~OEING 

MAY 0 4 2012 

RA-12-01946 

Ronald J. Hinderberger 

Lead Administrator 

Designated Compliance Org. 

Commercial Airplanes 

The Boeing Company 

P.O. Box 3707 MC 03-52 

Seattle, WA 98124-2207 

U.S. Department of Transportation 

Docket Operations . West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Subject: 

Model: 

RA Project No.: 

EASA Project No.: 

EASALevel: 

Branch/Panel No.: 

Revised Petition for Exemption from 14 CFR 

25.562(b)(2), Amendment 25-64, Flight Deck 

Floor Warpage 

767-2C 

PS09-0863 

N/A 

NIA 

ANM-106B 

U1 

Branch!Pahel Name: · Certification Sel'Vices · 

Response Due: August 3rd, 2012 

Reference(s): (a) Regulatory Docket No. FAA-2004-16974, 

FAA Exemption No. 8269, March 12,2004, 

Boeing 767-200C Floor Warpage for Flight 

Deck Seats, Exemption from FAR 

25.562(b)(2) 

(b) Regulatory Docket No. 26649, FAA 

Exemption No. 5436, April1, 1992, FAA 

Exemption No. 5436A, January 3, 1997, 

· FAA Exemption 5436B, November 15, 

2000, Boeing 777-200/-300/-200LRI-300ER 

Floor Warpage for Flight Deck Seats, 

Exemption from FAR 25.562(b)(2) 

(c) RegulatoryDocketNo. 28452, FAA 

Exemption No. 6425, April12, 1996, 

. Boeing 737-600/-700/-800 Floor Warpage 

for Flight Deck Seats, Exemption from FAR 

25.562(b)(2) 

(d) Regulatory Docket No. 28744, FAA 

Exemption No. 6600, AprilS, 1997, Boeing 

757-300 Floor Warpage for Flight Deck 

Seats, Exemption from FAR 25.562(b)(2) 

(e) Regulatory Docket No. 29451, FAA 

Exemption No. 6935, August 4, 1999, 

Boeing 767-400ER Floor Warpage for 

Flight Deck Seats, Exemption from FAR 

25.562(b)(2) 
Special lnstru'Cti~ns: 

, TJJ,is letter is to submit: 

Page 2 

Mr. Xidias 

RA-12-01946 

(f) Regulatory Docket No. 28452, FAA 

Exemption No. 6425A, August 20, 1999, 

Boeing 737-700C/-900 Floor Warpage for 

Flight Deck Seats, Exemption from FAR 

25.562(b)(2) 

(g) Regulatory Docket No. 20049, FAA 

Exemption No. 9486, September 11, 2007, 

Boeing 787 Floor Warpage for Flight Deck 

Seats, Exemption from FAR 25.562(b)(2) 

(h) Boeing Regulatory Administration letter 

RA-12-01407, "Petition for Exemption from 

14 CFR 25.562(b)(2), Amendment 25-64, 

Flight DecK Floor Warpage," dated April . 6th 2012 

' 

Please replace the reference- (h) letter ;):V:it):l the 

subject submittaL - : <'~?X ' 

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,~~-(~)'Other: Revised submittal of Petition for Exemption from 14 CFR 

25.562(b)(2), Amendment 25-64, Flight Deck Floor Warpage 

This revised submittal eliminates verbiage from the cover letter that does not 

conform to the requirements for publishing a petition for exemption, and 

supersedes the reference (h) submittal. The enclosure to this submittal is 

identical to that enclosed in reference (h). As such, the petition from the 

reference (h) letter remains valid and there is no need to replace or revise the 

contents of docket no. FAA-2012-0405. 

The Boeing Company hereby petitions for an exemption for relief from the Floor 

Pitch and Roll Requirements of 14 CFR 25.562(b)(2) Amendment 25-64 for 

Flight Deck Seats on the Boeing Model 767-2C. 

To support the 767-2C ATC program schedule, The Boeing Company requests 

that the enclosed information be processed by August 3rd, 2012. Furthermore, 

The Boeing Company requests to be notified when the enclosed petition 

processing has completed. 

Waiver from Public Comment 

This petition will not set a precedent and accordingly, The Boeing Company 

respectfully requests a waiver from the publication and public comment period of 

this Exemption. The Boeing Company believes that good cause exists to waive 

the publication and comment requirements of 14 CFR 11.85, 11.87 and 11.89. 

This letter is being sent for: 

(X) Posting to the Federal Docket 

';, :_. 
~OEING Page 3 

Mr. Xidias 

RA-12-01946 

Please contact this office or the following individ,uals if you have further 

questions: 

Project Administrator (PA): 

Program Manager 

Certification Lead/Specialist: 

S. Gordon 

J. Flower 

G. Gillette 

425-237-6068 

206-715-1768 

425-266-7484 

The information being forwarded to the FAA by or with this correspondence is 

for the exclusive purpose of support of applications for or amendments to Type 

Certificates. 

Enclosure: Petition for Exemption from 14 CFR 25.562(b)(2) 

cc 

Name 

Jim Cashdollar 

Angelos Xidias 

Letter 

EDT 

EDT 

Enclosures 

EDT. 

EDT 

Comments 

ANM-106B 

ANM-100B 
Enclosure to RA-12-01946 

Petition for Exemption from 14 CFR 25.562(b)(2), Amendment 25-64, 

Boeing Model 767 -2C, Flight Deck Floor Warpage 

I A. Name and Address of the Petitioner 

Doug Lane, Director, Regulatory Administration Deputy Lead Administrator 

The Boeing Company, 

PO Box 3707, 

Seattle, Washington, 98124 

I 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 At Which Requires 

Amendment 

14 CFR 64 (b)(2) A change in forward longitudinal velocity (Delta V) of not less 

25.562(b)(2) than 44 feet per second, with the airplane's longitudinal axis 

horizontal and yawed 10 degrees either right or left, whichever 

would cause the greatest likelihood of the upper torso restraint 

system (where installed) moving off the occupant's shoulder, and 

with the wings level. Peak floor deceleration must occur in not more 

than 0.09 seconds after impact and must reach a minimum of 16g. 

Where floor rails or floor fittings are used to attach the seating 

devices to the test fixture, the rails or fittings must be misaligned with 

respect to the adjacent set of rails or fittings by at least 1 0 degrees 

vertically (i.e., out of parallel) with one rolled 1 0 degrees. 

I C. The extent of relief being sought 

Reaulation Reauires: Relief is necessarv because: 

14 CFR Where floor rails The testing would create an economic disadvantage for the 

25.562(b)(2) or floor fittings are 767-2C without a commensurate expectation of safety. The 

Amendment used to attach the FAA considers the floor warpage testing of flight deck seats is 

64 seating devices to not justified for an aircraft of this size and type. The FAA has 

the test fixture, the stated their intent to develop a proposal to amend the 

rails or fittings regulation accordingly. 

must be 

misaligned with Description of relief sought: Relief from the rail misalignment 

respect to the and roll test requirements of 14 CFR 25.562(b)(2) Amendment 

adjacent set of 25-64 for flight deck seats. 

rails or fittings by 

at least 10 

degrees vertically 

(i.e., out of 

parallel) with one 

rolled 1 0 degrees. 

Page 1 of4 
Enclosure to RA-12-01946 

I D. Description of the Issue 

The Boeing Company hereby petitions for an exemption for relief from the Floor 

Pitch and Roll Requirements of 14 CFR 25.562(b)(2) Amendment 25-64 for Flight 

Deck Seats on the Boeing Model 767 -2C. 

The 767 -2C is a commercially-offerable, freighter derivative version of the 767-200 

passenger airplane, and is the next Boeing aircraft that will comply with the 

requirements of 14 CFR 25.562, as stated in the G-1 Issue Paper. Accordingly, 

there are provisions of 14 CFR 25.562 which previous Boeing models, 737-600/-

700 I-700C 1-800/-900, 757-300, 767-200C /-400ER, 777-200 /-200LR /-300/-

300ER and 787 [Refer to Exemptions No. 5436, 5436A, 5436B, 6425, 6600, 6935, 

6425A, 8269 and 9486] were not required to meet, specifically the floor warpage 

testing requirements for flight deck seats. 

The previous Boeing models were exempt from this requirement based on the 

following justification: 

14 CFR 25.562(b)(2) states that, " ... Where floor rails or floor fittings are used to 

attach the seating devices to the test fixture, the rails or fittings must be misaligned 

with respect to the adjacent set of rails or fittings by at least 10 degrees vertically 

(i.e., out of parallel) with one rolled 10 degrees. II 

The preamble to Amendment 25-64 states that, "Crash investigations have shown 

that localized cabin floor deformation can occur in survivable crashes. This has 

been confirmed by the controlled impact demonstration and drop tests involving 

transport category airplanes. The inability of some seats to accommodate such 

deformations, remain in place, and restrain the occupants can contribute significantly 

to degree of injury during a crash. The simulated floor deformation used in the 

dynamic tests, will demonstrate the tolerance of the seat and its attachments to 

deformations that could occur in an actual crash. II 

The preamble also states the benefit of this amendment is believed to be that, 

" ... some lives are expected to be saved that otherwise may not have been. II 

I E. Statement of No Adverse affect on Safety 

This test requirement makes no distinction between passenger and crew seats, 

while the evidence mentioned in the preamble is believed to be based on passenger 

seats only. There is evidence to suggest that floor warpage has not been a 

significant factor in flight deck seat failures during survivable crash conditions. 

Page 2 of4 
Enclosure to RA-12-01946 

The FAA has stated in previous grants of exemption, "Since issuance of Amendment 

25-64, the FAA has had the opportunity to review in detail the performance of crew 

seats under various crash conditions. Although some cockpit floor distortions have 

been observed, there has not been a problem with flight deck seat separations due 

to floor buckling on narrow body and larger airplanes. II "Although some cockpit floor 

distortions have been observed after accidents, there has not been a problem with 

flight deck seat separations due to floor buckling on narrow body and larger 

airplanes which have a minimum of 40 inches of frangible structure between the 

flight deck floor and the lower fuselage contour. The FAA now considers that 

requiring testing of pilot seats with floor warpage cannot be justified on narrow body 

and larger airplanes. The FAA is currently developing a proposal to amend the 

regulations accordingly. II 

I F. Statement of Public Interest 

The FAA acknowledged in the preamble to Amendment 25-64 the likelihood of seats 

designed to meet this amendment costing more to manufacture and therefore to 

purchase as well as increasing the airplane operating cost due to weight increase. 

In order to justify the increased costs, it must be expected that some lives will be 

saved that otherwise may not have been. This does not appear to be the case for 

flight deck seats. These increased costs create an economic disadvantage for the 

767 -2C without a commensurate expectation of saving lives that otherwise may 

have been lost. 

Granting of this exemption is in the public interest because it will: 

1. Not adversely affect flight safety 

2. Improve the efficiency of the Model 767-2C 

3. Tend to reduce air transportation costs 

4. Improve the potential for sales to foreign operators, which in turn improves 

the U.S. balance of payments 

I G. 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 14 CFR 11.85, 11.87, and 11.89. 

Page 3 of4 
Enclosure to RA-12-01946 

The reasons presented for the relief from the floor warpage testing requirement for 

flightdeck seats on the Boeing Model 767-2C are the same as those for which a 

number of exemptions have already been granted for other aircraft types. [Refer to 

Exemptions No. 5436, 5436A, 5436B, 6425, 6600, 6935, 6425A and 8269] 

Accordingly, Boeing requests a waiver for the publication and comment period of 

this exemption. In particular, the main purpose of this petition and the justifications 

presented herein are the same as those for exemptions previously granted by the 

FAA. 

I H. Privileges of this Exemption Outside the United States 

Per 14 CFR 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 767 -2C is intended for the global market place with 

a launch customer based in a country utilizing the United States airworthiness 

standards. 

j1. Conclusion 

Based on the above justification and rationale provided previously for the 737-600 I -

700 /-700C /-800/-900, 757-300, 767-200C /-400ER, 777-200 /-200LR /-300/-

300ER and 787 models [Refer to Exemptions No. 5436, 5436A, 5436B, 6425, 6600, 

6935, 6425A, 8269 and 9486], Boeing requests exemption from the rail 

misalignment and roll test requirements of 14 CFR 25.562(b)(2) for the Boeing 

Model 767-2C Flight Deck Seats. 

Page 4 of4