September 12 , 2013

SUBMITTED ELECTRONICALLY TO: Federal Docket Management System, www.regulations.gov

U.S. Department of Transportation Docket Operations West Building, Room W12

- 140 1200 New Jersey Avenue, SE Washington, D.C. 20590

- 0001

RE: International Aero Engines, LLC Petition for Exemption from 14 CFR § 33.94(a)(1)

Dear Ladies and Gentlemen:

Pursuant to 14 CFR part 11

, 1 International Aero Engines, LLC (IAE, LLC) hereby petitions for an exemption from § 33.94(a)(1) for the PW1100G

- JM Series T urbofan

E ngine

.

The exemption would allow IAE , LLC to show that its engine is capable of containing damage without catching fire and without failure of its mounting attachments where the most critical fan blade fails at the blade platform (as more particularly defined in

tech nical specifications) rather than at the outermost retention groove. This would

result in the liberation of more than 80% of the fan blade which is more material than required by § 33.94(a)(1) for the failure point in integrally

- bladed rotors.

For the re asons described below, a grant of exemption would be in the public interest, would not adversely affect safety and would provide an equivalent level of safety to that provided by the rule.

Pertinent Regulation

Section 21.21 requires a n applicant for a Type Certificate for an aircraft engine to meet certain requirements specified in t he Federal Aviation Regulations, including those

found in part 33. In pertinent part, § 33.94(a)(1) requires the applicant to demonstrate by engine tests that

--

(a)

... the engine is capable of containing damage without catching fire and

1 All citations are to 14 CFR unless otherwise noted. 117 North Henry Street, Alexandria, VA 22314

– 2903 Telephone 703.299.0784 Fax 703.299.0254

www.potomac

- law.com

Marshall S. Filler Direct Dial

- 703.451.7393

Admitted in the District of Columbia and Virginia E

- Mail

- marshall.filler @potomac

- law.comU.S. Department of Transportation Docket Operations September 12 , 2013 Page 2

RE: Internatio nal Aero Engines, LLC Petition for Exemption from 14 CFR § 33.94(a)(1)

without failure of its mounting attachments when operated for at least 15 seconds, unless the resulting engine damage induces a self shutdown, after each of the following events:

(1) Failure of the most critical compressor or fan blade while operating at maximum permissible r.p.m. The blade failure must occur at the outermost retention groove or, for integrally

- bladed rotor discs, at least 80 percent of the blade must fail.

Design Features an d Safety Considerations

The PW1100G

- JM Series Turbofan Engine employs geared turbofan technology, is manufactured with metallic, composite hybrid fan blades and contains additional strengthening at the fan blade attachment (i.e., fan blade root ).

Fan blade c ontainment is a function of fan rotational speed and fan blade weight. The blade operating environment of the geared turbofan is substantially lower in rotational speed with a corresponding lower fan pressure ratio than conventional

turbofans. Th e composite hybrid fan blade construction significantly reduces blade attachment load and is designed with significantly higher safety capability. It employs blade root surface treatments making it highly damage tolerant to service loads and

wear. In addi tion, the root area is over

- designed to drive any potential blade fracture to

the blade airfoils section above the platform. The combination of these characteristics

enables IAE , LLC to demonstrat e through analysis and test that the fan blade will not

fai l below the platform over the service life of the blade.

Exhibit A , which contains IAE, LLC confidential and proprietary information and will

therefore be submitted separately to the FAA, is a n impact assessment of how the requested exemption would affect compliance with other airworthiness standards in part

33

. 2 The design features of this engine described above , in combination with the impact

assessment

, conclusively demonstrates that granting an exemption would not adversely affect safety and wou ld also provide a level of safety equivalent to that provided by the

rule

.

2 The date of application for the PW1100G

- JM type certificate was December 15, 2011 . Therefore, the certification basis for the engine ( part 33 as amended by Amendment 33

- 1 through Amendment 33

- 32 ) was used as the basis for the regulatory impact assessment. The assessment also considers the FAA Policy Statements included in the PW1100G

- JM Compliance Plan PWA

- 9900

, as well as a pending rulemaking proposal to amend , in pertinent part, the icing airworthiness standards for turbine engines

. See FAA docket 2010

- 0636 ; 75 FR 37311 ( June 29, 2010 )

.U.S. Department of Transportation Docket Operations September 12 , 2013 Page 3

RE: Internatio nal Aero Engines, LLC Petition for Exemption from 14 CFR § 33.94(a)(1)

Public Interest

Granting the petition is i n the public interest because it would enable IAE , LLC to design

and manufacture an engine with a lighter fan case and accessory attachments, and an optimized flange joint design. This result s in a lighter

- weight engine relative to the engine thrust generated, which leads to (1) a lower fuel burn, and (2 ) reduced

emissions.

More specifically, the engine ’s reduce d weight decrease s fuel burn by 26,000 gallons

per year

. IAE, LLC estimates that approximately 5,000 PW1100G

- JM engines will enter

into service between 20 15 and 20 35

. Thus, fuel consumption will be reduced by 129.2

million gallons over the 20 year period. This will lead to a savings of approximately $ 517 m illion in lower fuel costs, and will reduce c arbon d ioxide e missions by 2.7 b illion pounds over the 20 year period. The data supporting these substantial cost savings

and emission reductions is found in the reference section of Exhibit A. The se are significant, tangible benefit s to the public as a whole.

In addition, Congress has declared that encouraging and developing civil aeronautics, including new aviation technology , is in the public interest an d should be considered by the FAA in carrying out its safety responsibilities under Title 49 U.S. Code

. 3 As such,

t he FAA determined that the carbon fiber composite fan blades of certain GE engines 4

w ere a novel and unusual design feature that justifi ed the issuance of special

conditions. 5 Consequently, in addition to meeting certain other requirements

, the special conditions authorized GE to perform a fan blade release test at the blade platform rather than the root

. GE therefore enjoys the concomitant benefits , such as a lighter

- weight fan case.

Co nversely , t he FAA determined that similar special conditions were in appropriate for

the PW1100G

- JM’s metallic composite hybrid fan blades

. Nevertheless, the design

characteristics of the PW1100G

- JM geared turbofan engine are such that the most

critical fan blade will not fail below the platform over the blade ’s service life

. The part 33 impact assessment and associated engineering data clearly demonstrate that granting the exemption would not adversely affect safety and would also provide an equivalent level of safety to that provided by the rule. This data is similar to what the FAA required of GE to meet the special conditions.

In summary, g ranting this petition would allow the approva l of a fan blade which results in less fuel burn, lower operating costs and reduced emissions. It would be consistent

3 49 U.S.C. § 40101(d)(3)

4 GE90

- 75B/

- 85B/

- 76B and various GEnx

- 1B and

- 2B series turbofan engines

5 Special Conditions No. 33

- 006

- SC, No. 33

- 007

- SC and 33

- ANE

- 08U.S. Department of Transportation Docket Operations September 12 , 2013 Page 4

RE: Internatio nal Aero Engines, LLC Petition for Exemption from 14 CFR § 33.94(a)(1)

with Congress’ desire to encourage the development of new aviation technology which

is clearly in the public interest.

Summary of Exemption Request

In accordance with § 11.81(f), IAE, LLC offers the following summary suitable for publication in the Federal Register.

IAE, LLC petitions the FAA for an exemption from § 3 3

. 94(a)(1) for its specific engine model PW 1100G

- JM to allow IAE, LLC to show that the

PW110G

- JM is capable of containing damage without catching fire and without failure of its mounting attachments where the most critical fan blade fails at the fan blade platform rather than at the outermost retention

groove.

Respectfully submitted,

Marshall S. Filler

Counsel for International Aero Engines, LLC

Attachment ( s ubmitted separately to the FAA )