DE lEtlBRflER-CERTIFICATIDN OFFICE FAX : 551239271134 13 JUN. 201 0 11:2 6 PSg. 1 

^ EMBRAER Embra«r - Empresa Brasileira de AeronSutlca S.A, 

Av. Brigadelro Faria Lima, 2.170 

12227-901 - S.J, dos Campos - SP - Brazil 

FAC - SlMILE 

Ref.: GCF-0628/2010 Date: 11/jun/20lO Page.: 1/4 RMA/mia 3 

To: U.S. Department of Transportation 

Docket Operations, M-30 

West Building Ground Floor, Room W12-140, 

1200 New Jersey Avenue, SE 

Fax: (202)493-2251 Phone: - -

From: S6rgio Augusto Viana de Carvalho 

Airworthiness Manager 

Fax: 55 12 3927-1184 Phone: 55 12 3927-4422 

Subject: Embraer Position to FAA AD 2010-09-04 

Reference: Docket No. FAA-2010-0385 

Copies: ANAC - Oswaldo Oliveira 

FAA - Chip Adam 

FAA - Cindy Ashforth 

Dear Sir or Madam, 

Please find enclosed EMBRAER position to FAA AD 2010-09-04 

1- Acronyms and Abbreviations: 

AD - Airworthiness Directive; 

AFE - Airport Field Elevation; 

CAS - Crew Alerting System, 

FMS - Flight Management System; 

IFR - Instrument Flight Rules; 

IRS - Inertial Reference System; 

PF - Pilot Flying; 

PNF - Pilot Not Flying; 

RNP - Required Navigation Performance; 

SiL - Service Information Letter; 

SOPM - Standard Operating Procedures Manual; 

VFR - Visual Flight Rules. 

- • J 

c:5 

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Immediately by phone. Thank you. 
:Et1BRAER-CERTIFlCftTI0N OFFICE FftX -.551239271184 13 JUN. 2010 li:2 7 PSg. 2 

^ EMBRAER Einbraer - Empresa Brasileira de Aeroniutica S.A. 

Av Brlgaaeiro Faria Uma, 2.170 

12227-901 - S.J, dos Campos - SP - Brazil 

FAC - SiMILE 

Ref.. GCF-0628/2010 Date: 11/jun/20l0 Page.: 2/4 RMA/mna 3 

2- introduction 

On April 29'*" 2010 F/VA issued AD 2010-09-04 to address software anomalies found in the 

Honeywell Primus EPIC software affecting the Embraer models ERJ 170 and ERJ 190. FAA 

considered these anomalies as an unsafe condition since it would generate misleading 

navigational guidance to the pilots and could cause the aircraft to depart from the scheduled 

flight. 

3- Analysis: 

Embraer would like to comment on each anomaly mentioned in the AD: 

3.1. FHflS Position Shift When Crossing 180th Meridian (Honeywell SIL D201002000051). 

This issue is an FMS position anomaly/Large IRS bias that dccurs when crossing the 180 deg 

Meridian line while using IRS for navigation 

When this condition happens, the following effects v«li be noticed on the flight decic 

1. The course deviation indicator (CD)) will deflect indicating the offset from the desired 

lateral and vertical path, based on the changed position; 

2. If autopilot is coupled and lateral navigation (LNAV) is engaged, the airplane will execute 

a bank maneuver to intercept the TO waypoint in the flight plan; 

3. If map display is selected to heading up, map display will move to the new FMS position; 

4. If map display is selected to north up, the aircraft symbol will disappear from the map and 

move to the new FMS position; 

5. UNABLE RNP message will be displayed in the multifunction control display unit (MCDU) 

scratchpad; 

6. FMS position starts slewing back to the selected sensor positions; 

7. Caution CAS message "FMS1>GPS pos disagree" and, if FMS 2 is installed, "FMS2> 

GPS pos disagree", (not mentioned in the Honeywell SIL) 

Based on the definition of hazardous misleading guidance of AC 20-130A: "Navigation data is 

considered to be hazardously misleading when unannunciated position errors exist that are 

greater than those specified by the multi-sensor equipment or individual sensor requirements.". 

Embraer position is that the condition is clearly annunciated to the flight crew based on the 

effects described above and therefore should not be considered a hazardous misleading 

guidance. Furthermore, flight crew using norma) airmanship skills will easily detect the anomaly 

and can quickly recover the aircraft from this scenario. 

Due to the continental mission of the ERJ 170 and ERJ 190, no commercial operator is 

nowadays flying routes that cross the date line. Only the executive jet - Lineage - would possibly 

operate in such area and considering that the whole Lineage fleet which would be in service this 

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immediately by phone. Thank you. 
DE lEriBRPlER-CERTIFICPTION OFFICE FftX :5512392711S4 13 JUN. 2010 11:28 PSg. 3 

- ^ EMBRAER Embraer - Empresa BraslMra de Aeronaudca S.A. 

Av. Brigacteino Faria Lima, 2.170 

12227-901 - S.J. dos Campos - SP - Brazil 

FAC - SlMILE 

Ref.: GCF-0626/2010 Date: 11/iun/2010 ' iPage.: 3/4 RMA/rma 

year are of 8 aircraft and their likelihood of having routes that will cross the dateline, we conclude 

that the exposition to such occurence in the EMBRAER platfonn is fairly remote. 

Nevertheless, EMBRAER also released operational bulletin 170-006-09 "FMS position anomaly" 

informing our operators of such anomaly. 

3,2, Destination Runway Change With no Arrival or Approach in Flight Plan (Honeywell SIL 

D201002000052). 

This issue only occurs when: 

- The airplane is flying to a runway which neither has an arrival nor an approach procedure 

selected in the FMS ARRIVAL page and; 

- The selected runway is the last and active waypoint on the flight planning. 

It is not mentioned in the Honeywell SIL, but in the EMBRAER design any change to the flight 

plan generates a MOD FLIGHT PLAN page and this information is also displayed in the MAP 

using a doted line together with the current flight plan. This way the pilot can verify the change 

and assess its correctness. 

Therefore this issue only occurs after the flight crew acknowledged and activated the incon-ect 

flight plan generated by the FMS. 

Moreover, it is important to consider the conditions in which such problem could occur. 

Firstly, Embraer SOPM (Standard Operating Procedures Manual) 3-05-10 recommends that 

below 10000 ft AFE, MCDU changes should be made by the PNF and executed only after 

confirmation by the PF. If necessary, revert to basic Autopilot/FD modes to avoid heads down 

time during high workload flight phases. 

Secondly, if the crew is intending to perform an IFR approach using the FMS, the approach 

procedure must be loaded from the navigation database The fact that no approach procedure is 

loaded in the flight plan indicates that the crew was planning to perfonn a VFR approach, which 

should not be used with the FMS as described in the Embraer AFM: 

"- ILS, LOC, LOC-BC, LDA, SDF, GS, MLS, Visual, and Radar approaches using the FMS as the 

navigation source for guidance are prohibited." 

It is important to point out that this type of situation is uncommon. The reasoning behind this is 

that when a pilot is executing an approach to an airport without an approach procedure, he has 

necessarily to be in visual conditions. In this case, the pilot could use the FMS flight path as 

supplementary information to the airport, but they would have to be in visual contact with the 

airport in order to proceed. Being this true, the pilot would have to fly the airplane outside of 

LNAV in order to position the airplane on a visual traffic pattern for the landing runway. In order to 

The information contained In this fao-simile mesaege Is Irttended only for the personal tind confidential use of the designated recipients name 

above. This message may also be attomeyKiiient pttvlleged. if the reader of this measage Is not the intended racipienl or an agent or employee 

responsible far delivering it to the Intended recipient, you are hereby notified that you have received this document In error, and that any 

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DE :EMBRPER-CERTIFICPTI0N OFFICE FAX :551239271184 13 JUN. 2010 11:29 PSg.4 

f-

- ^ EMBRAER Embraer - Etnpresa Brasileira de Aeroniutica S.A. 

Av, Brigadeiro Faria Lima, 2.170 

12227-901 - S,J. dos Campos - SP - Brazil 

FAC - SIMILE 

Ref.: GCF-0628/2010 Date: 11/jun/2010 Page: 4/4 RMA/ima 

do this the pilot would have to either, manually fly the airplane, or control the autopilot using HDG 

select. In either case, changes to the FMS would not result in changes to the airplane's flight 

path. In addition to this, pilots would rarely change the runway in use in this condition, since there 

would be no real improvement in situational awareness in doing this. 

Embraer also released operational bulletin 170-001-10 "FMS Misbehavioor Upon RunWay 

Change When No An-ival or Approach Procedure is Selected" infomiing our operators of such 

anomaly, 

4- Conclusion; 

Due to unique design features(CAS message on the first item and MOD flight plan on the second 

Item) that exists in the EMBRAER aircraft, which greatly enhances the crew situational 

awareness, we request that our aircraft be removed from the FAA AD 2010-09-04. 

Best regards, 

/ iuan Carlo Mileib Ramirsi 

Certifleatlofl Office 

IS^rgio Augusto Viana de Carvalho 

AinAforthiness Manager 

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