APR tO 2014 

RA-14-01655 

The Boeing Company 

P.O. Box 3707 .,rnA;-'\T' ·r"'T Ql= :.r::r· H! flln~ , seattle, WA98124·2207 

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U.S. Department of Transportation 

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.: 

EASA Project No.: 

EASALevel: 

Reference(s): 

Special Instructions: 

This letter is to submit: 

Petition for Exemption from Title 14, Code of Federal 

Regulations (14 CFR) 26.21(b)(2)(ii), "Limit of 

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 sent for: 

(X) Regulatory Review/Approval 

The Boeing Company respectfully submits the enclosed Petition for Exemption 

from the Title 14 Code of Federal Regulations Part 26, 26.21 (b)(2)(ii) for the 

Boeing Model 737CL airplanes as related to the list of maintenance actions not 

mandated by Airworthiness Directives. 

The subject letter supersedes the reference (d) letter dated November 26, 2013. 
rfJ-_aOEING 

APR t'O 2014 

Page 2 

U.S. Department of Transportation 

RA 14-01655 

Please contact this office or the following individuals if you have further 

questions: 

(X) Project Administrator (PA): Debra Dean at 425-717-1165 

Sincerely, 

j'o r 

)J~ 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 73 7 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 of Production 

Program Mgr. 
Enclosure to RA-14-01655 Page 1 of 3 

A. Name and Address of the Petitioner 

Douglas M. Lane 

Director 

Commercial Airplanes 

(425) 237-1383, MC 03-56 

Fax: (425) 294-9340 

B. Section of the Code of Fetleral Regulations (CFRs) that are Affected 

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 of the applicable 

compliance date specified in paragraph (c) of this section, a 

list identifying each of those actions and a binding schedule 

for providing in a timely manner the necessary service 

information for those actions. Once the FAA Oversight Office 

approves this schedule, each person identified in paragraph 

(c) of this section must comply with that schedule 

C. The Extent of Relief Being Sought 

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 a Type 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 of January 14, 2011 and a binding 

Widespread schedule for providing in a timely manner the 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 of those maintenance actions in the 

service bulletins form of Boeing Service Bulletins (SB) as well as a binding date by 

are to be which revisions of those SBs will be submitted to the FAA. 

submitted to the Included in the listing of SBs 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 of 737-200C airplanes and which has a 

binding schedule date of July 14, 2014 for submittal of the 

revision to the FAA. 

After the binding schedule for submittal of the revised SBs in 

reference (b) was approved, further WFD analysis of the 

structure addressed in the reference (c) Service Bulletin revealed 

that the Inspection Start Point (ISP) would occur after the Limit 

of Validity (LOV) for these airplanes. At the LOV, any active 

airplanes would be withdrawn from service. In light of this, 
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 of the 

applicability of the reference (a) final rule. 

· D. Description of the Issue 

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 of the binding schedule contained in reference (b). 

The revision to the reference (c) Service Bulletin would provide instructions to inspect the outer skin of 

the main deck cargo door below the hinge line at an Inspection Start Point (ISP) and to install a 

modification/repair at or before the Structural Modification Point (SMP). 

The revision of the reference (c) Service Bulletin would be addressing a total of 33 737-200C airplanes. 

Of these 33 airplanes, 30 are permanently out of service or exceed their Limit of Validity (LOV). One 

airplane is embargoed and the remaining two that would need service action are not N-registered and it 

is anticipated that they will never fly into US airspace. One airplane, L/N 309, is located in the Republic 

of South Africa, has not flown since April 2006 and is in long term storage. The other airplane, L/N 295, is 

located in the Cote D'lvoire and hasn't shown any activity for at least the past 12 months. It is 

anticipated that these two airplanes will never be operated under Parts 121 or 129. 

After the conclusion was reached that the affected fleet consisted of only two potentially active 

airplanes and noting that a conservative analysis approach was used, the WFD analysis was re-calculated 

resulting in an Inspection Start Point (ISP) that exceeds the LOV of 75,000 cycles for these 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 of July 14, 2014. 

E. Statement of Public Interest 

Exclusion of the revision of the reference (c) Service Bulletin from the requirements of 14 CFR 

§26.21(b)(2)(ii) would permit The Boeing Company to apply more resources to the development of the 

widespread fatigue damage data for those remaining SBs to which the rule is applicable. The Boeing 

Company also considers that the granting of this exemption would negate the need for FAA to evaluate 

the data required to support compliance with these regulations for the revision of the reference (c) 

Service Bulletin. Therefore, granting this exemption would, in turn, reduce the burden on FAA resources 

and consequently public expenditure. 

F. Statement of No Adverse Effect on .f;,Yafety 

The recalculated ISP for the maintenance actions for the revision of the reference (c) Service Bulletin 

exceeds the LOV. In the unlikely event that either of the two airplanes in the affected fleet is ever 

returned to a flyable condition, they will have been removed from service at the LOV point prior to the 

ISP. 

G. Conclusion 

Exemption of the revision of the reference (c) Service Bulletin from the requirements of 14 CFR 

§26.21(b)(2)(ii) would have no adverse effect on public safety and permit The Boeing Company to apply 

more resources to the development of the widespread fatigue damage data for those SBs to which the 

rule is applicable. 
Enclosure to RA-14-01655 

H. Privileges of this Exemption Outside the United States 

Extension of this exemption is not_required outside of the United States. 

Summary to be Published in the Fe£leral Register 

PETITIONER: Boeing Commercial Airplanes 

SECTION OF 14 CFR AFFECTED: 14 CFR §26.21(b)(2)(ii) Amendment 26-6 

Page 3 of 3 

DESCRIPTION OF RELIEF SOUGHT: The Boeing Company petitions for an exemption to 14 CFR 

§26.21(b)(2)(ii) for the revision of Service Bulletin 737-52A10~8 as listed in Boeing Document D6-84905, 

Boeing 737CL WFD/LOV Compliance Document 14 CFR 26 Subpart C in this Petition. This petition for 

exemption is based on the fact that a widespread fatigue damage (WFD) re-analysis has shown that the 

Inspection Start Point (ISP) for the service actions for the aircraft listed in Service Bulletin 737-52A1038 

would occur after the aircraft had reached the Limit of Validity (LOV) at which point they would be 

required to be withdrawn from service. Exemption of the 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.