Row44 Exemption Extension Request B777-200 Exemption No. 11071 Regulatory Docket FAA-2014-0402

1050 Oak Creek Drive

Lombard, IL 60148 Page 1 U.S. Department of Transportation Docket Operations West Building, Room W12-140 1200 New Jersey Avenue, SE Washington, D.C. 20590-0001
August 12, 2015
Re: Exemption No. 11071 - Regulatory Docket FAA-2014-0402: Petition of Row 44 for Time Limited Exemption from § 25.571(e)(1) of Title 14, Code of Federal Regulations (CFR). Row 44 Wireless Broadband System Antenna Provisions Installati on in Boeing 777-200 Series Aircraft, ODA Project ODA-GED-P066: Extension from 12 to 24 months In accordance with 14 CFR Part 11, Row 44 hereby pet itions for an extension to the referenced exemption from 14 CFR § 25.571(e)(1) (Amendment 25-132) as it relates to the above referenced certification project. For the reasons detailed below, Row 44 requests an imm ediate extension to this exemption from this rule and that it remain in effect for a period of an additional 12 months from the original date of approval. This twelve-month extension from the FAA bird-strike damage tolerance requirement is required to ensure that Row 44 has time to complete its development of a fu ll compliance methodology with § 25.571(e)(1) that is acceptable to the FAA. The specific regulation, § 25.571(e)(1) is as follows: Section 25.571(e)(1) – Damage tolerance (discret e source) evaluation. The airplane must be capable of successfully completing a flight during wh ich likely structural damage occurs as a result of – (1) Impact with a 4-pound bird when the velocity of the airplane relative to the bird along the airplane’s flight path is equal to Vc at sea level or 0.85 Vc at 8,000 feet, whichever is more critical. This section defines required stru ctural requirements for damage to the airframe from a bird strike. Safety and the Public Interest This petition for an extension to this exemption would not adversely affect safety because of two primary factors. First, there have never been any documente d bird strikes for large fuselage mounted satellite antenna radomes installed on Part 25 Tr ansport Category Aircraft. Secondly, in the normal operational flight envelope, the fuselage shadows the radome and a bird strike is not possible due to the positive angle of attack of the airplane. Row 44 currently has approximately 550 satellite antenna r adomes installed on Southwest’s 737 aircraft fleet. These aircraft are accumulating over 1 million flight hours pe r year with no reported bird strikes to the radome. Additionally, the following table below lists all the ex emption extensions granted for § 25.571(e)(1) for calendar years 2014/2015.Row44 Exemption Extension Request B777-200 Exemption No. 11071 Regulatory Docket FAA-2014-0402

1050 Oak Creek Drive

Lombard, IL 60148 Page 2 Exemption No. Applicant Aircraft type Regulatory Docket No. 10814B Plane Antennas and Security Systems Boeing 737-900 FAA-2013-0433 10817B Gogo, LLC Boeing 767 FAA-2013-0562 10845A Standard Aero Airbus A330 FAA-2013-0563 10847A Standard Aero Boeing 757 FAA-2013-0564 10848A Gogo, LLC Boeing 767-400 FAA-2013-0567 10850A DRB Aviation Consultants Boeing 777 FAA-2013-0660
In each exemption case listed above, the applicant ha s presented data that indicates on satellite antenna radome installations, which are similar to the satellite r adome installed by Row 44 in both size and installation location, there has never been a documented bird strike to the radome. This includes over 10 million flight hours with satellite antenna r adomes installed on all ty pes of Part 25 Transport Category Aircraft. In previous efforts to substantiate the Row 44 sate llite antenna radome in stallation for bird strike, it was shown analytically that for normal flight operations below 10,000 feet, the fuselage shadows the radome and a bird strike was not possible. Per 14 CFR 91.1 17(a), aircraft are not to fly beyond 250 Knots at an altitude below 10,000 feet. This project had expected to use this “normal flight envelope” velocity when showing compliance to § 25.571(e)(1). It has been clar ified by the FAA that the cruise velocity should be used for the flight envelope when investigating the potent ial for bird strike. This increased the speed used in the analysis from 250 Knots to Vc (Aprox.360 Knots). This clarification changes the attitude of the aircraft when investigating the radome for bird strike potential. Under the operational rule for max velocity below 10,000 feet (§ 91.117(a)), the aircraft would fly in a “nose up” attitude thus shielding the satellite antenna radome from a bird strike. However, under the langu age of § 25.571(e)(1), the aircraft design speed at sea level is used. This changes the attitude of the airc raft to level thus exposing the satellite antenna radome to a potential bird strike. This project’s STC was approved on December 18, 2014 and the updated analysis and testing required to show compliance to § 25.571(e) (1) has not been completed. This extension will allow Row 44 to complete the required testing a nd certification of these compliance criteria. The public interest is served in granting this exemptio n extension for the following reasons. There is keen interest, by the flying public, in having connectivity se rvices while flying, particularly on long domestic and international flights. These services enable business travelers to remain engaged in their trade while flying, thus enhancing efficiency and productivit y. The connectivity services are al so of great benefit to the leisure traveler by providing valuable co nnectivity and entertainment options. Bird Strike Substantiation: Row 44 has been reviewing § 25.571(e)(1) compliance opt ions with the Chicago Aircraft Certification Office (ACO) and the Transport Aircraft Directorate (TAD) for t he past year. A coordination meeting held in early November 2013 resulted in a method of showing comp liance to § 25.571(e)(1) t hat was tentatively agreed to by all parties present and is summarized below. Row 44 is developing an analytical model to predict the effects of bird strikes on our satellite antenna radome and antenna installation methodology. The model will be developed by creating a modeled (digital simulation) and performing an actual bird strike test on a satellite antenna radome and antenna installed on a rigid instrumented test fixture. A fter testing, the digital model response will be updated to incorporate the results obtained from the physical test. Next, the upd ated model will be validated by performing a bird strike analysis on a second (simulated) satellite antenna radome and antenna installation (different from the initial testing) and comparing this result with actual results of a second physical test of the actual structure with the satellite antenna radome and antenna mounted. Phase one of this testing (initial testing on a rigid testRow44 Exemption Extension Request B777-200 Exemption No. 11071 Regulatory Docket FAA-2014-0402

1050 Oak Creek Drive

Lombard, IL 60148 Page 3 fixture) is complete with positive results. Phase tw o is currently in final devel opment, testing is currently planned for the mid to late September 2015 time frame. Once the model/methodology is validated, the simulation data will be used to show compliance to § 25.571(e)(1) on this an d new FAA STC projects employing this particular satellit e antenna radome and antenna installation methodology. International Operations: Per § 11.81(h), Row 44 requests that the privileges of this Exemption be extended outside of the United States. This extension of privil eges is necessary for operations based within foreign countries having bilateral agreements with the United States acceptin g FAA 14 CFR Part 25 as their airworthiness standards for transport category aircraft. The Boeing 777-200 aircraft is inte nded for the global marketplace. The initial aircraft that has been modified has China r egistration and is currently the only aircraft operating under this exemption. The local airworthiness authorit ies are insistent that the United States airworthiness standards along with the CAAC airwor thiness standards be followed for all modifications. This extension is requested to allow this aircraft to continue operation in its inst alled configuration. Commercial Impact: Row 44 will incur significant loss of revenue as a result of a not obtai ning an extension of this exemption and will end our trial operations of the FAA approved Sa tellite System Installation on Boeing 777-200 series aircraft operated by China Airlines. Good Cause Exists to Issue the Extension to this Exemption without Notice and Comment: Row 44 requests that the FAA issue the exemption extension without publication for comment in the Federal Register. Section 11.87 lists four factors co nsidered by the FAA in deciding whether or not to publish a summary of the petition and request comments. Row 44’s response to each condition is shown below in italics. (a) Whether granting the petition would set a precedent. According to the FAA’s Exemption database, at le ast five (5) exemption extensions have been granted to § 25.571(e)(1) in calendar year 2014/20 15 which allowed aircraft to operate for a limited period of time pending the successful resolution of a compliance issue. (b) Whether the relief requested is ident ical to exemptions granted previously. The majority of the exemptions granted were fo r the same reason as stated in requesting this exemption. The applicant, Row 44 needs additional time to analyze and/or test and/or modify the existing radome to be fully compliant with the provisions of § 25.571(e)(1).( c a d
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