March 24th , 2015 

G C F-0335/2015 - 1 /5 

BAP 

-E EMBRAER 

timbracr S.A. 

Av. Bngadeiro Faria Lima. 2.170 

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

Brasil 

Fone: (12) 3927-2563 

Fax: (12) 3927-1184 

PC: 179 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W 12-140 

Washington, DC 20590 

Subject: EMB 550/545 - FAA Validation 

Request of amendment on Exemption 10757 - Docket No. FAA-2012-0302 - 

Requirement 14 CFR 25.809(a). 

Dear Sir: 

Please, find enclosed request of amendment on Exemption 10757 - Docket No. FAA2012-0302- to permit type certification of similarly non-compliant derivatives of the 

current Embraer Model EMB-550 airplane. 

The original petition was sent on March 9 th , 2012 and it was granted on April 25 1 ", 2013. 

The complete petition is available at the Department of Transportation's Federal Docket 

Management System, in Docket No. FAA-2012-0302. 

Embraer has analyzed Exemption 10757 and this was also considered applicable to 

similarly non-compliant derivatives of the current Embraer Model EMB-550 airplane 

(including, but not limited to EMB-545) once the same interior design, all the arguments 

and compensating factors are considered the same. 

Sincerely, 

~ ~ 

r ~-Ricardo L val Hollerbach ~ 

Airwort iness Director 

raf~ef ~ustavo rrassina ftrqups 

Airworthiness Office 
GCF-0335/2015 - 2/5 { EMBRAERi 

14 CFR 11.81 (a) - Contact Information: 

Ricardo Lavall Hollerbach 

Embraer Airworthiness Director 

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 

14 CFR 11.81 (b) Specific section from which Exemption is required 

& 25.809 Emerctency exit arrangement: 

(a) Each emergency exit, including each flightcrew emergency exit, must be a moveable 

door or hatch in the external walls of the fuselage, allowing an unobstructed opening to 

the outside. In addition, each emergency exit must have means to permit viewing of the 

conditions outside the exit when the exit is closed. The viewing means may be on or 

adjacent to the exit provided no obstructions exist between the exit and the viewing 

means. Means must also be provided to permit viewing of the likely areas of evacuee 

ground contact. The likely areas of evacuee ground contact must be viewable during all 

lighting conditions with the landing gear extended as well as in all conditions of landing 

gear collapse. 

14 CFR 11.81 (c) Extent of relief and Reason for Seeking Relief 

Petition and General Information: 

Under the provisions set forth in Title 14 Code of Federal Regulations (14 CFR) 11.81, 

Embraer is seeking an exemption to allow partial relief from § 25.809(a) at Amendment 

25-116 for the Type III overwing exit on the Model EMB-550 and similarly derivatives 

models. 

The overwing hatch is located inside the lavatory and has a window that provides an 

effective means to assess external conditions prior to exit opening. This includes 

viewing of the wing surface where the evacuees would make their initial contact up to 

the end of the scape route on the wing considering all lighting conditions with the 

landing gear extended as well as in all conditions of landing gear collpase. Partial relief 

is being sought from the requirement since this outside viewing means does not permit 

viewing of the likely area of evacuee ground contact prior to exit opening during all 

lighting conditions with the landing gear extended as well as in all conditions of landing 

gear collapse. 

Relief is necessary since literal compliance with the rule would require extensive design 

changes to the airplane (exit relocation) to permit viewing of the likely areas of evacuee 

ground contact during all lighting conditions and with the landing gear extended and in 

conditions of landing gear collapse. Making this type of design change would not 
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-< EMBRAER 

enhance the level safety provided for the occupants and it would impact introduction of 

the Model EMB-550 and similarly derivatives models. 

Background: 

In an emergency situation it is generally accepted that an exit should not be opened if 

opening it would create a more hazardous situation for the occupants of the airplane. 

With Amendment 25-116 14 CFR 25.809(a) now includes the requirement that an 

outside viewing means at emergency exits permit viewing of the likely area of evacuee 

ground contact and that the likely area of evacuee contact be viewable during all lighting 

conditions with the landing gear extended as well as in all conditions of landing gear 

collapse. 

Model EMB-550 and similarly derivatives models are executive jets with a maximum 

occupancy of 12 passengers provided with a Type III overwing exit hatch located inside 

the lavatory. The hatch window provides an effective means to assess external 

conditions when deciding whether or not to open the exit. This includes viewing of the 

wing surface where the evacuees would make their initial contact up to the end of the 

scape route on the wing considering all lighting conditions with the landing gear 

extended as well as in all conditions of landing gear collpase. This also includes viewing 

of the ground near where the evacuees would normally be expected to make their initial 

contact. In addition, an emergency lighting system is provided according 14 CFR 25.812 

(g)(1) and an escape route is provided according 14 CFR 25.810 (c). Since the end of 

the escape route on the wing terminates in a height distance from the ground of less 

than 6 feet there is no emergency egress assist means installed. Once the evacuees 

step on the wing and reach the end of the escape route on the wing they will be able to 

see the ground contact area considering all lighting conditions and under all conditions 

of landing gear collapse. Therefore, they will get a good sense of whether or not there is 

a significant hazard on the ground. While the overwing exit window provide an excellent 

means for assessing the outside conditions, this does not allow direct viewing of the 

ground where the evacuees would normally be expected to make their initial ground 

contact. This is due to the relative distance of the exit location and the ground contact 

area. 

Partial relief from § 25.809(a) at Amendment 25-116 is necessary because design of 

the Model EMB-550 and similarly derivatives models airplanes are complete and it 

would require extensive design changes for the overwing exit to comply with the outside 

viewing requirements with no material difference in the level of safety. 

14 CFR 11.81 (d) Reason why granting relief would be in public interest 

Public Interest: 

Granting this petition is in the public's interest because the outside viewing means 

provided for the Model EMB-550 and similarly derivatives models overwing exits provide 

the level of safety the FAA intended to promulgate with the new rule. 
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-< EMBRAER 

Not granting the exemption would lead to an extensive unplanned design and 

manufacturing effort (exit relocation to the passenger cabin). In addition, the level of 

comfort of the passengers would be compromised due to consequent changes of 

moving the exit: seat movements restrictions to allow assess and openability of the exit, 

noise increase and temperature variations in the passenger seating/rest area. 

Incorporating this type of design change would not enhance the level safety provided for 

the occupants and it would impact introduction of the Model EMB-550 and similarly 

derivatives models airplanes to the operators. Therefore, granting the exemption is in 

the public interest. 

14 CFR 11.81 (e) Reasons why exemption would not adversely affect safety 

Justification: 

During an airplane emergency evacuation, there is the potential for an extemal hazard 

that could pose an immediate threat to the occupants of the airplane if an exit was 

opened. While fire is the principle external hazard, there are other types of hazards 

such as water or large obstructions that could make not opening an exit the preferred 

course of action. However, due to the viewing area provided by the overwing hatch 

window during all lighting conditions and with the landing gear extended and in any 

conditions of landing gear collapse, it is very likely that any severe extemal hazard that 

could create an immediate hazard to the occupants could be detected prior to deciding 

whether or not to open the overwing exit. Therefore, there is no appreciable difference 

between the level of safety provided by the outside viewing means provided for the 

Model EMB-550 and similarly derivatives models overwing exits and that intended by 

the new regulation. 

14 CFR 11.81 (f) Summary for publication in Federal Register 

Embraer requests an Exemption from 14 CFR 25.809(a) Amdt. 25-116 for the Type III 

overwing exit on Model EMB-550 and similarly derivatives models. 

14 CFR 11.81 (g) Additional Information to Support Request 

Conclusions: 

For the Model EMB-550 and similarly derivatives models airplanes, the overwing hatch 

window provides an effective means to assess extemal conditions when deciding 

whether or not to open the overwing hatch. This includes viewing of the wing area 

where the evacuees would make their initial contact after opening the exit considering 

all lighting conditions with the landing gear extended as well as in all conditions of 

landing gear collapse. This also includes viewing of the ground near where the 

evacuees would normally be expected to make their initial contact. The overwing hatch 

window provides an external viewing means equivalent to that intended by the new 

regulation, which Embraer believes was the FAA's stated intent when codifying the 
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-< EMBRAER 

requirement for an outside viewing means at the emergency exits. Passenger and crew 

safety will not be degraded by a grant of this exemption petition.