(Aj Ronald J . Hinderberger The Boeing Company 

Lead Administrator P.O. Box 3707 MC67-LR 

Delegated Compliance Org. • Seattle, WA 98124-2207 

Commercial Airplanes 

JIJN 2 5 2010 

BDCO-10-02194 

U.S. Department of Transportation "jz. 

Docket Operations 

West Building Ground Floor, Room W12-140 I 

1200 New Jersey Avenue, S.E. '; 

Washington, D.C. 20590 . j 

. • : . 3 

:—' 

-'^ 

Subject: Petition for Exemption to 14 CFR 25.783(g) ^ ' ' 

Amendment 23, 14 CFR 25.807(a)(1) 

Amendment 67, 14 CFR 25.809(a) Amendment 

116, 14 CFR 25.813(a) Amendment 46 and 

Petition to Amend Exemption 9793 A 

Model: 747-8F 

BDCO Project No.: PS05-0212 

EASA Project No.: P.EASA.IM.A.164 

EASA Level: N/A 

Branch/Panel No.: ANM-115 

Branch/Panel Name: Cabin Safety 

Response Due: July 9,2010 

Reference(s): N/A 

This letter is to submit: 

(X) Petition for an Exemption 

Please find enclosed the Boeing 747-8/-8F Petition for Exemption from 14 CFR 

25.783(g) Amendment 23, 14 CFR 25.807(a)(1) Amendment 67, 14 CFR 

25.809(a) Amendment 116, 14 CFR 25.813(a) Amendment 46 and Petition to 

Amend Exemption 9793 A. 

To support 747-8/-8F program schedules, Boeing requests that the enclosed 

information be processed by July 16, 2010. Furthermore, Boeing requests to be 

notified when the enclosed petition processing has completed. 

Waiver from Public Comment: 

This petition for Exemption will not set a precedent and accordingly, Boeing 

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

this Exemption. Boeing 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 
Page 2 

Mr. Breneman 

BDCO-10-02194 

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

questions: 

Project Administrator (PA): 

Certification Specialist: 

JeffPotocki 

G. Gillette 

425-266-7473 

425-266-7484 

^ 

Very truly yours, 

Christine Thompson ^ ^ 

Lead Project Administrator, Development Projects 

(425) 266-6572, MC 67-LR 

FAX: (425)294-9340 

Enclosure: Petition for Exemption from 14 CFR 25.783(g) Amendment 

23,14 CFR 25.807(a)(1) Amendment 67,14 CFR 25.809(a) 

Amendment 116,14 CFR 25.813(a) Amendment 46 and 

Petition to Amend Exemption 9793A. 

cc 

Name 

Gary Oltman 

Roxanne Pinkstaff 

Julie Zachary 

Rene Buendia 

Shannon Lennon 

Jason Claar 

Letter 

EDT 

EDT 

EDT 

EDT 

EDT 

EDT 

Enclosures 

EDT 

EDT 

EDT 

EDT 

EDT 

EDT 

Comments 

ANM-IOOS 

ANM-102S 

ANM-102S 

ANM-150S 

ANM-150S 

ANM-115 
Enclosure to BDCO-10-02194 

Petition for Exemption to 14 CFR 25.783(g) Amendment 23,14 CFR 25.807(a)(1) 

Amendment 67,14 CFR 25.809(a) Amendment 116,14 CFR 25.813(a) Amendment 46 and 

Petition to Amend Exemption 9793A 

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 tlie 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: 

Reaulation 

14 CFR 

25.783(g) 

14 CFR 

25.807(a)(1) 

14 CFR 

25.809(a) 

14 CFR 

25.813(a) 

At 

Amendment 

23 

67 

116 

46 

Which Requires 

Eacli passenger entry door in the side of tlie fuselage must qualify 

as a Type A, Type 1, or Type II passenger emergency exit and must 

meet the requirements of Sees. 25.807 through 25.813 that apply to 

that type of passenger emergency exit 

Type and location. For the purpose of this part, the Types and 

locations of exits are as follows: (1) Type 1. This Type must have a 

rectangular opening of not less than 24 inches wide by 48 inches 

high, with corner radii not greater than one-third the width of the exit. 

Type 1 exits must be floor level exits. 

Each emergency exit, including each flight crew emergency exit, 

must be a movable door or hatch in the external walls of the 

fuselage, allowing an unobstructed opening to the outside. In 

addition, each emergency exit must have means to permit viewing of 

the conditions outside the exit when the exit is closed.... Means 

must also be provided to permit viewing of the likely areas of 

evacuee ground contact. The likely areas of evacuee ground contact 

must be viewable during all lighting conditions with the landing gear 

extended as well as in all conditions of landing gear collapse. 

A passageway between individual passenger areas, and leading 

from each aisle to each Type 1 and Type II emergency exit. These 

passageways must be unobstructed and at least 20 inches wide. 

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

Limitation 16 in Exemption 9793A: 

Reauirement 

Exemption 

9793A 

Limitation 

16 

Which Requires 

For airplanes with the optional escape slide installed at the crew door 

Boeing must develop instructions for moving the escape slide aft to 

clear the projected opening of the exit from outside the airplane. 

These instructions must be added to the outboard side of the escape 

slide assembly so that rescue personnel can read the instructions 

and move the escape slide out of the way. These instructions must 

be demonstrated to be effective for rescue personnel. 

Page 1 of 10 
Enclosure to BDCO-10-02194 

The extent of relief being sought 

Reaulation 

14 CFR 

25.783 (g) 

Amendment 

23 

14 CFR 

25.807(a)(1) 

Amendment 

67 

14 CFR 

25.809(a) 

Amendment 

116 

14 CFR 

25.813(a) 

Amendment 

46 

Limitation 16 

from 

Exemption 

9793A 

Reauires: 

The crew door 

and Door 1 LH to 

be considered 

entry doors and 

thus would need 

to be a Type A, 1 

or II exit. 

The crew door as 

a Type 1 exit to be 

a floor level exit. 

The crew door as 

an emergency exit 

to have a means 

to view the 

evacuee ground 

contact area in all 

combinations of 

gear collapse. 

The crew door as 

a Type 1 exit to 

have a 20 inch 

passageway 

The crew door 

escape slide be 

labeled with 

instructions to 

move the escape 

slide aft to clear 

the projected 

opening of the exit 

Relief is necessary because: 

Main deck Door 1 LH is a Type A size door without any 

evacuation assist means and thus does not meet this 

regulation. This is unchanged from the 747-400F design. The 

configuration of the upper deck crew door does not meet all 

Type 1 exit requirements in section 14 CFR 25.807 through 14 

CFR 25.813 although the fuselage cutout meets the Type 1 exit 

dimensions. Some of the requirements not met are covered in 

Exemption No. 9793/9793A for the 747-8F;however the 

Exemption 9793/9793A does not provide relief from this 

requirement to provide a Type A, 1, or II size exit. 

The crew door can no longer be considered a Type 1 floor level 

exit due to a step-up to the exit when the airplane is configured 

with inertia reels as the only evacuation means. A previously 

granted Exemption No. 9735 has acknowledged this same 

condition on the 747-400F and considered the rating of the exit 

as a Type III. 

The provided viewing window on the crew door is not capable of 

viewing the evacuee ground contact area in all combinations of 

gear collapse for either evacuation means prior to the exit being 

opened. The configuration of the 747-8F airplane includes 

exterior body-mounted lights which will meet the requirement 

for lighting for both evacuation means. 

A similar grant of Exemption No. 9696 was extended for the 

767-300BCF based on the exit porthole combined with inertia 

reel assist means, six person occupancy, and additional crew 

procedures which will be drawn upon for the 747-8F. 

The passageway to the exit is less than 20 inches with the 

manually deployed slide installed in the 747-8F interior 

configuration. As a customer selectable option, the 747-400F 

manually-deployed escape slide at the crew door has been 

selected by a majority (5 of 6) of 747-8F airline customers as an 

additional evacuation means at that location. Although the 

interior configuration for the 747-8F is changed from the 747-

400F, a similar condition exist on the 747-400F. 

The interior configuration of the 747-8F does not allow the 

escape slide to be moved far enough aft to directly comply with 

the requirement to "clear" the projected opening. However, the 

design and configuration of the 747-8F does allow the slide to 

be moved aft to allow outside access by rescue personnel 

which will be demonstrated. Thus the Limitation could instead 

require the crew door be shown to allow access into the 

airplane from the outside by rescue personnel. Limitation 16 is 

to address a concern in Exemption 9793A that "the escape 

slide is partially blocking the access to the airplane when the 

crew service door is opened from the outside, which may 

prevent rescue personnel from rapidly entering the airplane in 

an emergency." This concern can be addressed without fully 

clearing the projected door opening. 

There is no similar requirement in Exemption series 1870 for 

this similar configuration and condition on the 747-200F/400F 

airplanes which have a proven safety record. 

Page 2 of 10 
Enclosure to BDCO-10-02194 

Description of the Issue 

The Model 747-8F is a derivative aircraft based on the 747-400F. The fuselage of 

the 747-8F is 220" longer than the 747-400F. The 747-8F emergency exits, crew 

door window, exterior body-mounted light for the escape slide, and the escape 

means are identical to the 747-400F with the exception that the escape slide is a 

customer selectable option on the 747-8F where as it was basic on the 747-400F. 

For the 747-8F, the escape slide has been selected by a majority (5 of 6) of the 

airline customers as the evacuation means at the crew door. 

Like the 747-400F, the 747-8F has a required flight crew of two (2) and is allowed 

the carriage of up to six (6) supernumeraries. Like the 747-400F and its 

predecessors, the 747-8F AFM will limit the airplane to eight (8) occupants. The 

eight (8) inertia reel descent devices located on the flight deck are identical in part 

number and location to the 747-400F and will be included on all 747-8F airplanes, 

with one for each airplane occupant to use either through the crew door or from the 

flight deck overhead exit. Additionally, there are eight (8) harnesses installed basic 

in the 747-8F supernumerary seating areas, two (2) more than the 747-400F, one 

for each occupant to don and connect to their descent device before evacuating the 

airplane. 

The optional manually-deployed escape slide is attached to a platform that moves 

fore and aft on rails inside of the upper deck crew door. When the escape slide is 

deployed through the crew door, the fonward side of the platform is stationary and 

remains in the interior creating the boundary to the passageway out the exit. The 

escape slide system also has a flexible, non-inflatable, chute hinged to the platform 

to assist as a guide in slide deployment. This chute also remains in the interior 

creating a boundary to the passageway out the exit. When the optional escape slide 

is installed the 20 inch passageway leading to the exit is not maintained from the 

slide platform to the interior monument, nor is the escape slide chute itself 20 inches 

The current design on the 747-8F provides the capability to move the escape slide 

aft providing access for rescue personnel with instructions that are affixed to the 

outboard side of the slide pack such that they can be seen when the door is opened 

from the outside. The ability to gain access, including the effectiveness of the 

instructions, will be demonstrated by rescue personnel in accordance with 

Exemption 9793A Limitation 16. 

A new body-mounted exterior light was added to the 747-8F. This new light 

illuminates the ground contact area of the inertia reels, in all combinations of gear 

collapse, before and after door opening. The existing exterior body-mounted light 

illuminates the ground contact area of the escape slide, in all combinations of gear 

collapse when the slide is usable, before and after door opening. Both exterior 

lights will be installed on all airplanes regardless of evacuation means selected by 

the customer. These lights are activated (1) automatically upon loss of main 

electrical power (28 VDC bus) when the system is armed, or (2) manually via the 

Page 3 of 10 
Enclosure to BDCO-10-02194 

emergency light switches located on the flight deck or in the supernumerary seating 

area. 

Statement of No Adverse affect on Safety 

The petitioner strives to provide acceptable safety conditions such that 747-8F cargo 

operators can safely operate their airplane with evacuation means and procedures 

consistent with the current fleet. The majority (5 of 6) of the airline customers that 

have purchased the 747-8F also operate fleets of earlier model 747 Freighters, 

including the 747-400F. The surest, safest, and most cost effective manner of 

operating these cargo aircraft is to have consistent airplane designs and 

crew/supernumerary training with respect to evacuation safety features of the 

airplane. A grant of Exemption will result in consistent operator's procedures for 

evacuation of the 747-8F with the 747-400F fleet when the escape slide is installed 

and similar to other airplane models with only inertia reels installed, thus enhancing 

safety. 

Granting the Exemption to 14 CFR 25.783(g) Amendment 23 for Door 1 LH and the 

upper deck crew door will not have an appreciable affect on safety based upon the 

following factors which are summarized here and discussed as necessary in more 

detail below: 

• Limited number of trained supernumeraries 

• Specific to Door 1 LH, while it will be used for entry it will not be marked with 

any exit signs visible from the upperdeck supernumerary seating area 

• Specific to the crew door, while it is sized as a Type I door, it will not 

practically be used as an entry door due to it's location on the upper deck 

approximately 26 feet above the ground. 

• The crew door will be marked with exit signs visible from the upperdeck 

supernumerary seating area and have appropriate evacuation means 

available at the exit. 

Previously the FAA recognized in Exemption No. 4808 for the 757-200PF "The 

Intent of 14 CFR 25.783(g) is to ensure that the door through which people enter an 

airplane Is also useable as an emergency exit". "Because of the better trained, 

operator-approved, small number of noncrewmembers allowed In the flight deck, the 

FAA finds that the entry door provided in the Model 757-200PF can safety be used 

as an emergency exit and that the requirements that the entry door be a Type A, I or 

II Is unnecessary." Although the 747-8F has a different configuration than the 757-

200PF, the circumstances are similar in training and small number of non-crew 

members. The personnel (maximum of 8) aboard the 747-8F are required to be 

briefed by the flight crew prior to each flight on the use of the exits in accordance 

with Exemption No. 9793/9793A. This additional level of knowledge afforded to 

these occupants when compared to the normal passenger provides an 

enhancement in evacuation normally afforded. Door 1 LH will be used as the entry 

door on the 747-8F however it will not be used as the emergency exit. It will be out 

of sight and no exit signs will lead personnel to Door 1 LH once the supernumeraries 

have taken their seats in the upper deck thus it is unnecessary to make it a useable 

emergency exit with evacuation means as other exits will be available, appropriately 

Page 4 of 10 
Enclosure to BDCO-10-02194 

marked, and equipped with the evacuation means (same as previous 747 Freighter 

models). 

Granting the Exemption to 25.807(a)(1) Amendment 67 and 14 CFR 25.813(a) 

Amendment 46 for the non-floor level exit and less than 20 inch passageway, 

respectively, at the upper deck crew door will not have an appreciable affect on 

safety based upon the following factors which are summarized here and discussed 

as necessary in more detail below: 

o Limited number of trained supernumeraries (see discussion, above) 

o Consideration of the crew door rating similar to a Type III exit with a 19 inch 

passageway being maintained 

o a small step-up of approximately 8 inches 

Per 14 CFR 25.807(c)(1) Amendment 67, a pair of Type I exits would allow 40-79 

passengers, while a pair of Type III exits would be sufficient for between 20 and 39 

occupants. In combination with the flight deck overhead exit, having the 747-8F 

airplane configured with a Type I size cut out and nearly meeting the Type I 

passageway requirements, while only needing to provide evacuation capability for 8 

occupants, the overall design is considered sufficiently safe. 

While a 20 inch passageway is required for a Type I sized exit, the crew door can be 

considered, based on the number of passengers being evacuated, similar to a Type 

III exit. The applicable regulations, 14 CFR 25.813(c)(1)(2) Amendment 46, do not 

specify a passageway requirement for Type III exits rather only that the projected 

opening may not be obstructed and there may be no interference in opening the 

exit. Considering the 747-8F crew door as similar to a Type III exit, with a method of 

compliance associated with the projected opening by providing a 19 inch 

passageway at the crew door and no obstruction in opening the exit, is sufficiently 

safe for the 8 occupants. A step-up of 20 inches is allowed for a Type III exit. The 

747-8F step-up when the escape slide is not installed is approximately 8 inches and 

there is no step up when both the inertial reels and slide are installed. The FAA 

recognized a similar condition in Exemption No. 9735 for the 747-400F "...have a 

crew service door the size of a Type I exit, but because the door has a step-up 

inside the airplane it Is rated as a Type III exit and Is available for evacuation".. 

Granting the exemption to 14 CFR 25.809(a) Amendment 25-116 will not adversely 

affect safety based upon the following factors which are summarized here and 

discussed in more detail below: 

• Flight deck and supernumerary windows 

• Crew awareness 

• Manually-deployed escape slide and inertia reels 

• Exit height 

• Exterior body-mounted lights 

It is understood 14 CFR 25.809(a) at Amendment 25-116 was codified to address 

the potential for a crew member or supernumerary to mistakenly open or use an 

emergency exit when there is an external hazard (such as a fire, water or 

terrain/obstacles) that is not visible (due to lack of means to view outside and/or 

Page 5 of 10 
Enclosure to BDCO-10-02194 

from inadequate lighting) that could pose an immediate threat to the occupants of 

the airplane, damage the evacuation means, pose a threat to personnel using the 

evacuation means, and/or delay the evacuation. 

Previous industry design practice has provided outside viewing means (windows) 

installed on or adjacent to the passenger emergency exits in the majority of cases. 

Additionally, the large flight deck windows provide a means to view the surrounding 

area by the flight crew as the airplane is on approach. These windows have proven 

an effective means for quickly assessing conditions outside the emergency exit prior 

to the emergency exit being opened in order to avoid delay in opening the 

emergency exits and initiating the evacuation. 

In addition to the flight deck windows, a window is installed in the crew door of the 

747-8F. Additionally, the 747-8F includes three standard passenger sized windows 

(for the supernumeraries) on the right hand side of the airplane aft of the crew door 

and located adjacent to the supernumerary seats. 

All windows provide a view of the surrounding area with the airplane resting on all 

landing gear. Once the airplane has slowed to a stop, viewing of all of the likely 

areas of evacuee ground contact prior to the exit being opened will not be fully 

possible since they are directly beneath the aircraft when inertia reels are used. 

However, a view of the surrounding area as the airplane comes to a stop as well as 

the surrounding view from the flight deck and supernumerary windows once stopped 

provides the ability to make assessments and appropriate evacuation decisions as 

follows: 

o In most cases, the presence of a fire in the vicinity of the flight deck windows 

and crew door large enough to be a hazard if the exit is opened would be 

readily and easily recognizable by the flight crew as the airplane slows to a 

stop. In these cases, the flight crew would command evacuation from the 

appropriate exit. 

o Recalling, the supernumeraries are required to be briefed in the use of the 

exits, the presence of a fire or water in the surrounding area of the crew door 

large enough to be a hazard would likely be recognized by the 

supernumeraries from their adjacent supernumerary windows, in conjunction 

with the body-mounted lights as necessary, before leaving their seats and 

could be communicated to the flight crew when determining which exit to 

utilize. 

It is understood 14 CFR 25.809(a) at Amendment 25-116 is also to prevent the 

deployment of an escape slide into a hazard, since this deployment is irreversible, 

and door re-closure is necessarily impeded by the deployed slide due to its interface 

with floor structure immediately inboard of the door sill. In the case of the 747-8F, 

the evacuation means is manually-deployed after the emergency exit is opened. If a 

hazard such as fire, water, or terrain is detected near the crew door, after the door is 

opened, the door may be easily closed again because the manually deploy 

passenger escape slide or inertia reels would not be in the way of the door 

mechanism. 

Page 6 of 10 
Enclosure to BDCO-10-02194 

The location of the emergency exit is approximately 13.5 feet above the water line in 

the unplanned ditching scenario which is worst case. The crew door is far enough 

above the water level after a ditching event such that if this emergency exit were to 

be opened without first assessing outside conditions it could easily and quickly be 

re-closed without consequence. 

Additionally the 747-8F airplane is configured with body-mounted lights providing the 

illumination in dark of night conditions to assess the surrounding area prior to 

emergency exit opening. After emergency exit opening and before evacuating 

through the exit, making an assessment of safety to evacuate can be done by 

viewing out the open exit utilizing the body-mounted exterior lights which will fully 

illuminate the ground contact area of both evacuation means before those means 

are deployed. 

While a means that provides viewing of the evacuee ground contact area for all 

combinations of gear collapse does not exist for the crew door when equipped with 

inertia reels or manually-deployed escape slides, the airplane design provides an 

acceptable level of safety as noted above. 

Similar conditions were recognized and accepted by the FAA in Exemption No. 9696 

for the 767-300BCF. 'We agree in this specific case with the petitioner's rationale 

that In most cases the presence of a fire In the vicinity of the lefthand flight deck 

window and Door 1 L would be recognizable by the flight deck crew...". "Because 

the assist means Is an inertia reel, the evacuee has a bit more control over the 

landing zone...". Similar to the inertial reels, there is also control over the 

deployment of the optional escape slide for the 747-8 and rationale for no adverse 

affect on safety for the optional slide in relation to 14 CFR 25.809(a) is contained 

herein. 

Limitation 16 

It is proposed that the FAA accept an adequate opening to allow access from 

outside the airplane at the crew door by providing relief from Limitation 16 of 

Exemption No. 9793A which requires in part, "For airplanes with the optional escape 

slide Installed at the crew door Boeing must develop instructions for moving the 

escape slide aft to clear the projected opening of the exit from outside the airplane." 

Exemption 9793A noted a concern that "the escape slide Is partially blocking the 

access to the airplane when the crew service door is opened from the outside, 

which may prevent rescue personnel from rapidly entering the airplane in an 

emergency." An acceptable level of safety can be maintained without the specific 

requirement to fully clear the projected opening of the exit based on: 

o providing adequate access for rescue personnel from outside the airplane 

o rescue personnel procedures 

o maintaining all of the other aspects of Limitation 16. 

The exit maintains the physical structural cutout of a Type I exit as well as the 

function of being openable from the outside allowing entry into the airplane. If the 

slide has not been deployed, then the rescue personnel can move the slide pack aft 

Page 7 of 10 
Enclosure to BDCO-10-02194 

by following the instructional placards added to the outboard of the slide pack, thus 

providing an entry way. 

In the nose down adverse attitudes, the 747-8F slide does not have a detent on the 

track for it to lock in the full open position. The force to move the slide is less than 

30 pounds which is within the capability of rescue personnel. 

Safety is maintained because the requirements of Limitation 16 provide an increase 

in safety as compared to the 747-400F by including instructions for rescue 

personnel in the type design (via placarding) in addition to including instructions in 

the rescue and fire fighting procedures. 

Proposed Revision to Limitation 16 

Request to Revise Limitation 16: Boeing hereby requests the FAA revise 

Limitation 16 to remove the "clear opening" requirement. Boeing proposed wording 

- "For airplanes with the optional escape slide installed at the crew door Boeing must 

develop instructions for moving the escape slide aft to provide an entrvwav sufficient 

to allow access Into the airplane for the purposes of rescuing occupants from the 

outside. These instructions must be added to the outboard side of the escape slide 

assembly so that rescue personnel can read the Instructions and move the escape 

slide out of the way. These instructions must be demonstrated to be effective for 

rescue personnel." 

Statement of Public Interest 

The public interest will be advanced by the grant of Exemption as it is in the best 

economic interest of the United States. Increased sales of airplanes contribute to 

the balance-of-trade, the gross domestic product and economic health of the United 

States. Marketability of the 747-8F is improved, leading to increased sales, by 

keeping the sales price and operating cost of the 747-8F down while providing 

flexibility to the airlines in a choice of evacuation means. 

Purchase prices could increase due to extensive design changes associated with 

providing fully compliant designs for both evacuation means which would be 

necessary to allow the operational flexibility in evacuation means. Design changes 

likely to be necessary include: 

o New escape slide 

o Revisions to provide for a floor level exit for operators who select only the 

inertia reels 

o Means to view the evacuee ground contact area for both the inertia reel and 

escape slide 

o Changes to the door structure and/or door mechanisms 

o Interior configuration changes to allow the escape slide to be moved further 

aft to fully clear the projected opening of the exit 

Operating costs are kept down by: 

Page 8 of 10 
Enclosure to BDCO-10-02194 

o Having common training and operating procedures with the 747 Freighter 

Fleet when the escape slide is installed while avoiding the cost of maintaining 

different material in the training, maintenance, dispatch and operations 

manuals for the 747-8F and 747-400F. Every 747-400F delivered from 

Boeing was equipped with an escape slide installed in a similar interior 

configuration, a window in the crew door, and an exterior body-mounted light 

to illuminate the evacuee ground contact area of the escape slide. The 

majority (4 of 6) of the airline customers that have purchased the 747-8F also 

operate fleets of earlier model 747 Freighters and will have the escape slides 

installed on their 747-8F, same as the 747-400F. 

o Common training and operating procedures to other freighter models for 

those airlines selecting only the inertia reels as the evacuation means. 

o Having common escape slide spares with existing 747 Freighter fleets. 

o Avoiding the weight and fuel penalty and system maintenance costs including 

any economic penalties associated with flight delays that would othenwise be 

realized by the required design changes as noted above in the purchase 

price impacts. 

o Weight and fuel benefits for operators choosing the inertia reels as the 

evacuation means 

Lower purchase and operating cost will help maintain cargo shipping rates aboard 

Freighter airplanes at their current levels, which benefit the US economy as a whole. 

Grant of Exemption as requested in this petition is in the best interest of the 

travelling public through introduction of this new product into the marketplace that 

has advanced the certification basis in many areas as compared to the 747-400F. 

Enabling common operating procedures for evacuation not only maintains purchase 

price and operating cost as noted above, but avoids the potential for human error 

which may be introduced when procedures vary for similar products. For the 

reasons noted above, it is the petitioner's opinion that the overall level of safety is 

improved by comparison to the previous 747 Freighter models that are certified with 

similar configurations and evacuation systems and safety is maintained which is in 

the public's best interest. 

H. 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. 

Relief from 14 CFR 25.783(g) has been provided on other freighter aircraft 

including 757 Exemption No. 4808. Relief from 14 CFR 25.807(a)(1) Amendment 

67 and 14 CFR 25.813(a) Amendment 46 while not previously explicitly granted in 

previous exemptions has been implied and is related to the relief sought for 14 CFR 

25.783(g). Relief from 14 CFR 25.809(a) Amendment 116 has been provided on 

other freighter aircraft including 767-300 BCF Exemption No. 9696. Additionally, 

this change is less prescriptive in its method of achieving the intended goal of 

Page 9 of 10 
Enclosure to BDCO-10-02194 

Limitation 16 yet the full capability intended by Limitation 16 is still provided. This 

request to revise Limitation 16 is not unprecedented. The FAA has granted a 

revision to Exemption No. 9793 to allow for installation of the crew slide because a 

corresponding level of safety is provided. Similarly, the same level of safety is 

provided by the revised Limitation, in that the design allows access to the 

occupiable areas from outside the airplane. 

The 747-8F petition is being provided in a timely manner; however, due to the 

scheduled delivery of the first 747-8F being near the end of the year 2010, for the 

first customer with the escape slide chosen option, a delay in processing of the 

Exemption could delay the entry into service. 

I. 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 ainrt/orthiness standards for 

transport category aircraft. The 747-8F is intended for the global market place. 

J. Conclusion 

The 747-8F maintains the level of safety previously afforded on the 747 Freighter 

series from an exit rating and evacuation systems standpoint. The 35 year service 

history of the 747F series has proven its safety. Granting relief from 14 CFR 

25.783(g) Amendment 23, 14 CFR 25.807(a)(1) Amendment 67 and 14 CFR 

25.809(a) Amendment 116 for the 747-8F model is justified based on this exit 

meeting the pertinent aspects of the Type I exit and considering that it will only be 

used by a limited number of trained and capable occupants. Granting relief from 

14 CFR 25.809(a) Amendment 116 for the 747-8F model is justified based on the 

capability of the airplane to provide safe evacuation means including illumination. 

Granting the revision to Limitation 16 is justified based on providing adequate 

access by rescue personnel from outside the airplane and maintaining all of the 

other aspects of Limitation 16. If Limitation 16 is revised the crew door will maintain 

an effective opening adequate for rescue personnel to enter from outside the 

airplane if necessary. 

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