A380豁免条款

Exemption No. 8538 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION RENTON, WASHINGTON 98055-4056 In the matter of the petition of Airbus Regulatory Docket No. FAA-2003-15812 for exemption from § 25.562(b)(2) of Title 14, Code of Federal Regulations GRANT OF EXEMPTION By letter dated June 17, 2003, Mssrs. Jean Francois Petit, Certification Manager, and Jean Michel Govaere, A380 Chief Airworthiness Engineer; Airbus; 1 Rond-Point Maurice Bellonte; 31707 Blagnac Cedex; France, petitioned for exemption from § 25.562(b)(2), Title 14, Code of Federal Regulations (14 CFR), as amended by Amendment 25-64. The proposed exemption, if granted, would permit relief from the floor warpage testing requirement for flightdeck seats on the Airbus Model A380 airplanes. The petitioner requests relief from the following regulation: Section 25.562(b)(2), Amendment 25-64, requires the floor tracks used to attach the seat to the floor be misaligned with respect to the adjacent seat tracks by at least 10 degrees vertically (i.e., out of parallel) with one rolled 10 degrees. [The misalignment is used during the forward loading dynamic test condition and applies to all seats occupiable for takeoff and landing.] ANM-03-569-E The petitioner’s supporting information is as follows: Airbus seeks exemption from the requirement to demonstrate compliance by testing the flight deck seats in accordance with this requirement. The reason Airbus seeks this relief is that FAA has determined that such testing is unnecessary. Since 1992 FAA has taken the position (see, e.g. Docket 26649, Exemption Grant 5436, dated April 1, 1992) that ‘there has not been a problem with flight deck seat separations due to floor buckling on narrow body and larger airplanes which have a minimum of 40 inches of frangible structure between the flight deck floor and the lower fuselage contour. The FAA now considers that requiring testing of pilot seats with floor warpage cannot be justified on narrow body and larger airplanes.’ Since that position was first taken, FAA has granted numerous exemptions from the floor warpage testing requirements for flight deck seats to both US and non-US applicants. Airbus seeks the same relief that has been granted in the past to other similarly situated applicants. (See, e.g., exemptions 6425, 6425A, 6600, 6819, 6887, and 6935, all granted to applicants seeking the same relief under similar circumstances.) FAA itself has analyzed past requests from numerous petitioners as noted above. These requests were similar in all material respects to the instant request of Airbus. Simply put, using FAA words (see Exemption 6887), ‘Subsequent to the adoption of this requirement by Amendment 25-64, it was determined that, although some cockpit floor distortions have occurred during accidents, there has not been a problem with flight deck seat separations due to floor buckling on “narrow body” and larger airplanes having at least 40 inches of frangible structure between the flight deck floor and the extended lower fuselage contour [as does the A3800]. Consequently, the FAA has concluded that requiring the testing of flight deck seats under conditions of floor warpage cannot be justified on airplanes of this minimum size.’ The petitioner’s statement of public interest is as follows: Airbus submits that granting this petition is in the public interest, because such action will: 1. Not adversely affect flight safety, as the FAA itself has stated; 2. Improve the efficiency of the Airbus A380; 3. Tend to reduce air transportation and air cargo fares for all users; and 4. Reduce the cost of the aircraft to US operators. 2 Public Comment A summary of this petition was published in the Federal Register on October 3, 2003 (68FR57504). No public comments were received. The FAA's analysis/summary is as follows: The petitioner requests exemption from the requirement to conduct dynamic testing with seat tracks misaligned in accordance with 14 CFR 25.562(b)(2). This request is limited to seats on the flightdeck. The petitioner notes that the FAA has previously granted numerous exemptions from this requirement. While such exemptions must be reviewed for precedent, the fact that other exemptions have been granted does not ensure that further exemptions will be granted. The conditions and rationale must be established in each case in order to justify relief from a requirement. The petitioner's request for relief from the requirement to misalign the seat tracks is limited to the flightdeck seats in Airbus model A380. These seats are individually mounted single seats with both floor and wall mounting to accommodate both flightcrew and observers. Crew seats are required to be fairly rigid in order to withstand the pilot reaction forces from the flight controls. No matter where they are installed, wall mounted seats are generally not subject to the requirement for floor misalignment during testing, because they do not mount directly to the floor. The FAA has reviewed the arguments presented by the petitioner in support of the exemption and concludes that the service history of flightdeck seats on larger airplanes supports the petitioner's request. The A380 is the largest commercial airplane ever made, and any rationale applicable to previous airplane types is equally applicable to the A380. Although some distortions of the flightdeck floor have been observed after accidents, separation of flightdeck seats due to floor buckling has not been observed on those narrow body and larger airplanes that have a minimum of 40 inches of frangible structure between the flightdeck floor and the lower fuselage contour. As noted in the other exemptions to which the petitioner refers, the FAA is considering amending the regulation governing seats on the flightdeck. However, no schedule has been set for this rulemaking, because other safety initiatives are more urgent. 3 The grant of exemption: In consideration of the foregoing, I find that a grant of exemption is in the public interest, and will not adversely affect safety. Therefore, pursuant to the authority contained in 49 U.S.C. §§ 40113 and 44701, delegated to me by the Administrator (14 CFR § 11.53), Airbus is hereby granted an exemption from the floor warpage testing requirements of 14 CFR § 25.562(b)(2), Amendment 25-64, to the extent required to permit type certification of the Airbus Model A380 for seats mounted in the flightdeck. The following limitations apply to this exemption: 1. This exemption is limited to the Airbus model A380 series airplanes and applies only to the seats in the flightdeck. The seats aft of the flightdeck are not exempted. 2. The flightdeck seats are exempted from compliance with the 10 degrees of track misalignment required under § 25.562(b)(2). Compliance with all other requirements of § 25.562 is required. Issued in Renton, Washington, on April 1, 2005. /S/ __________________________ Kalene C. Yanamura Acting Manager Transport Airplane Directorate Aircraft Certification Service 4 Airbus GRANT OF EXEMPTION Public Comment