March 6 , 2014

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

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

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

- 0001

RE: International Aero Engines, LLC Petition for Reconsideration of Exemption Denial, 14 CFR § 33.94(a)(1) , Regulatory Docket No. FAA

- 2013

- 0815 , Exemption No. 10914

Dear Ladies and Gentlemen:

Pursuant to 14 CFR § 11.101

, 1 International Aero Engines, LLC (IAE, LLC) hereby petitions

for reconsideration of the FAA’s January 9, 2014 denial of 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 technical 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 i n integrally

- bladed rotors.

Legal b asis for this r equest

Section 11.101 provides that a petition er for reconsideration must , within 60 days after an exemption request is denied

--

(a) Present a significant additional fact and explain why it was omitted fro m the original petition;

(b) Establish that t he FAA made an important factual error in denying the original petition; or

(c) Show that t he FAA did not correctly interpret a law, regulation, or precedent.

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

March 6 , 2014 Page 2

RE: International Aero Engines, LLC Petition for Reconsideration of Exemption Denial,

14 CFR § 33.94(a)(1) , Regulatory Docket No. FAA

- 2013

- 0815

, Exemption No. 10914

As further described below, IAE, LLC is submit ting significant additional facts in accordance with § 11.101(a)

.

Summary of IAE, LLC Petition for Exemption

On September 12, 2013

, IAE, LLC filed a petition for exemption from § 33.94(a)(1). 2 In support of its request , IAE, LLC stated that the design c haracteristics 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. In its petition IAE, LLC stated that the part 33 impact assessment and associated engineering data submitted to the FAA 3 demonstrated that an exemption would not adversely affect safety and would provide an equivalent level of safety to that provided by the rule.

IAE, LLC also stated that granting the petition is in the public interest because it would enable the company to design and manufacture an engine with a lighter fan case and accessory attachments, and an optimized flange joint design. This results in a lighter

- weight engine relati ve to the engine thrust generated, which leads to (1) lower fuel burn, and (2) reduced emissions. IAE, LLC then provided specific figures to quantify the reduced fuel

burn , reduced emissions, and cost savings

– all of which constitute significant, tangibl e benefits to the public as a whole.

Summary of FAA D e nial

On Jan uary 9, 2014, the FAA denied IAE , LLC’s request for the following reasons

.

1. T he petition for exemption stated that the fan blade will not fail below the platform

over the service life of the blade, but d id not provide technical data to establish that probability of failure to be at least equivalent to a failure rate of extremely improbable

or less. Consequently, t he petitioner has not shown that granting the exemption would not adversely a ffect safety or shown how the exemption would provide a level of safety at least equal to that provided by the rule or those established by the GE special conditions.

2. The yearly fuel savings per engine was incorrectly stated in the petition. The petition

estimated a yearly fuel savings of 26,000 gallons per engine ; however, this is the 20

- year fuel savings. The annual fuel savings per engine is 1 ,292 gallons, which is substantially less. Based on an estimated 1,500 flights per year, this fuel savings
equat es to approximately two gallons per flight.

2 The petition was supplemented on September 26, 2013 to address international issues.

3 This privileged and confidential data was submit ted directly to the Engine & Propeller Directorate for

evaluation.U.S. Department of Transportation Docket Operations

March 6 , 2014 Page 3

RE: International Aero Engines, LLC Petition for Reconsideration of Exemption Denial,

14 CFR § 33.94(a)(1) , Regulatory Docket No. FAA

- 2013

- 0815

, Exemption No. 10914

Significant additional facts

Pursuant to § 11.101(a) , IAE, LLC is submitting significant additional engineering

information showing that the probability of the fan blade’s failure below the platform is extremely imp robable or less. This confidential analysis will be submitted in confidence to the Engine & Propeller Directorate contempo raneously with the filing of this petition for

reconsideration.

This detailed technical report provides evidence in the form of significant additional data,

test results

, and analyses which shows that the fan blade below platform fracture rate for

the PW1100G

- JM Series Turbofan Engine is extreme ly improbable ( i.e., less than 1E

- 09 per flight hour). This probability of fracture supports the conclusion that safety is not affected and the requested exemption to § 33.94(a)(1) would provide an equivalent level of safety to that provided by the rule.

The fracture rate determination was based on a robust fault tree risk analysis that includes all below platform fracture mechanisms of the PW1100G

- JM fan blade, including corrosion, low cycle fatigue, embedded flaws, high cycle fatigue, impact and overstr ess.

Th e data was not provided in the original submittal because § 33.94(a)(1) does not include

a probability analysis requirement

. A lthough such a requirement was included in the GE special conditions 4 , there was no indication in that document that this analysis had been performed before the special conditions were issued

.

As the FAA correctly noted on page 7 of the Denial of Exemption, the 26,000

- gallon figure is

the 20

- year fuel savings for each engine, not the per year fuel savings. However, the

rem aining figures for fuel consumption reduction (192.2 million gallons), cost savings ($517 million), and reduced carbon dioxide emissions (2.7 billion pounds) are all accurate when the life of the engine program (i.e., 5000 engines entering into service bet ween 2015 and 2035) is considered in the aggregate. It is these aggregated public benefits

– particularly

the reduced carbon dioxide emissions

– which support a finding that granting this petition is in the public interest.

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

with Congress’ desire to encourage the development of new aviation technology which is clearly in the public interest.

4 The special conditions were i ssued for the GEnx series, the GEnx

- 2B series and the GE90

- 75B/

- 85B/

- 76B model turbofan engines.U.S. Department of Transportation Docket Operations

March 6 , 2014 Page 4

RE: International Aero Engines, LLC Petition for Reconsideration of Exemption Denial,

14 CFR § 33.94(a)(1) , Regulatory Docket No. FAA

- 2013

- 0815

, Exemption No. 10914

Good Cause Exists to Grant this Request without Further Notice and Comment

Section 11.87 lists four factors that the agency considers in deciding whether a petitioner has shown good cause for the FAA not to delay action on a petition for exemption. Those

factors are set forth below in italics along with the company’s response in plain text:

(a) Whether granting the petition would set a precedent: The FAA has previously granted similar relief in the form of special conditions as referenced in this petition; therefore, this request would not set a precedent. (b) Whether the relief requeste d is identical to exemptions previously granted : The requested relief is substantially similar to that previously granted through the special conditions process. (c) Whether delaying action would adversely affect IAE, LLC : Delaying action for the

notice and comment process will inject further delay and uncertainty into the certification process. IAE, LLC is planning to run another engine test in May and therefore requires a decision on its request as soon as possible. (d) Whether the petition was filed in a timel y manner : The petition for reconsideration is timely filed.

Summary of Petition for Reconsideration

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

IAE, LLC petitions for reconsidera tion of the FAA ’s January 9, 2014 denial of an exemption from § 3 3

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

- JM . The exemption would allow IAE, LLC to show that the 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 fan blade platform rather than at the outermost retention groove. The petition for reconsideration

is base d on the submission of significant additional engineering information demonstrating that failure of the blade below the platform is extremely improbable.

Respectfully submitted,

Marshall S. Filler

Counsel for International Aero Engines, LLC

Attachment (submitted separately to the FAA)