March 18, 2011 V; EMBRAEH

GCF-0325/2011 tlVIBHAtH

MCB

BftbAKr S-\-

Av Brigadeiro Faria Lima. 2.170

12227-901-SJ dos Campos SP

Brasfl

Fone (12) 3927-6481

Fas1 (12) 3927-1 !84

PC:179

US Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor

RoomW12-140

Washington, DC 20590

Subject: EMB-550 FAA Type Validation

Petition to the Exemption from 14 CFR 25.813 (e) Amdt. 25-116

Dear Sir (Madam):

Please find enclosed Embraer Petition to the Exemption from 14 CFR 25.813 (e) Amdt.

25-116, in order to allow the certification of the installation of interior doors between

passenger compartments and emergency exit in the EMB-550 Type Design. The

additional information is below:

Contact Information:

Embraer

Av. Brigadeiro Faria Lima, 2170 PC 179

12227-901 Sao Jose dos Campos, SP Brazil

Phone: 55-12-3927-3543

Fax: 55-12-3927-1184

Sincerely,

JnJISergio AugfMo ViSna <feCarv~aiM> Rafaet Gustavo Fassina Marques

Airworthiness Manager Certification Office

C.c: ANAC-WillianYoshinoriTanji (PCM EMB-550)
EMBRAER

Summary of Petition

Embraer requests an Exemption for the compliance of 14 CFR 25.813(e) Amdt. 25-116,

in order to allow the certification of the installation of interior doors between passenger

compartments and emergency exit in the EMB-550 Type Design.

14 CFR 25.813 Emergency exit access.

(e) No door may be installed between any passenger seat that is

occupiable for takeoff and landing and any passenger emergency

exit, such that the door crosses any egress path (including aisles,

crossaisles and passageways).

Petition and General Information

The EMB-550 airplane will comply with the 14 CFR 25 requirements in amendment 127,

transport category airplanes. The regulations on the aircraft category transport do not

make any distinction between commercial aircraft, used for the public paying and

aircraft especially used for other operations, as the "charter" or private.

Therefore, the only mean available for accepting this installation for private use

airplanes would be through an exemption from the prohibition of interior doors between

passenger compartments 14 CFR 25.813 (e) as above mentioned.- Embraer intends to,

if this exemption is granted, provide certain privacy options that have became standard

for business jets.

EMBRAER believes that aircraft specially designed for the private use shall be eligible

for the acceptance of exemptions of cabin characteristics that do not comply with certain

parts of 14 CFR 25. In this case, similar level of safety can be demonstrated.

Embraer also states that the following characteristics are unique to private use airplanes

and provide compensating factors that are not normally provided in commercial use

airplanes:

The number of passengers in private use airplanes is smaller than that

traditional airplanes commercial

The passengers in private use airplanes are typically frequent fliers and

familiar with the safety features of the specific airplane they are aboard;

The interior arrangement is static, allowing flight and cabin crews to become

acquainted with the configuration of the airplane, and emergency equipment

provided, and the location of the emergency exits. They also have regular

contact with the "repeated" passengers, which promotes positive influence

on communicating safety issues;

Differently from an airline, the operator has control and may restrict the public

and/or select the passengers of aircraft.
EMBRAER

Justification:

Embraer believes that many customers who purchase and operate Embraer airplanes

consider privacy to be an essential feature. Therefore, it is important that portions of the

cabin may be configured as private areas to accommodate private meetings. The only

plausible method of providing such privacy is through the use of doors that separate

passenger compartments. When private area is created within the passenger cabin,

the doors separating the private area from the rest of the cabin will be located between

passenger compartments.

The cabin of the EMB-550 is approximately 8.4 feet wide. It is necessary to divide the

cabin full width laterally to produce private area because side corridor would not be

practical.

The proposed doors will be installed across longitudinal aisle and translate laterally to

open and close. The doors will not obstruct the openings when they are open complying

with the aisle width requirements of 14 CFR 25.815 for the maximum possible

passenger configuration.

Embraer states that the doors will have the following additional safety features:

1. Each interior door will be frangible, so that in the event that it is jammed in the

deployed position, it will allow 5th percentile female to break the doors open in

case of an emergency, creating large enough opening that 95th percentile

male can pass through.

2. Each interior door will also be equipped with dual locking mechanism to hold the

door in the open position in such the probability of door unlocking due to

distortion of the fuselage in an emergency landing will be minimized. Each

locking will be able to withstand the loads imposed upon it when the door is

subjected to the ultimate inertia forces specified in 14 CFR 25.561.

3. When the doors are deployed (i.e., spanning across the aisle), there will not be

latching mechanism that keeps the doors in that position, obstructing the aisle.

This will allow occupants to access the opposite side of the door without the use

of any tools.

4. An advisory CAS message "Door Pocket Not Open" will be provided for crew

when an interior door is not open and locked for take off and landing. The doors

will be placarded to be locked open during taxi, take-off and landing.

5. Emergency exit locator, marking signs and emergency lighting in accordance

with 14 CFR 25.811 and 25.812 will be provided.

6. The Airplane Flight Manual (AFM) will provide procedures and limitations to

ensure that the doors are in the proper position for taxi, takeoff and landing.
EMBRAER

Embraer believes that the basic issues of passenger finding and reaching an exit in an

emergency are addressed by the above additional safety features and by the existing

safety parameters inherent in the operation of private use airplanes. Embraer also

believes that even if some extreme condition should result in door being closed or

partially closed after an accident, there are simple means to get through the door to

reach the exit(s). For this reason, the exemption, as requested, would provide level of

safety for passengers in the EMB-550 that would be acceptable to that required for

passengers of airplanes in commercial operation.

Public Interest

Because the design features listed above provide adequate passenger ability to egress

in an emergency, the granting of this petition will allow Embraer to provide the type

interior layouts expected in this class of airplane while simultaneously providing an

adequate level of passenger protection. Allowing the installation of passenger

compartment doors while maintaining an adequate level of passenger protection is in

the public interest.

Denial of this petition would also negatively impact the ability of the EMB-550 to

compete with other airplanes in the executive market, that have passenger

compartment doors because their authority granted them similar exemption or is

under an earlier certification basis, leading to loss of revenue for Embraer and its

Brazilian suppliers having an adverse impact on the Brazilian economy, which would be

against the public interest.

Conclusions

EMBRAER believes that the EMB-550 interior arrangement design, which is specific for

private use as well as its operation private and the characteristics proposals for the

occupant protection must justify the granting of exemption.