The present concrete pavement design specification uses design aircraft to convert the traffic of other aircrafts into traffic of design aircraft according to the principle of equivalent damage, and it assumes that the wheel path in the lane of runway follows uniform distribution. Actually, wheel path follows the normal school, landing gear of new large aircraft becomes more complex, the peak value of cumulative damage of each aircraft maybe not at the same location, shortages of conversion method using design aircraft is increasing. Based on the wheel path in the lane of runway follows the normal school, pass-to-coverage ratio is used to calculate passes number. Design aircraft-s function is replaced by cumulative fatigue damage of pavement structure, which produced by all kinds of aircrafts is carried out directly. A new design method for concrete pavement based on cumulative fatigue damage is discussed and a design example is given. It is approved that the pavement design method using cumulative fatigue damage as design index is more suitable for concrete pavement design of large aircraft with complex landing gear.