition in a timely manner. 

The petition is timely filed. Row 44 and our agent have had discussions on this subject with the 

New York ACO and Chicago ACO and are planning additional discussions with these certification 

offices. 

In light of the above considerations, Row 44 submits that good cause exists not to delay action on this 

request. 

Summary of Exemption Request: 

In accordance with 14 CFR § 11.81(f), Row 44 offers the following summary suitable for publication in the 

Federal Register in the event the FAA believes that good cause to waive publication has not been 

established. 

Row 44 petitions the FAA for an additional extension to this exemption from the discrete source damage 

tolerance (bird strike) requirements of 14 CFR § 25.571(e)(1) for an additional period of six months based 

on data that a bird strike encounter on a fuselage mounted satellite antenna radome is extremely remote, 

additionally the compliance methodology currently being developed will benefit the future compliance of this 

requirement in support of the evolving technologies being developed. 

Please feel free to contact me by phone or email if additional information is required. 

Respectively, 

Director, Aircraft Certification 

DL +1 (732) 710 6414 

Kreg.Doerr@geemedia.com

Row 44/GLOBAL EAGLE ENTERTAINMENT 

1050 Oak Creek Drive

Lombard 

IL 60148, USA

Respectively,

Director, Aircraft Certification