# APR tO 2014

RA-14-01655 The Boeing Company P.O. Box 3707 

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## U.S. Department ofTransportation Docket Operations, M-30 1200 New Jersey Avenue S.E. Room W12-140, West Bldg. Ground Floor Washington, DC 20590-0001


## Subject:

Model: RA Project No.: EASAProjectNo.: EASALevel: Reference(s):

Special Instructions:

This letter is to submit: Petition for Exemption from Title 14, Code ofFederal Regulations (14 CFR) 26.21(b)(2)(ii), "Limitof Validity", for Model 737CL 737CL N/A N/A N/A (a) Docket No. FAA-2006-24281, Widespread Fatigue Damage, issued May 24,2012 (b) Boeing Document D6-84905, Boeing 737CL WFDILOV Compliance Document 14 CFR 26 Subpart C, Revision B, 

## dated May 15, 2013 (c) Boeing Service Bulletin 737-52A1038 (d) Boeing Letter RA-13-05307 dated November 26, 2013
Please forward a copy to FAA Specialist Alan Rauschendorfer (ANM-100S)

(X) Petition for Exemption 

## This letter is being sentfor: (X) Regulatory Review/Approval
The Boeing Company respectfully submits the enclosed Petition for Exemption from the Title 14 Code ofFederal Regulations Part 26, 26.21 (b)(2)(ii) for the Boeing Model 737CL airplanes as related to the list ofmaintenance actions not mandated byAirworthiness Directives.
The subject letter supersedes the reference (d) letter dated November 26, 2013.

# rfJ-_aOEING APR t'O 2014 Page 2 U.S. Department ofTransportation RA 14-01655

Please contact this office or the following individuals ifyou have further questions: (X) Project Administrator (PA): Debra Dean at 425-717-1165 Sincerely,

# )J~ j'or Douglas M. Lane Director Commercial Airplanes (425) 237-1383, MC 03-56 FAX: (425) 294-9340
Enclosures:

cc Petition for Exemption from 14 CFR 26.21(b)(2)(ii) for Model 737 CL (3)

Name Enclosures Share Comments Point Mr. P. 

## Adjibly No X FAA 737 Program Mgr., 6Y-01
Mr. D. Tsuji No X 6Y-01 737
Mr. A. 

## Lam No X FAA LAACO Out ofProduction ProgramMgr.

## Enclosure to RA-14-01655 Page 1 of 3



## A. NameandAddressof thePetitioner Douglas M. Lane Director Commercial Airplanes (425) 237-1383, MC 03-56 Fax: (425) 294-9340 

## B. Section of the Code of FetleralRegulations (CFRs) thatareAffected As provided for in §11.61(b), per §11.81, Boeing hereby petitions for exemption from the following 14 CFR for the model 737-200C: 

### Regulation Amendment Requirement 14 CFR §26.21(b)(2)(ii) 26-6 (ii) For those maintenance actions for which service information has not been issued as ofthe applicable compliance date specified in paragraph (c) ofthis section, a list identifying each ofthose actions and a binding schedule for providing in a timely mannerthe necessary service information forthose actions. Once the FAA Oversight Office approves this schedule, each person identified in paragraph (c) ofthis section must comply with that schedule


## C. TheExtentof Relief BeingSought Regulation Requirement Why relief is necessary 14CFR Provide a list of Within the reference (a) Widespread Fatigue Damage final rule, §26.21(b)(2)(ii) service bulletins §26.21(b)(2)(ii) requires aType Certificate Holder (TCH) to

at Amdt 26-6 (SB) for which submit a list identifying each ofthose maintenance actions for revision is required which service information has not been mandated by to address airworthiness directive as ofJanuary 14, 2011 and a binding Widespread schedule for providing in a timely mannerthe necessary service Fatigue Damage information for those actions. (WFD) and a binding schedule Reference (b), the Boeing 737CL WFD/LOV Compliance by which those Document, provides the list ofthose maintenance actions in the service bulletins form of Boeing Service Bulletins (SB) as well as a binding date by are to be which revisions ofthose SBs will be submitted tothe FAA. submitted to the Included in the listing ofSBs to be revised is the reference (c) FAA for review and Service Bulletin which addresses the main deck cargo door hinge approval. area on the a number of737-200C airplanes and which has a binding schedule date ofJuly 14, 2014 for submittal ofthe revision to the FAA.

Afterthe binding schedule for submittal ofthe revised SBs in reference (b) was approved, further WFD analysis ofthe structure addressed in the reference (c) Service Bulletin revealed that the Inspection Start Point (ISP) would occur afterthe Limit ofValidity (LOV) for these airplanes. Atthe LOV, any active airplanes would be withdrawn from service. In light ofthis,

## Enclosure to RA-14-01655 

### Page 2 of 3

there is no need for Boeing to revise the reference (c) Service Bulletin. As a result, Boeing is respectfully petitioning that the revision of reference (c) SB as listed in reference (b) be exempted from the 14 CFR §26.21(b)(2)(ii) aspects ofthe applicability ofthe reference (a) final rule.



## ·D. Description of theIssue
A revision to the reference (c) Service Bulletin was required in response to the reference (a) Widespread Fatigue Damage rule and to meet the commitments ofthe binding schedule contained in reference (b). The revision to the reference (c) Service Bulletin would provide instructions to inspect the outerskin of the main deck cargo door belowthe hinge line at an Inspection Start Point (ISP) and to install a modification/repair at or before the Structural Modification Point (SMP). The revision ofthe reference (c) Service Bulletin would be addressing atotal of 33 737-200C airplanes. Ofthese 33 airplanes, 30 are permanently out ofservice or exceed their Limit ofValidity (LOV). One airplane is embargoed and the remaining two that would need service action are not N-registered and it is anticipated that theywill never fly into US airspace. One airplane, L/N 309, is located in the Republic ofSouth Africa, has notflown since April 2006 and is in longterm storage. The other airplane, L/N 295, is located in the Cote D'lvoire and hasn't shown any activityfor at leastthe past 12 months. It is anticipated thatthese two airplanes will never be operated under Parts 121 or 129. Afterthe conclusion was reached thatthe affected fleet consisted ofonly two potentially active airplanes and notingthat a conservative analysis approach was used, the WFD analysis was re-calculated resulting in an Inspection Start Point (ISP) that exceeds the LOV of75,000 cycles forthese airplanes. Therefore, no additional service actions are required to address WFD and there is no reason to revise the reference (c) Service Bulletin by the binding schedule date ofJuly 14, 2014. 

## E. Statementof PublicInterest
Exclusion ofthe revision ofthe reference (c) Service Bulletin from the requirements of 14CFR §26.21(b)(2)(ii) would permit The Boeing Company to apply more resources to the development ofthe widespread fatigue damage data for those remaining SBs to which the rule is applicable. The Boeing Company also considers thatthe granting ofthis exemption would negate the need for FAA to evaluate the data required to support compliance with these regulations forthe revision ofthe reference (c) Service Bulletin. Therefore, grantingthis exemption would, in turn, reduce the burden on FAA resources and consequently public expenditure. 

## F. 

## Statementof NoAdverseEffecton.f;,Yafety
The recalculated ISP for the maintenance actions for the revision ofthe reference (c) Service Bulletin exceeds the LOV. In the unlikely event that eitherofthe two airplanes in the affected fleet is ever returned to a flyable condition, theywill have been removed from service atthe LOV point prior to the ISP. 

## G. Conclusion Exemption ofthe revision ofthe reference (c) Service Bulletin from the requirements of 14 CFR §26.21(b)(2)(ii) would have no adverse effect on public safety and permitThe Boeing Company to apply more resources to the development ofthe widespread fatigue damage data for those SBs to which the rule is applicable.

## Enclosure to RA-14-01655



## H. Privilegesof thisExemption Outsidethe UnitedStates Extension ofthis exemption is not_required outside ofthe United States. 

## Summaryto bePublishedin theFe£leralRegister PETITIONER: Boeing Commercial Airplanes SECTION OF 14 CFR AFFECTED: 14 CFR §26.21(b)(2)(ii) Amendment 26-6 

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DESCRIPTION OF RELIEF SOUGHT: The Boeing Company petitions for an exemption to 14 CFR §26.21(b)(2)(ii) forthe revision of Service Bulletin**737-52A10~8** 

### as listed in Boeing Document D6-84905, Boeing 737CL WFD/LOV Compliance Document 14 CFR 26 Subpart Cin this Petition. This petition for exemption is based on the fact that a widespread fatigue damage (WFD) re-analysis has shown thatthe Inspection Start Point (ISP) forthe service actions forthe aircraft listed in Service Bulletin 737-52A1038 would occur afterthe aircraft had reached the Limit ofValidity (LOV) at which pointtheywould be required to be withdrawn from service. Exemption ofthe revision of Service Bulletin 737-52A1038 from the requirements of 14 CFR §26.21(b)(2)(ii) would have no adverse effect on public safety.