February 17, 2017. GCF- 0346/2017-1/3 CAS/cas

U.S. DepartmentofTransportation, Docket Operations, West Building Ground Floor, Room W12-140, 1200 NewJerseyAvenue, SE., Washington, DC 20590 

## -(EMBRAER
EmbraerS.A. Av. Brigadeiro Faria Uma,2.170 12227·901 o S.J. dosCampos o SP Brasil Fone: (12) 3927·5043 Fax: (12) 3927°1184 PC: 179

Subject: EMB-550-Additional Extension Requestfor Exemption Petition to the Extension Request for Exemption from 14 CFR 25.562 (b) amendment 64, 25.785(b) amend 88 and Special Condition N° 25-495-SC number2. (e)



## .. Ref: Ong1nal Exemption no 1 0974 Ref: Previous extension ofexemption n°10974A Ref: Previous extension ofexemption n°109748
Dear Siror Madam: EMBRAER respectfully requests an Additional Extension for Exemption from 14 CFR 25.562(a) amendment 25-64, 14 CFR 25.785(b) amendment 25-88 and FAA Special Condition 25-495-SC number2. (e), in orderto allow the certification of the installation lateral single and multiple sidefacing seats in the EMB-550. This installation is associated with a Design Change Application (DCA) 0550-025- 00006-2015 Anti legflail device installation. Fordetails, pleasefind attachedthe EMBRAER request.
Sincerely,



# tJk**r'~** 

# A/1 \**~~i~ardo** Lavall

## ffo~ch Airworthiness Director 

## ICC: 

## IANAC- Willian Tanji 

### Ne.son Freire**M.,;;c~do** Airworthiness Offic-=GCF
- 0346/2017
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## ~EMBRAER

Request for Extension for Exemption No.10974

..Docket Number FAA-2013-0810
Background: By letters dated September6, 2013, and November22, 2013 EMBRAER petitioned the Federal Aviation Administration (FAA) for an exemption from the requirements of 25.562(a) and 25.785 (b) of Title 14, Code of Federal Regulations (14 CFR) and from FAA Special Condition 25-495-SC number2(e). The exemption No. 10974 was granted on April 04, 2014, that permits partial relief for the lower-leg flail requirement forthe forward-most seat position on all side-facing seats on EMBRAER Model EMB-550 airplanes, serial number 1tothrough 55. The exemption No. 10974Awas granted on May4,2016and extended the time limit of exemption no. 1 0974 until December 31, 2016 for all side-facing seats for Embraer Model EMB-545 and EMB-550 airplanes. The exemption No. 109748was granted on Dec**15~** 2016 and extended thetime limitof exemption no. 10974A until December 31, 2017 f·Or all side-facing seats for Embraer Model EMB-545 and EMB-550 airplanes.

EMBRAER ANALYSISAND ARGUMENTATION On Dec 15, 2016, the Federal Aviation Administration informed Embraer that have again extended the time limit of Exemption N°10974. FAA has recognized that the complexity of the remaining issues to be resolved for the Embraer side-facing seats (mainly related with submarining event and rapid egress with the deployed leg-flail airbag), to meet Special Conditions No 25-495-SC, •::ombined with the public interest are motivationto warrant an extension ofcurrent exemption. Since the grant of that latest extension, furtherr discussions with the FAA on the certification analysis and testing campaign schedule necessary to address all the outstanding technical aspects for this novel**desi~Jn** has demonstrated that one-year exemption is not sufficient. Among the tasks that must be performed, the egress evaluation is the critical path to demonstratethat rapid egress is notjeopardized bya deployed leg-flail device. There is no established method of compliance forthis partic:Jiar issueyet, since FAA is currently preparing to conduct research to evaluate this issue in the passenger cabin. As FAA stated, their goal is to complete this research byt March 31, 2017. Besides that, the research data will be reviewed to prepare a stage: 2 FAA position for an issue paper. Only after this Issue Paper issuance, Embraar will learn which airworthinessGCF- 0346/2017-3/3 

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requirements are applicable to this subject. As detailed in the letter GCF
- 0133/2017 sentto FAA by Embraeron January20, 2017 wherethis critical path and all subsequent activities are presented, the limit of exemption to December 31, 2017 is not feasible to completethis certification campaign. Concerning with remaining certification activities that are still outstanding, Embraer is requesting FAAto extend time limit of Exemption N°10974to December31, 2018. EMBRAER has demonstrated its commitment to complete the certification of this system, and to dothat we are working closely with FAA to definethe Certification Basis andvalidatethe Certification Plan as soon as possible. The side facing seat of the EMB-550 is one of the few that have been certified to the new dynamic standard, so even without complying with the new leg flail requirement it represents a significant increase in level of safety compared with earlier certified sidefacing seats that are still being produced. In addition, any delay in aircraft delivery to meet the terms ofthe original exemption and it extension will impose an adverse effect on our customers' ability to fully utilize the product they purchased and will have an adverse economic effect on their operations. The extension of the previously granted exemption to cover aircrafts until January 2019 continues to be in the public interest because the level of safety provided is still greaterthan that of ourconfigurations being offered. EMBRAER appreciates FAA's consideration of this extension request. If there is any further information required, please contact us.