Crash Resistant Fuel System / Breakway Coupling / Separation Load

In the context of validation of a crash resistant fuel system for a small turbine powered rotorcraft EASA received a request for an equivalent safety finding (ESF) with CS 27.952(c)(1)(i) for the requirements concerning breakaway coupling separation load.
(Note: CS 27.952 Amdt. 10, FAR 27.952 Amdt. 30 and its current Amdt. 51 are technically identical, while there is only an editorial difference concerning the units N and lb).

The function of the breakaway coupling is to ensure controlled separation of the fuel line without fuel leakage in case of a crash landing. 
CS 27.952 (c)(1)(i) reads as follows:
“The load necessary to separate a breakaway coupling must be between 25 to 50 percent of the minimum ultimate failure load (ultimate strength) of the weakest component in the fluid-carrying line. The separation load must in no case be less than 1334 N (300 lb), regardless of the size of the fluid line.”

The intent of this requirement is supposed to be as follows:
The separation load shall be designed to ensure that:
1)    the coupling reliably separates during a crash (< 50% of UL weakest component)
2)    the coupling does not separate during normal aircraft operation (> 25% of UL weakest component)
3)    the coupling does not separate during maintenance (> 1334 N (300 lb))

EASA received an application for Major Change to TC involving a fuel tank design where the separation loads of the couplings for specific load cases do not directly comply with the specified minimum value of 0,25 UL. Nevertheless, with the given design features it can be expected that there will be conservative margin between the maximum working loads in normal operation and the actual separation load of the coupling. Consequently, the intent to prevent unintended separation of the coupling under normal operating conditions is not compromised.

Considering all the above, the following Equivalent Safety Finding is proposed.