Subject: Petition for Exemption from 14 CFR 25.791(a),(b); 25.807(b), 

(c)(1),(c)(5),(c)(6); 25.809(f)(1); 25.813(f); 25.857(e) and 

25.1447(c)(1) due to carriage of persons other than crew 

(supernumeraries) on the 747-400 Large Cargo Freighter 

(LCF) 

Introduction:

The 747-400 Large Cargo Freighter (LCF) is a 747-400 series passenger airplane that has 

been modified in accordance with FAA-approved Boeing Service Bulletin 747-00-2084 

to operate in a freighter configuration. As identified in Exemption 8769/8769A/8769B, 

the primary purpose of these airplanes is carrying non-flammable components that 

support Boeing Model 787 airplane production and other non-787 large/outsized cargo 

that directly supports Boeing corporate business activities. There are currently four (4) 

LCF airplanes in operation. 

Although Boeing owns these airplanes, they are operated on behalf of Boeing by a Part 

121 operator, and the aircraft are N-registered. As a condition of the previous exemption, 

these aircraft transport only the cargo allowed per the exemption and are not used by 

Boeing or the aircraft operator to conduct commercial freight hauling operations.

The flight deck of the LCF retained the four (4) approved flight deck seats from the 

original 747-400 series passenger model which are currently restricted to flight crew use 

only: pilot, co-pilot and two (2) observer seats. 

There are no provisions on the aircraft for the carriage of passengers. The purpose of this 

exemption would be to allow for carriage of two (2) persons other than flight crew 

(supernumeraries) utilizing the existing observer seats located in the flight deck. No 

access to the Class E cargo compartment is possible. 

The upper deck interior arrangement consists of a flight deck crew rest, lavatory, closet, 

galley and 747-400F style ladder to the main deck. Emergency equipment, galley oxygen 

drop, exit signs, and emergency lighting are also installed to support the interior 

configuration (CP D926U013-17). The flight deck overhead hatch remains unchanged 

and is equipped with inertial reels same as the 747-400 series passenger model. 

The main deck area located forward of the Class E cargo compartment is not allowed to 

be occupied during taxi, takeoff, flight and landing. The ladder from the upper deck leads 

directly towards the RH entry door. The slide raft on the RH door has been removed and 

replaced by a 747-400F door liner and escape rope with a ten (10) person life raft 

installed nearby. The RH slide raft was removed to allow better access to the door. The 

LH entry door retains its passenger slide raft. These main deck doors and rafts have been 

preserved for the planned ditching scenario. Exit signs and emergency lighting are 

installed to illuminate the path and direct the occupants to the main deck door pair for 

their use as planned ditching exits. Emergency equipment including two (2) fire 

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extinguishers, (halon and water), and a portable Emergency Locator Transmitter (ELT) 

are also installed on the main deck. 

Boeing is proposing to allow the carriage of up to two (2) persons (supernumeraries) in 

the flight deck in addition to the two (2) flight crew members in lieu of four (4) 

crewmembers only. This will allow for the more efficient use of the LCF airplanes in 

support of the 787 program. Boeing is therefore requesting an exemption similar to FAA 

Exemptions 1870, 1870A, 1870B, 1870C, 1870D, 1870E and 9735 for 747-100(SF)/-

200F/-200C/-200(SF)/-400F, FAA exemptions 8590, 8590A, and 8590B for 747-400SF 

(747-400BCF), and FAA exemptions 9793, 9793A and 9793B for 747-8 which allows 

for the carriage of limited persons (supernumeraries) on cargo aircraft. The main 

difference between these listed 747 aircraft and the 747-400 LCF is that the upper deck 

area has a single emergency exit which is the overhead crew hatch and that the planned 

ditching scenario exits are located on the main deck. 

(a) Name and Address of the Petitioner 

The Boeing Company 

c/o Mr. Robert A. Beaudreau 

3855 North Lakewood Blvd 

P.O. Box 200 

Mail Code D800-0018 

Long Beach, CA 90846-0200 

(b) Sections of 14 CFR from which an Exemption is Requested 

Boeing is seeking an exemption from the following sections of 14 CFR for the Model 

747-400 LCF: 

14 CFR 25.791(a)(b), Amendment 25-32 effective May 1, 1972, requires, in part, 

that when installed, signs notifying when smoking is prohibited and when safety 

belts should be fastened must be legible to each seated occupant in the passenger 

cabin and be operable by the crew.

14 CFR 25.807(b) introductory sentence, Amendment 25-55 effective April 28, 

1982, requires, in part, that each required passenger emergency exit must be accessible 

to the passengers and must be located where it will afford the most effective means of 

passenger evacuation. 

14 CFR 25.807(c)(1),(c)(5), Amendment 25-55 effective April 28, 1982, requires, 

in part, that for passenger seating configuration of one through nine (1-9) that there 

must be one Type IV over wing emergency exit in each side of the fuselage otherwise 

the exit in each side of the fuselage must be a Type III size or greater. 

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14CFR 25.807(c)(6), Amendment 25-55 effective April 28, 1982, requires, in part, 

that excess emergency exits in the passenger compartment must be readily 

accessible and meet the requirements of 14 CFR 25.809 thru 25.812. 

14 CFR 25.809(f)(1), Amendment 25-34 effective December 31, 1972, requires, in 

part, that each passenger emergency exit greater than six (6) feet from the ground 

must have an automatically deployed slide or equivalent to assist the occupants in 

reaching the ground with landing gear leg(s) collapsed. 

14 CFR 25.813(f), Amendment 25-46 effective December 1, 1978, requires, in 

part, that doors utilized to reach any required emergency exit from any seat in the 

passenger cabin must be latched open. 

14 CFR 25.857(e), Amendment 25-93 effective March 19, 1998, requires, in part, 

when a Class E cargo compartment is installed on the airplane, the airplane is 

used for carriage of cargo only. 

14 CFR 25.1447(c)(1), Amendment 25-41 effective Sept. 1, 1977, requires, in 

part for operations above 25, 000 feet, the oxygen dispensing system must be 

immediately available to each seated occupant and automatically presented. The 

number of dispensing units must be greater than 10 percent of the number of seats 

and uniformly distributed throughout the cabin. 

Related Sections of 14 CFR and 747-400 LCF G-1 issue paper: 

14 CFR 25.805, Amendment 25-0 effective November 3, 1964 requires, in part, 

that except for aircraft with less than 20 passengers that have convenient and readily 

accessible passenger exits for flight crew evacuation, there must be either one exit on 

each side of the airplane or a top hatch, in the flight crew area. 

14 CFR 25.807(b)(1),(b)(2), Amendment 25-55 effective April 28, 1982 requires, 

in part, that exit openings larger than specified may be used if the specified opening 

can be inscribed within the opening and the base of the inscribed opening meets the 

specified step-up and step-down heights. 

14 CFR 25.809(f)(2), Amendment 25-34 effective December 31, 1972, requires, in 

part, that each flight crew emergency exit greater than six (6) feet from the ground 

that the assisting means may be a rope or any other means demonstrated to be suitable 

for the purpose. 

14 CFR 121.583(a), Amendment 121-298 effective July 10, 2003 provides, in 

part, for categories of persons that may be carried aboard an airplane in part 121 

service without complying with all passenger-carrying airplane requirements of 

part 121. 

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Exception to 14 CFR 25.365: 

The 747-400 LCF G-1 issue paper utilizes, in part, as a mitigating feature (in 

order to retain the certification basis for 14 CFR 25.365 at the 747-400 

certification basis) the fact that there is a reduced exposure to the threat of 

explosive devices as there are no passengers. 

Special Conditions 25-61-NW-1, 25-71-NW-3: 

The 747-400 LCF G-1 issue paper states that the above listed special conditions 

are not part of the aircraft certification basis since there are no passengers and no 

passenger accommodations. 

Equivalent Safety Findings to 14 CFR 25.815: 

The 747-400 LCF G-1 issue paper states that the 14 CFR 25.815 Equivalent 

Safety Finding (ESF) does not apply to the LCF since there are no passenger and 

no passenger seats. 

(c) Extent of Relief and Reason 

Extent of Relief Sought

As provided in 14 CFR 11.61(b), Boeing hereby petitions for exemption from 14 CFR 

sections 25.791(a),(b); 25.807(b),(c)(1),(c)(5),(c)(6); 25.809(f)(1); 25.813(f); 25.857(e) 

and 25.1447(c)(1) as noted above to allow the carriage of two (2) persons 

(supernumeraries) other than flight crew to occupy the observer seats located within the 

flight deck of the 747-400 LCF. 

Information to Support Grant of Exemption

1. Occupancy of the LCF is a maximum of four (4) persons, two (2) of whom are 

requested to be non-crewmembers. In support of this request, the Airplane Flight Manual 

(AFM) will be revised to limit the carriage of supernumeraries to persons as defined in 14 

CFR 121.583 (a)(1) through (7). This limitation shall include the requirement for the 

operator to ensure that the occupants are properly trained and briefed on the evacuation 

system and that the occupant is physically able to utilize the escape means as determined 

by the operator {14 CFR 121.583(b) through (d)}. 

2. Evacuation harnesses for each occupant which are suitable for egress through the 

overhead hatch will be installed in the crew accommodation area. 

3. Supernumeraries are located in the flight deck and as such, they are located within 

visual and aural range of the flight crew. Through verbal instruction, and observation of 

the crew, the supernumeraries would clearly understand what actions are acceptable and 

required. The low ratio (1:1) of crew to supernumeraries provides adequate leadership 

and control during an emergency evacuation. 

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4. Boeing proposes that supernumerary training coupled with the close proximity to flight 

crew members provides a level of safety equivalent to 14 CFR 25.791(a),(b). 

5. The upper deck flight crew overhead emergency exit hatch meeting the requirements 

of 25.805 and 25.809(f)(2) provides a readily accessible and effective means of 

evacuation for two (2) flight crew and two (2) supernumeraries within the flight deck. 

This is based on granted exemptions on other 747 freighter (ref. section g) which has 

previously designated the overhead exit as an emergency exit for the use of persons other 

than crew members. In addition, evacuation of eight (8) occupants through the 747-400F 

overhead exit was demonstrated as described in test report D6U10195. The 

demonstration showed two (2) crew and six (6) supernumeraries were able to evacuate 

through the overhead exit of the upper deck using evacuation harnesses and inertia reels 

in 71.4 seconds. By comparison, the LCF will have a maximum occupancy of four (4) 

persons. Boeing proposes that the flight crew emergency exit provides a level of safety 

equivalent to 14 CFR 25.807(b),(c)(1),(c)(5), 25.809(f)(1). 

6. The current LCF is equipped with the flight deck overhead hatch as the means of 

egress using inertial reels. The main deck exits are utilized as required planned ditching 

exits. The main deck Door 1L has retained the passenger slide/raft meeting the 

requirements of 25.809(f)(1) and Door 1R is equipped with an escape rope with an 

additional portable life raft stored nearby. The slide/raft at Door 1R was removed to 

provide adequate space at the foot of the ladder to enable unrestricted descent/ascent. 

Boeing proposes that this emergency exit combination provides adequate escape means 

for the four (4) occupants (2 flight crew, 2 supernumeraries) and requests an exemption 

from 14 CFR 25.807(c)(6) and 14 CFR 25.809(f)(1) at Door 1R. 

7. The current LCF is equipped with a ladder enclosure door to preclude occupants from 

accidentally falling down the ladder while moving about the confined crew 

accommodation area. In addition, the closed door aids in smoke evacuation and reduces 

the probability of smoke penetration. The ladder door is required to be latched when not 

in use and must remain closed during taxi, takeoff, flight and landing. The ladder door is 

expected to be used for normal airplane entry/exit and for a planned ditching scenario. A 

planned ditching event has not been recorded in the history of aviation and hence, is 

highly unlikely. In addition, it is unlikely during a planned ditching with water 

displacement that the fuselage would deform to such an extent that the ladder door would 

become jammed and be rendered unusable. The ladder door is located on the upper deck 

with a large amount of structure beneath which must deform prior to the door jamb 

structure deforming. In the remote chance that the door becomes jammed, as a back-up, 

the ax required by 14 CFR 121.309(e) can be used to break the latch and/or hinge to get 

the door open. If the door was latched open, the likelihood of occupants falling down the 

ladder would greatly increase. This is contrasted with the unlikelihood of the door 

jamming during a planned ditching scenario. Boeing proposes that the ladder door in the 

closed position provides more protection for the limited number of deck occupants than 

would be provided with the ladder door in the open position and requests an exemption 

from 14 CFR 25.813(f). 

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8. The LCF has Class E cargo compartments as granted in Exemptions 8769/8769A/ 

8769B. The compartments can only be accessed through the cargo doors while on the 

ground. The cargo compartments are physically separated from the occupiable area by a 

pressure bulkhead. In the event of a fire in a cargo compartment, there is no procedure to 

depressurize the occupied compartments. The flight deck area complies with the smoke 

penetration requirements and crew type oxygen is provided for each seat. 

Supernumeraries are provided the same level of protection as the flight crew members 

during a fire. Boeing proposes that an exemption be granted to 14 CFR 25.857(e) to 

allow the carriage of supernumeraries. This would be consistent with other exemptions 

granted for cargo aircraft with Class E compartments (ref. section g). 

9. The LCF has crew type oxygen provisions for all seats in the flight deck for 

ground/flight operations (taxi, takeoff, cruise, descent and landing). The masks are 

installed in a readily accessible location that is visible to the occupants, and are of the 

quick-donning variety. A single motion removes the mask from its stowage, which is 

directly comparable to passenger oxygen dispensing units. Notification that oxygen is 

necessary is by aural signal and visual of flight crew actions, as opposed to automatic 

presentation of the masks. Additional passenger type oxygen drops with automatic 

presentation are provided inside the crew rest, lavatory and galley area. Boeing proposes 

that the crew type oxygen with flight crew indication of when oxygen is needed provides 

a level of safety equivalent to 14 CFR 25.1447(c)(1) for automatic presentation. 

10. A ten percent excess of the required oxygen provisions is also required by 14 CFR 

25.1447(c)(1). Extra oxygen within the passenger cabin is typically required enable 

cabin attendants to move freely about while aiding passengers with donning of their 

oxygen masks. The LCF supernumeraries are trained and will not require assistance 

with donning their masks. Boeing proposes that excess oxygen masks are not required 

and that an exemption to 14 CFR 25.1447(c)(1) for the required ten percent excess 

oxygen provisions be granted. 

11. The 747-400 LCF G-1 issue paper utilizes, in part, as a mitigating feature (in order to 

retain the certification basis for 14 CFR 25.365 at the 747-400 certification basis) the fact 

that there is a reduced exposure to the threat of explosive devices as there are no 

passengers. If this exemption is granted, there still will not be any passengers aboard the 

aircraft. Boeing proposes that the carriage of two (2) supernumeraries who are a special 

class of persons limited to those persons listed in 14 CFR 121.583 will not materially 

change the argument presented in the G-1 issue paper and that 14 CFR 25.365 will 

remain at amendment 25-53. 

12. The 747-400 LCF G-1 issue paper states that Special Conditions 25-61-NW-1 and 25-

71-NW-3 are not part of the aircraft certification basis since there are no passengers and 

no passenger accommodations. If this exemption is granted, there still will not be any 

passengers aboard the aircraft. Boeing proposes that the carriage of two (2) 

supernumeraries who are a special class of persons limited to those persons listed in 14 

CFR 121.583 will not materially change the argument presented in the G-1 issue paper 

and that these special conditions are not applicable to the LCF. 

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13. The 747-400LCF G-1 issue paper states that the 14 CFR 25.815 Equivalent Safety 

Finding (ESF) does not apply to the LCF since there are no passenger and no passenger 

seats. If this exemption is granted, there still will not be any passengers or standard 

passenger seats aboard the aircraft. Boeing proposes that the carriage of two (2) 

supernumeraries who are a special class of persons limited to those persons listed in 14 

CFR 121.583 will not materially change the argument presented in the G-1 issue paper 

and that the 14 CFR 25.815 ESF does not apply. 

(d) Statement of Public Interest 

The public interest would be advanced by the grant of this petition since flexibility in the 

LCF aircraft missions would increase its efficiency and in turn, maintain or lower the 

costs associated with the aggressive manufacturing and delivery schedule for the Boeing 

Model 787 airplane. More efficient use of the LCF will reduce the cost associated with 

manufacturing and minimize delays associated with transporting mission-critical parts 

and personnel. This is most efficiently accomplished by carrying mission critical 

personnel on the particular cargo flight they are supporting rather than taking separate 

commercial flights that may not have the same schedule while incurring additional 

transportation expenses. 

The 787 is more fuel efficient as compared to other airplanes currently in service. The 

sale of 787s contributes to a healthier environment through the replacement of less fuel 

efficient airplanes. The 787 relies on the 747-400 LCF to maintain this tight schedule 

and disruption in the LCF operations can cause delays to the 787 production delivery 

schedule. Given the large volume of international sales of the 787, this would impact 

commerce worldwide. Maintaining the 787 delivery schedule could result in increased 

sales thus helping to supply the public need for increased air travel for passenger carrying 

capacity. The availability of reliable, cost efficient, and timely transportation of 787 part 

assemblies will contribute to the competitive position of air transport manufactures in the 

United States and to the balance of trade, gross domestic product and economic health of 

the United States. In addition to creation of jobs and promotion of United States 

commerce, the 747-400 LCF global transportation system contributes to the 

competitiveness of US state of design airplanes in the global market through the use of 

lean manufacturing on a global level. More efficient manufacturing and transportation 

reduces reliance on fossil fuel sources and promotes a cleaner and healthier environment. 

These are all in the public interest, and the design proposed in combination with these 

petitions maintains the current level of safety. 

(e) Reasons why Granting the Exemption Would Not Adversely Affect Safety 

Boeing maintains that the carriage of supernumeraries would not adversely affect the 

safety of the aircraft. Supernumeraries are provided an equivalent or better level of 

safety afforded the flight crew through the usage of the existing required flight crew 

safety systems on the 747-400 LCF and the usage of additional emergency evacuation 

harnesses provided for all LCF occupants. 

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This includes the following considerations: 

The fleet of 747-400 LCF aircraft is small due to their special use. They are designed to 

carry non-flammable aircraft components per Exemptions 8769/8769A/8769B. Due to 

their special use, the aircraft are not used to conduct commercial freight hauling 

operations by its 14 CFR Part 121 operator. The supernumeraries will be limited to those 

persons who meet the requirements of 14 CFR 121.583(a)(1) through (7) as noted in the 

747-400 LCF AFM. In addition, the AFM will include the requirement that 

supernumeraries are physically fit as determined by the operator, and briefed on the usage 

of their emergency equipment and means of egress prior to each flight {14 CFR 

121.583(b) through (d)}. These AFM limitations restrict the aircraft’s usage such that the 

LCF cannot carry passengers for hire. 

(f) Summary for Publication in the Federal Register 

Rule from which the exemption is being sought: 

In accordance with 14 CFR 11.61(b), the Boeing Company hereby petitions for an 

exemption from the requirements of 14 CFR sections 25.791(a),(b); 25.807(b),(c)(1), 

(c)(5),(c)(6); 25.809(f)(1); 25.813(f); 25.857(e) and 25.1447(c)(1) to allow the carriage of 

two (2) persons (supernumeraries) other than flight crew who may occupy the observer 

seats located within the flight deck of the 747-400 LCF. The FAA previously granted 

similar exemptions to these requirements to allow for the carriage of limited persons 

(supernumeraries) on aircraft with a Class E cargo compartment and allowing egress 

through the flight crew emergency hatch on a range of 747 freighter models: 

1870/1870A/1870B/1870C/ 1870D/1870E & 9735 for 747-100(SF)/-200F/-200C/-

200(SF)/-400F, Exemptions 8590/8590A/8590B for 747-400SF (747-400BCF), and 

Exemptions 9793/ 9793A/9793B for 747-8. 

Brief description of the nature of the exemption: 

Boeing has converted a small fleet of 747-400 passenger aircraft into 747-400 Large 

Cargo Freighters (LCF). These aircraft are designed to carry non-flammable aircraft 

components per Exemptions 8769/8769A/8769B primarily in support of the 787 

production. Due to their special use, the aircraft are not used to conduct commercial 

freight hauling operations by its 14 CFR Part 121 operator. The LCF flight deck has 

retained the four (4) approved flight deck seats from the original 747-400 series 

passenger model. These flight deck seats are currently restricted to flight crew use only: 

pilot, co-pilot and two (2) observer seats. 

In order to increase the mission efficiency of the LCF, carriage of persons other than 

crew is required. More efficient usage of the LCF will reduce the cost and time delay 

associated with transporting mission-critical personnel via commercial flights to the 

cargo destination they are intended to support. The most cost-effective way to transport 

such personnel is aboard the particular cargo flight they are to support. 

 

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This requires an exemption from 14 CFR part 25, sections 25.791(a),(b); 25.807(b), 

(c)(1),(c)(5),(c)(6); 25.809(f)(1); 25.813(f); 25.857(e) and 25.1447(c)(1) to allow for 

carriage of two (2) supernumeraries utilizing the existing observer seats located in the 

flight deck. 

The 747-400 LCF Airplane Flight Manual will include a limitation that the carriage of 

supernumeraries must meet the requirements of 14 CFR 121.583(a)(1) through (7). In 

addition, the AFM will include the requirement that supernumeraries are physically fit as 

determined by the operator, and briefed on the usage of their emergency equipment and 

means of egress prior to each flight {14 CFR 121.583(b) through (d)}. These AFM 

limitations restrict the aircraft’s usage such that the LCF cannot carry passengers for hire. 

The public interest would be advanced by the grant of this petition since flexibility in the 

LCF aircraft missions would increase its efficiency and in turn, maintain or lower the 

costs associated with the aggressive manufacturing and delivery schedule for the Boeing 

Model 787 airplane. More efficient use of the LCF will reduce the cost associated with 

manufacturing and minimize delays associated with transporting mission-critical parts 

and personnel. This is most efficiently accomplished by carrying mission critical 

personnel on the particular cargo flight they are supporting rather than taking separate 

commercial flights that may not have the same schedule while incurring additional 

transportation expenses. 

The 787 is more fuel efficient as compared to other airplanes currently in service. The 

sale of 787s contributes to a healthier environment through the replacement of less fuel 

efficient airplanes. The 787 relies on the 747-400 LCF to maintain this tight schedule 

and disruption in the LCF operations can cause delays to the 787 production delivery 

schedule. Given the large volume of international sales of the 787, this would impact 

commerce worldwide. Maintaining the 787 delivery schedule could result in increased 

sales thus helping to supply the public need for increased air travel for passenger carrying 

capacity. The availability of reliable, cost efficient, and timely transportation of 787 part 

assemblies will contribute to the competitive position of air transport manufactures in the 

United States and to the balance of trade, gross domestic product and economic health of 

the United States. In addition to creation of jobs and promotion of United States 

commerce, the 747-400 LCF global transportation system contributes to the 

competitiveness of US state of design airplanes in the global market through the use of 

lean manufacturing on a global level. More efficient manufacturing and transportation 

reduces reliance on fossil fuel sources and promotes a cleaner and healthier environment. 

These are all in the public interest, and the design proposed in combination with these 

petitions maintains the current level of safety. 

Boeing maintains that the proposed airplane configuration in conjunction with 

supernumerary carriage limitations will result in a comparable level of airplane safety to 

that of an airplane designed to only carry flight crew as required by 14 CFR, Part 25. The 

carriage of supernumeraries has been approved on multiple large transport airplane 

designs and has not adversely affected the safety of the aircraft. Supernumeraries are 

provided an equivalent or better level of safety afforded the flight crew through the usage 

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of the existing required flight crew safety systems on the 747-400 LCF and the usage of 

additional emergency evacuation harnesses provided for all LCF occupants. 

Boeing therefore requests that an exemption be granted to allow the carriage of up to two 

(2) persons other than flight crew (supernumeraries) lieu of four (4) crewmembers only. 

(g) Additional Information in support of the Exemption Request 

Boeing requests that the FAA not publish a summary and not request comments for this 

petition for exemption because the relief requested is similar to exemptions granted 

previously in Exemptions 1870/1870A/1870B/1870C/ 1870D/1870E & 9735 for 747-

100(SF)/-200F/-200C/-200(SF)/-400F, Exemptions 8590/8590A/8590B for 747-400SF 

(747-400BCF), and Exemptions 9793/ 9793A/9793B for 747-8 which allows for the 

carriage of limited persons (supernumeraries) on cargo aircraft with egress through the 

flight crew emergency hatch. 

Additional Proprietary information will be submitted to the cognizant FAA Directorate 

for review. 

(h) Application of Exemptions Outside of the United States 

This exemption applies to the type design for a transport airplane designed to transport 

major assemblies built outside of the United States. The privileges for this exemption 

for this aircraft are necessary to be made available outside of the United States in order 

to recognize the economic benefit of this means of air transport. 

Enclosure (A) to RA-12-04908 

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