FAA Proposes Certification Conditions for Embraer E195-E2 Enhanced Takeoff System
Why It MattersAutomated takeoff rotation is outside current transport-category rules, so the conditions set a regulatory precedent for how pilot-replacing flight automation is certified, with possible reach beyond this one type.
The U.S. Federal Aviation Administration has proposed additional certification requirements for Embraer's Enhanced Takeoff System (E2TS) on the E195-E2 commercial jet. The proposal was published Tuesday in the Federal Register. E2TS engages when pilots advance the thrust levers to the takeoff/go-around position, then automatically manages pitch and bank angle during rotation and initial climb, while pilots remain responsible for runway alignment during the ground roll. Embraer developed the system to improve takeoff performance, potentially allowing more payload or fuel on shorter runways, and it has been undergoing certification testing in Brazil.
The FAA stated in its proposal: "The current regulations do not take into consideration that the takeoff rotation is being performed by an automatic system, not a human being." Existing requirements account for variations in pilot technique, whereas the proposed conditions would evaluate deviations caused by sensor accuracy and system tolerances. Takeoff distance following an engine failure could not exceed the corresponding published distance in the aircraft flight manual after accounting for expected system variations. With both engines operating, the system could not increase the applicable takeoff distance by more than 1%. Embraer would also have to demonstrate that E2TS does not produce unsafe flight characteristics, including in out-of-trim conditions.
Embraer first applied to amend the type certificate to incorporate E2TS in December 2021. The FAA said existing transport-category regulations do not adequately address the system's automated takeoff functions, which makes additional conditions necessary. The agency is accepting public comments for 30 days after publication. The conditions would set certification standards for the technology but would not themselves approve it for operational use.
