( ^ 

Ronald J. Hind«rb«rg*r The Boeing Company 

Lead Administrator P.O. Box 3707 MC 03-52 

Delegated Compliance ()rc) Seattle, WA 98124 -2207 

Commercial Airplane?; 

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UW; 2 0 2010 ... if.0-3:) 

BDCO-10-05416 \ \ '^^S ^ 

U.S. Department of Transportation -^^ 

Docket Management System '-r1200 New Jersey Avenue, SE ^^ 

West Building Ground Floor, Room W12-140 ^-' 

Washington, D.C. 20590 

Subject: Petition for Exemption from Title 14 Code of 

Federal Regulations section 25.1309(c) at 

Amendment 25.116 with Respect to Crew 

Annunciation of the Status of Fuel System 

Components 

Model: 787-8 

The Boeing Company respectfully submits this petition for exemption from 

specific aspects of Title 14 Code of Federal Regulations Section 25.1309(c) at 

Amendment 25.116 for a limited number of General Electric (GE) GEnx-lB 

powered 787-8 airplanes as described in the summary below. The enclosure to 

this letter provides the details of the petition in accordance with Title 14 Code of 

Federal Regulations Section 11.81. The following summary is provided for the 

Federal Register in accordance with 14 CFR Section 11.81(f). 

Summary for Federal Register 

Petitioner: The Boeing Company. 

Section of 14 CFR Affected: Section 25.1309(c). 

Description of Relief Being Sought: 

Boeing is requesting relief from full compliance to Section 25.1309(c) for the 

General Electric (GE) GEnx-lB powered 7S7-S aiiplanes for the unambiguous 

and timely indication to the flight crew to aleil them of an anticipated fuel system 

contamination. If granted, this exemption will allow sufficient time for Boeing to 

develop, certify and incorporate into production a new alerting system this is 

fully compliant with Section 25.1309(c). The exemption would allow relief from 

the requirement in Section 25.1309(c) to provide indication to the crew of 

anticipated fuel system contamination for General Electric GEnx-lB powered 

787-S aitplanes delivered up to June 30. 2014 and December 31. 2018 for retrofit 

incoiporation. 
^ . Page 2 

Docket Management Svstem 

BDCO-10-05416 

Very tally yours, 

/Christine Thompson 

iLead Project Administrator, Development Projects 

1:425) 266-6572, MC 03-56 

FAX: (425)294-9340 

Enclosure: Petition for Exemption from 14 CFR 25.1309(c) at Amdt. 25-116 

cc 

Name 

Ali Bahrami 

Ken Schroer 

Sherry Vevea 

Tom Thorson 

David Solar 

Ken Fontaine 

Letter 

EDT 

EDT 

EDT 

EDT 

EDT 

EDT 

Enclosures 

EDT 

EDT 

EDT 

EDT 

EDT 

EDT 

Comments 

ANM-IOOS 

ANM-IOOS 

ANM-140S 

ANM-140S 

EASA Panel 0 

EASA Panel 7 
Enclosure to BDCO-10-05416 

Page 1 of 6 

Petition for Exemption from 14 CFR 25.1309(c) Amendment 25-116 for General Electric 

GEnx-lB Powered 787-8 Airplane, FAA Project Number PS06-0414 

Name and Address of the Petitioner 

CM. Thompson, Manager, Lead Project Administrator, Development Projects 

The Boeing Company, 

PO Box 3707, 

Seattle, Washington, 98124 

B. Section of the Code of Federal Regulations (CFRs) that are affected 

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

following CFRs: 

Regulation 

14 CFR 

25.1309(c) 

At 

Amendment 

116 

Which Requires 

(c) Warning Information must be provided to alert the 

crew to unsafe system operating conditions, and to 

enable them to take appropriate corrective action. 

Systems, controls, and associated monitoring and 

warning means must be designed to minimize crew 

errors which could create additional hazards. 
Enclosure to BDCO-10-05416 

Page 2 of 6 

The extent of relief being sought 

Regulation 

14 CFR 

25.1309(c) 

Amendment 

120 

Requires: 

The FAA has 

determined to comply 

with §25.1309(c) for 

the General Electric 

GEnx-lB fuel system, 

an unambiguous and 

timely Indication to the 

flight crew is required 

to alert them of an 

anticipated fuel 

system contamination. 

The purpose of this 

Indication is to enable 

the flight crew to take 

appropriate corrective 

action. 

Relief Is necessan/ because: 

The 787-8 / GEnx-1 B engine will be one of 

the first General Electric engines to 

incorporate a method to detect gross fuel 

system contamination. The FAA only 

recently provided guidance regarding what 

Is needed to show compliance to 

§25.1309(c) for indication of Impending 

bypass of a component upstream of the 

main fuel filter. Therefore, It would create a 

significant burden If Boeing were now 

required to Incorporate this new gross fuel 

system contamination indicatlon(s) on the 

first production 787-8 airplanes prior to Type 

Certification. 

For the 787-8 fuel systems to comply with 

§25.1309(c), an unambiguous and timely 

indication to the flight crew Is required In the 

event that both engines on the same flight 

are subjected to a fuel filter Impending 

bypass condition. Further, to comply with 

§25.1309(c), the flight crew must be alerted 

of anticipated fuel system contamination 

that could clog the fuel system ahead of the 

engine fuel filter. The purpose of this 

Indication Is to enable the flight crew to take 

appropriate corrective action. 

With this petition for exemption, Boeing Is 

requesting relief for a limited number of 787-

8 airplanes to allow sufficient time to 

develop, validate, certify and Incorporate 

Into production a new compliant gross fuel 

system contamination Indicatlon(s). 

Following Incorporation of the compliant 

Indication into production airplanes, Boeing 

will Issue a service bulletin that 

recommends all airplanes delivered under 

this time limited exemption be retrofitted. 

Description of relief sought: The requested 

time-limited exemption will allow the Boeing 

Model 787-8 relief from the requirement of 

§25.1309(c) for an unambiguous and timely 
Enclosure to BDCO-10-05416 

Page 3 of 6 

Indication to the flight crew of gross fuel 

system contamination. 

The relief sought Is limited to those 787-8 

aircraft completed prior to the production 

incorporation of the compliant message. 

The production Incorporation of the 

compliant message will first be 

accomplished by June 30, 2014. A service 

bulletin will be available no later than June 

30, 2014 such that all 787-8 airplanes 

delivered under this exemption can order 

parts and Install a compliant configuration. 

The Boeing service bulletin will recommend 

that all airplanes be retrofitted by December 

31,2018. 
Enclosure to BDCO-10-05416 

Page 4 of 6 

Description of the Issue 

The FAA recently clarified what is required to show compliance to §25.1309(c) for Indication of 

gross fuel contamination. Given the advanced stage of the 787-8/GEnx-1 B program relative 

to gaining basic type design certification, Boeing is requesting this time-limited exemption to 

enable a robust, reliable design and verification of the subject alerting. Boeing agrees that 

severe fuel system contamination can lead to undesirable engine effects, such as loss of 

thrust. 

The FAA has found the 787-8/GEnx-1 B design to be non-compliant to §25.1309(c) for this 

Issue. This FAA position Is based on the lack of an unambiguous and timely annunciation to 

the flight crews of gross contamination of the airplane fuel supply. The GEnx-1 B fuel system 

components that have the potential to become clogged by ice or fuel contaminants are each 

designed with bypasses to ensure maintained commanded fuel flow to the engine. The 

engine fuel Indication system does not currently directly address the basic problem of gross 

fuel system contamination Indication. 

Prior to the expiration of this time-llmlted exemption, Boeing Intends to comply with these 

requirements by providing a flight deck Indication of gross fuel system contamination using a 

sensor upstream of the main fuel filter. Additionally, Boeing will elevate the existing EICAS 

flight deck alert for a multiple-engine fuel filter Impending bypass condition. 

Statement of No Adverse Affect on Safety 

The GEnx-lB engine fuel system design allows for the greatest possible tolerance to gross 

fuel contamination. Excessive fuel system component blockage of the GEnx-1 B engine does 

not limit fuel flow to the engine due to multiple bypasses In the design. 

The main fuel filter Is sized for compliance to §33.67 and subsequently §25.997(d). The fuel 

strainer at the LP pump exit provides additional filtering capability for the system. The fuel 

strainer Is sized to protect the heat exchangers and high pressure fuel pump gear stage from 

extreme / maintenance-Induced contamination. The fuel strainer does not stop particles that 

are within the size range of expected contamination. This contamination Is passed through 

the eductor pump and the heat exchangers to the filter. When the filter is exposed to 

contaminated fuel and debris accumulates to the point that It reaches impending blockage, an 

alert Is provided to the flight deck via an advisory level message according to the requirements 

of §25.1305(c)(6). The GEnx-lB fuel system Indications provide flight crew warning 

information that an unsafe operating condition may exist via the main fuel filter advisory-level 

messages. This alerting scheme provides an adequate level of safety for the airplanes 

affected by this exemption. This is the same fuel filter alerting on all Boeing production 

airplanes. 

The existing GEnx engine also Incorporates a differential pressure sensor across the fuel 

strainer that under certain conditions provides EICAS Status messages and CMC messages 

for additional awareness beyond any previous GE powered airplane model. 
Enclosure to BDCO-10-05416 

Page 5 of 6 

Service history studies conducted showed that the fuel strainer/ filter architecture used on 

GE90, GE90-115B, CF6-6, CF6-50, CF6-80A, CF6-80C2, and CF6-80E engines (similar 

architecture of the GEnx-1 B engine) have had no known IFSD or power Interruption events 

attributed to fuel strainer clogging. 

The proven service history of similar engine models, the maintenance actions defined to 

preclude the Introduction of solid contamination into the fuel tanks and the existing flight deck 

messages and crew procedures from associated checklists provide an adequate level of 

safety for the airplanes affected by this exemption. 

Statement of Public Interest 

Granting this petition Is In the public's Interest because It would allow adequate time for Boeing 

and Its supplier to develop an effective design solution to the requirement to add a flight deck 

Indication of gross fuel system contamination that became applicable to the Model 787-8 well 

after the airplane development program completed firm configuration of the 787-8. 

Conversely, If the requested relief Is not granted the addition of the subject flight deck 

Indication at this late stage of the airplane development program would lead to delays In the 

deliveries of Model 787-8 airplanes. The public Interest will be advanced by the grant of 

Exemption as It is In the best economic Interest of the United States. Many 787-8 customers 

are overseas. Further delivery delays of the 787-8 are not In the Interest of the public due to 

the potential negative Impact to export sales, the balance-of-trade, the gross domestic product 

and economic health of the United States. 

In addition, without adequate time to develop a robust solution, nuisance flight deck alerts inservice have the potential to reduce operational safety when flight crews are tasked to respond 

to false indications potentially resulting in unnecessary flight diversions, landing at airports that 

they are not familiar with, and conceivably, shutting down an engine unnecessarily. 

Availability of 787-8 airplanes with the GEnx-lB engines will reduce fuel burn and hence 

reduce emissions of carbon dioxide, reduce global emissions of NOx, and reduce operating 

costs of airlines. 

Request for Waiver of Publication 

The petitioner requests that this petition for exemption not be delayed by the public process, 

which Includes publication of the subject petition, due to the fact that this exemption will not set 

a precedent. Boeing believes good cause exists to waive the publication and comment 

requirements of §11.85, §11.87, and §11.89. 

The 787-8 petition is being provided in a timely manner; however, due to the scheduled 

delivery of the first 787-8 in 2011, a delay In processing of the Exemption could delay the entry 

Into service. 
Enclosure to BDCO-10-05416 

Page 6 of 6 

H. Privileges of this Exemption Outside the United States 

Per §11.81(h), Boeing requests that the privileges of this Exemption be extended outside the 

United States. This extension of privileges is necessary for operations based within foreign 

countries having bilateral agreements with the United States accepting FAA 14 CFR Part 25 

as their airworthiness standards for transport category aircraft. The 787-8 Is Intended for the 

global market place with a launch customer based In a country utilizing the United States 

airworthiness standards. 

I. Conclusion 

The requested time-limited exemption will allow the Boeing Model 787-8 relief from the 

requirement of §25.1309(c) for an unambiguous and timely indication to the flight crew of 

gross fuel contamination. 

The relief sought Is limited to those 787-8 aircraft completed prior to the production 

Incorporation of the compliant message. The production incorporation of the compliant 

message will be accomplished by June 30, 2014 delivery and all subsequent 787-8 airplanes. 

The Boeing Service Bulletin will recommend that all 787-8 airplanes delivered under this 

exemption be retrofitted by December 31, 2018. 

As discussed above, passenger and crew safety will not be appreciably affected by a grant of 

exemption In this case.