._~ ._. EASTERN 

September 14,2015 

PetiHon 

For Exemption of 

121.1117 Flammability reduction means 

Eastern Air lines Group, Inc. is a Supplemental Air Carrier with a mailing address of: 

Eastern Air Lines Group, Inc. 

P.O. Box 526865 

Miami, Florida 33152 

Eastern was certified according to 14 CFR 119.21 (a)(3} on May 13,2015 with one B 737-8AL 

aircraft, Registration N276EA. This aircraft met the certification compliance requirements 

of 14 CFR 121 .1117 because a NGS was installed prior to certification. 

A second airplane N277EA was added to the 0085 Operation Specification July 29,2015. 

A NGS kit had been purchased for this aircraft and was ready for installation but the aircraft 

had been delayed in "8Y" Check by approximately seven weeks (this check wasn't 

controlled by Eastern} and Eastern didn't take possession of the aircraft until July 10, 2015. 

Because Eastern had commercial business that had been contracted for, Eastern elected 

not to delay the check by a further 20 days to install the NGS system. Further and as a result 

of this delay, the purchased but not installed NGS kit was given back to Boeing so that kit 

could be installed on another carrier's aircraft. Eastern was given a credit for a future 

delivery of the NGS kit. With one aircraft fully compliant and the second aircraft not yet 

modified Eastern was in full compliance with 14 CFR 121.1117 ( e}} ( 1}. 

Eastern was now preparing to take delivery of its third aircraft, a B737-7L9, but now the 

delayed NGS kit could not be delivered in its entirety until late October. Commercial 

business had been contracted for this aircraft and it was arriving on the date originally 

specified by EAL. Even though it was not modified with the NGS system EAL would have 

been compliant with 14 CFR 121.1117(e)(1 J as originally planned because more than 50% 

of the EAL fleet were planned to be equipped with the NGS system. 

Eastern was fully aware of the compliance requirements of 14 CFR 121 .1117 and began 

pursuing all available means of compliance with the full assistance and support from CM0-

29. After exhausting all potential avenues that were available Eastern had no choice but 

to pursue an exemption to get the relief found in 14 CFR 121 .1117 (I} that was available to 

certificate holders that had applied for the relief contained in 14 CFR 121 .1117 (k} (2}. 

Accordingly, and In Accordance with 14 CFR Chapter l, Subchapter B, Part 11.81, on 

behalf of Eastern Air Lines, (EAL} a Supplemental Part 121 Air carrier, certificate number 

29EA847N, I am requesting exemption from 14 CFR, Chapter 1, Subchapter B, Part 

121 .1117(e), Flammability Reduction Means Compliance Times. 

EAL is requesting this exemption because we are unable to utilize the compliance time 

extension offered in Operations Specification Paragraph A570. Our formal request to have 

this paragraph added to our Operations specifications was denied because 121 .1117 has 

the following limitations; 

Eastern A r Lines Group. Inc. Mlam1 International Airport. 4200 fJW 36'' Street. Bldg. SA Mlam1. Flor1da 33166 

PO Box 526865 Mlam1. Flonda 33152 Tel: 305.869.4249 easternairlines.aero 
~EASTERN 

(k) The compliance dates specified in paragraph (e) of this section may be extended by 

one year, provided that-

( 1) No later than March 26, 2009, the certificate holder notifies its assigned Flight Standards 

Office or Principal Inspector that it intends to comply with this paragraph; 

(2) No later than June 24, 2009, the certificate holder applies for an amendment to its 

operations specification in accordance with § 119.51 of this chapter and revises the 

manual required by§ 121.133 to include a requirement for the airplane models specified 

in Table 2 of this section to use ground air conditioning systems for actual gate times of 

more than 30 minutes, when available at the gate and operational, whenever the 

ambient temperature exceeds 60 degrees Fahrenheit; and 

(3) Thereafter, the certificate holder uses ground air conditioning systems as described in 

paragraph (k) (2) of this section on each airplane subject to the extension. 

To support this request, EAL shall revise its General Maintenance Manual (GMM) to address 

121.1117 by adding verbiage from the rule into the GMM Chapter 18, Technical Operations 

Approved Programs. EAL will also place placards into flight decks of the effected aircraft 

that mandate ground operation of the Auxiliary Power Unit (APU) and environmental 

systems for 30 minutes or longer is not authorized when outside ambient temperatures are 

60 degrees Fahrenheit or higher. The EAL Vice President of Flight Operations will issue a 

bulletin to the flight crews to ensure the awareness of and compliance with these 

restrictions. 

In the event that effected EAL aircraft can utilize ground air conditioning systems at 

locations where it may be available and operationaL EAL will instruct flight crews that the 

aforementioned requirements remain in effect for actual ground or gate times of 30 

minutes or longer to ensure compliance with 121 .1117 and Operations Specifications 

paragraph A570. 

EAL will revise the effected training for flight crews and ground operations personnel to 

address the above requirements. All of the above commitments will be in place by 

September 15, 2015. 

The EAL aircraft effected by this extension are Boeing 737-8CX MSN 32359 N277EA and 

B737 7L9, MSN 28006 N674AC. EAL has made arrangements for and paid for the Nitrogen 

Generating System modification accomplished by December 26, 2015 on N277EA. This 

OEM modification will permit EAL to be in compliance with 121.1117 (e) (1 ). 

Eastern was unable to meet the requirements of 121.1117(k)(2) because EAL was not 

certificated until May 13, 2015. The first EAL aircraft, N276EA a B737-8 has been in 

compliance with 121 .1117 since our FAA Certification allowing EAL to comply with the 50% 

compliance requirement of 121.1117)(e))(1 ). 

Obviously the crofters of 121.1117 contemplated possible extension times because of 

manufacturing capabilities and potential other unforeseen reasons and allowed for this 

extension by adding the provisions contained in 121.1117(1). EAL does not wish to extend 

the dates allowed in 121.1117(e) with the issuance of Operations Specification A570 but 

rather, wishes to take advantage of that same extension which could not be issued 

because EAL did not exist as a certificate holder by the date the extension request was 

required. EAL however is in existence prior to the date that the extension would expire on 

December26, 2015 if it could have been issued. 

Eastern Ar L1nes Group. Inc Miami International Airport. 4200 NW 36" Street. Bldg. SA f\ ,a 1. Flonda 33166 

PO Box 526865 Mlam1. Flonda 33152 Tel: 305.869.4249 easternairlines.aero 
~EASTERN 

Because the majority of Eastern's flying is international we request this exemption for both 

domestic and international operations. 

To summarize, an equivalent level of safety is achieved by this request. The same number 

of compliant aircraft will be in the whole B 737 fleet in the United States and EAL will not be 

penalized financially because of a regulation that didn't contemplate carriers certificated 

after June 24, 2009. Eastern is asking for a short term exemption from 121.1117(e) until 

December 26, 2015 or the issuance of Operations Specification A570. Eastern feels that this 

request is justified because FAR 121.1 117 did not provide alternatives for operating 

certificates that were issued after June of 2009 as it did for certificates issued prior to June 

of 2009. 

EAL is confident the above commitments are more than sufficient to ensure compliance 

with 121 .1117 and will assure a level of safety equal to or greater than the intent of this 

regulation. 

Sincerely, 

~~/~ Robert Scaglione 

Eastern Airlines 

Chief lnspector/DQC 

Eastern A r Ltnes Group. Inc. Mtamt lnternattonal Atrport. 4200 f JW 36" Street. Bldg. SA M:amt. Flortda 33166 

PO Box 526865 Mtami. Flonda 33152 Tel: 305.869.4249 easternairlines.aero