~DEING 

February 7, 2014 

M-ABOH-14-00022 

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Avenue S.E. 

. : /;\~ "\ 'P,IT OF • ; H , I I~ ,._i 1 

-- -. '-'~l:pR·l-ATir',N ..... ·'-' u VI . ._,.. --.--- 09ER"TIO' S - ; , ,c! - , . 1\ i~ 

ZOl~ FEB 10 A '1: 2W 

Room W12-140, West Bldg. Ground Floor 

Washington, DC 20590-0001 

The Boeing Company 

P.O. Box 3707 

Seattle, WA 98124-2207 

Subject: 

Model: 

Petition for Exemption from Title 14, Code of Federal 

Regulations (14 CFR) Part 25 Regulations, for Model 

767-300 Boeing Converted Freighter (BCF) 

767-300BCF 

FAA Project No.: NIA 

EASA Project No.: NIA 

EASALevel: NIA 

This letter is to submit: 

(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 

applicable Title 14 Code of Federal Regulations Part 25 for the Boeing Model 767-300BCF 

airplane as related to the proposed installation of an oven. ' 

Please contact Ted Scoville at 425-717-3895 if you have further questions. 

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, is considered proprietary to The Boeing Company and/or its suppliers, and is 

provided on a confidential basis. 

The data provided should be returned to Boeing immediately following use by the FAA, 

including any copies thereof which the FAA may be required to make in the course of its 

review. Boeing does not authorize the FAA to retain any portion of the materials being 

supplied. 
rti-BDEIND _/ 

Page 2 

U.S. Department of Transportation 

M-ABOH-14-00022 

Sincerely, 

T. A. Scoville 

Manager, Puget Sound Regulatory Administration 

Technical Services, Commercial Airplanes 

M/C 7A-WP, (425) 717-3895 

FAX: (425) 965-8280 

Enclosures: 

cc 

Name 

Mr.A.Lam 

Ms. M. Gordon 

(a) Petition for Exemption 

(b) Specification Approval Letter 

Enclosures Share Comments 

Point 

No X FAA Program Mgr., TS & OOP 

Models (LAACO) 

No X FAA TAD 
Enclosure (a) to M-ABOH-14-00022 

Page 1 of 12 

, A. Name and Address of the Petitioner 

Doug Lane, Director, Regulatory Administration 

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 §11.61 (b), per §11.81, Boeing hereby petitions for exemption for the following 

CFR Title 14 Part 25 regulations associated with the installation of JAMCO oven, Part Number 

A233-1, on model767-300 Boeing Converted Freighter (BCF), VS721 (SIN 32972). All regulations 

listed below are per the model certification basis as defined by Type Certification Data Sheet 

A1NM. 

Regulation Requirement 

14CFR (a) Strength requirements are specified in terms of limit loads (the 

25.301(a)(b)(c) maximum loads to be expected in service) and ultimate loads 

Loads (limit loads multiplied by prescribed factors of safety). Unless 

otherwise provided, prescribed loads are limit loads. 

(b) Unless otherwise provided, the specified air, ground, and 

water loads must be placed in equilibrium with inertia forces, 

considering each item of mass in the airplane. These loads must 

be distributed to conservatively approximate or closely represent 

actual conditions. Methods used to determine load intensities and 

distribution must be validated by flight load measurement unless 

the methods used for determining those loading conditions are 

shown to be reliable. 

(c) If deflections under load would significantly change the 

distribution of external or internal loads, this redistribution must 

be taken into account. 

14 CFR 25.303 Unless otherwise specified, a factor of safety of 1.5 must be 

Factor of safety applied to the prescribed limit load which are considered external 

loads on the structure. When a loading condition is prescribed in 

terms of ultimate loads, a factor of safety need not be applied 

unless otherwise specified. 

14CFR (a) The structure must be able to support limit loads without any 

25.305(a)(b )(c)( e )(f) detrimental permanent deformation. At any load up to limit loads 

Strength and the deformation may not interfere with safe operation. 

deformation. (b) The structure must be able to support ultimate loads without 

failure for at least 3 seconds. However, when proof of strength is 

shown by dynamic tests simulating actual load conditions, the 3-

second limit does not apply. Static tests conducted to ultimate load 

must include the ultimate deflections and ultimate deformation 

induced by the loading. When analytical methods are used to 
14 CFR 25.307(a)(d) 

Proof of structure. 

14CFR 

25.561(a)(b)(c) 

General. 

Enclosure (a) to M-ABOH-14-00022 

Page 2 of 12 

show compliance with the ultimate load strength requirements, it 

must be shown that--

(1) The effects of deformation are not significant; 

(2) The deformations involved are fully accounted for in the 

analysis; or 

(3) The methods and assumptions used are sufficient to cover the 

effects of these deformations. 

(c) Where structural flexibility is such that any rate of load 

application likely to occur in the operating conditions might 

produce transient stresses appreciably higher than those 

corresponding to static loads, the effects of this rate of application 

must be considered. 

(e) The airplane must be designed to withstand any vibration and 

buffeting that might occur in any likely operating condition up to 

V0 /M0 , including stall and probable inadvertent excursions 

beyond the boundaries of the buffet onset envelope. This must be 

shown by analysis, flight tests, or other tests found necessary by 

the Administrator. 

(f) Unless shown to be extremely improbable, the airplane must be 

designed to withstand any forced structural vibration resulting 

from any failure, malfunction or adverse condition in the flight 

control system. These must be considered limit loads and must be 

investigated at airspeeds up to V c/Mc. 

(a) Compliance with the strength and deformation requirements of 

this subpart must be shown for each critical loading condition. 

Structural analysis may be used only if the structure conforms to 

those for which experience has shown this method to be reliable. 

The Administrator may require ultimate load tests in cases where 

limit load tests may be inadequate. 

(d) When static or dynamic tests are used to show compliance 

with the requirements of Sec. 25.305(b) for flight structures, 

appropriate material correction factors must be applied to the test 

. results, unless the structure, or part thereof, being tested has 

features such that a number of elements contribute to the total 

strength of the structure and the failure of one element results in 

the redistribution of the load through 'alternate load paths. 

(a) The airplane, although it may be damaged in emergency 

landing conditions on land or water, must be designed as 

prescribed in this section to protect each occupant under those 

conditions. 

(b) The structure must be designed to give each occupant every 

reasonable chance of escaping serious injury in a minor crash 

landing when--

( 1) Proper use is made of seats, belts, and all other safety design 

provisions; 
14 CFR 25.601 

General 

14 CFR 

25.603(a)(b)(c) 

Materials 

14 CFR 25.605(a)(b) 

Fabrication methods 

14CFR 

25.607(a)(b)(c) 

Fasteners 

Enclosure (a) to M-ABOH-14-00022 

Page 3 of 12 

(2) The wheels are retracted (where applicable); and 

(3) The occupant experiences the following ultimate inertia forces 

relative to the surrounding structure: 

(i) Upward, 3.0g. 

(ii) Forward, 9.0g. 

(iii) Sideward, 3.0g on the airframe; and 4.0g on the seats and 

their attachments. 

(iv) Downward, 6.0g. 

(v) Rearward, 1.5g. 

(c) For equipment, cargo in the passenger compartments and any 

other large masses, the following apply: 

(1) Except as provided in paragraph (c)(2) of this section, these 

items must be positioned so that if they break loose, they will be 

unlikely to: 

(i) Cause direct injury to occupants; 

(ii) Penetrate fuel tanks or lines or cause fire or explosion hazard 

by damage to adjacent systems; or 

(iii) Nullify any of the escape facilities provided for use after an 

emergency landing. 

(2) The supporting structure must be designed to restrain, under 

all loads up to those specified in paragraph (b)(3) of this section, 

each item of mass that could injure an occupant if it came loose in 

a minor crash landing. 

The airplane may not have design features or details that 

experience ha~ shown to be hazardous or unreliable. The 

suitability of each questionable design detail and part must be 

established by tests. 

The suitability and durability of materials used for parts, the 

failure of which could adversely affect safety, must--

(a) Be established on the basis of experience or tests; 

(b) Conform to approved specifications (such as industry or 

military specifications, or Technical Standard Orders) that ensure 

their having the strength and other properties assumed in the 

design data; and · 

(c) Take into account the effects of environmental conditions, 

such as temperature and humidity, expected in service. 

, (a) The methods of fabrication used must produce a consistently 

sound structure. If a fabrication process (such as gluing, spot 

welding, or heat treating) requires close control to reach this 

objective, the process must be performed under an approved 

process specification. 

(b) Each new aircraft fabrication method must be substantiated by 

a test program. 

(a) Each removable bolt, screw, nut, pin, or other removable 

fastener must incorporate two separate locking devices if--

(1) Its loss could preclude continued flight and landing within the 
I4 CFR 25.609(a)(b) 

Protection of structure 

I4 CFR 25.6I I 

Accessibility 

prOVISIOnS 

14CFR 

25 .613(a)(b )(c)( e )(f) 

Material strength 

properties and 

material design values 

Enclosure (a) to M-ABOH-14-00022 

Page 4 of 12 

design limitations of the airplane using normal pilot skill and 

strength; or 

(2) Its Joss could result in reduction in pitch, yaw, or roll control 

capability or response below that required by Subpart B of this 

chapter. 

(b) The fasteners specified in paragraph (a) of this section and 

their locking devices may not be adversely affected by the 

environmental conditions associated with the particular 

installation. 

(c) No self-locking nut may be used on any bolt subject to rotation 

in operation unless a nonfriction locking device is used in addition 

to the self-locking device. 

Each part of the structure must--

(a) Be suitably protected against deterioration or loss of strength 

in service due to any cause, including--

(I) Weathering; 

(2) Corrosion; and 

(3) Abrasion; and 

(b) Have provisions for ventilation and drainage where necessary 

for protection. 

Means must be provided to allow inspection (including inspection 

of principal structural elements and control systems), replacement 

of parts normally requiring replacement, adjustment, and 

lubrication as necessary for continued airworthiness. The 

inspection means for each item must be practicable for the 

inspection interval for the item. Nondestructive inspection aids 

may be used to inspect structural elements where it is 

impracticable to provide means for direct visual inspection if it is 

shown that the inspection is effective and the inspection 

procedures are specified in the maintenance manual required by 

Sec. 25.1529. 

(a) Material strength properties must be based on enough tests of 

material meeting approved specifications to establish design 

values on a statistical basis. 

(b) Material design values must be chosen to minimize the 

probability of structural failures due to material variability. Except 

as provided in paragraphs (e) and (f) of this section, compliance 

must be shown by selecting material design values which assure 

material strength with the following probability: 

(1) Where applied loads are eventually distributed through a 

single member within an assembly, the failure of which would 

result in loss of structural integrity of the component, 99 percent 

probability with 95 percent confidence. 

(2) For redundant structure, in which the failure of individual 

elements would result in applied loads being safely distributed to 

other load carrying members, 90 percent probability with 95 
14CFR 

25.619(a)(b)(c) 

Special factors 

14CFR 

25.621 (a)(b)(c)(d) 

Casting factors 

percent confidence. 

Enclosure (a) to M-ABOH-14-00022 

Page 5 of 12 

(c) The effects of environmental conditions, such as temperature 

and moisture, on material design values used in an essential 

component or structure must be considered where these effects are 

significant within the airplane operating envelope. 

(e) Greater material design values may be used if a "premium 

selection" ofthe material is made in which a specimen of each 

individual item is tested before use to determine that the actual 

strength properties of that particular item will equal or exceed 

those used in design. 

(f) Other material design values may be used if approved by the 

Adm'inistrator. 

The factor of safety prescribed in Sec. 25.303 must be multiplied 

by the highest pertinent special factor of safety prescribed in Sees. 

25.621 through 25.625 for each part of the structure whose 

strength is--

(a) Uncertain; 

(b) Likely to deteriorate in service before normal replacement; or 

(c) Subject to appreciable variability because of uncertainties in 

manufacturing processes or inspection methods. 

(a) General. The factors, tests, and inspections specified in 

paragraphs (b) through (d) of this section must be applied in 

addition to those necessary to establish foundry quality control. 

The inspections must meet approved specifications. Paragraphs 

(c) and (d) of this section apply to any structural castings except 

castings that are pressure tested as parts of hydraulic or other fluid 

systems and do not support structural loads. 

(b) Bearing stresses and surfaces. The casting factors specified in 

paragraphs (c) and (d) of this section--

(I) Need not exceed I.25 with respect to bearing stresses 

regardless of the method of inspection used; and 

(2) Need not be used with respect to the bearing surfaces of a part 

whose bearing factor is larger than the applicable casting factor. 

(c) Critical castings. For each casting whose failure would 

preclude continued safe flight and landing of the airplane or result 

in serious injury to occupants, the following apply: 

(1) Each critical casting must--

(i) Have a casting factor of not less than I.25; and 

(ii) Receive I 00 percent inspection by visual, radiographic, and 

magnetic particle or penetrant inspection methods or approved 

equivalent nondestructive inspection methods. 

(2) For each critical casting with a casting factor Jess than 1.50, 

three sample castings must be static tested and shown to meet--

(i) The strength requirements of Sec. 25.305 at an ultimate load 

corresponding to a casting factor of 1.25; and 

(ii) The deformation requirements of Sec. 25.305 at a load of 1.15 
14 CFR 25.623(a)(b) 

Bearing factors. 

14 CFR 

25.625(a)(b)(c) 

Fitting factors 

Enclosure (a) to M-ABOH-14-00022 

Page 6 of 12 

times the limit load. 

(3) Examples of these castings are structural attachment fittings, 

parts of flight control systems, control surface hinges and balance 

weight attachments, seat, berth, safety belt, and fuel and oil tank 

supports and attachments, and cabin pressure valves. 

(d) Noncritical castings. For each casting other than those 

specified in paragraph (c) of this section, the following apply: 

(1) Except as provided in subparagraphs (2) and (3) of this 

paragraph, the casting factors and corresponding inspections must 

meet the follo~ing table: 

Casting I . . . Inspection 

factor 

~~~~-~:-~ore -~100 percent visual. .. 

·Less than 2.0 100 percent visual, and magnetic particle or 

but more penetrant or equivalent 

·.than 1.5 nondestructive inspec!ion methods. 

1.25 through 1 00 percent visual, magnetic particle or penetrant, 

1.50--- and radiographic, or 

approved equivalent nondestructive inspection 

methods. 

(2) The percentage of castings inspected by nonvisual methods 

may be reduced below that specified in subparagraph (1) of this 

paragraph when an approved quality control procedure is 

established. 

(3) For castings procured to a Specification that guarantees the 

mechanical properties of the material in the casting and provides 

for demonstration of these properties by test of coupons cut from 

the castings on a sampling basis--

(i) A casting factor of 1.0 may be used; and 

(ii) The castings must be inspected as provided in subparagraph 

( 1) of this paragraph for casting factors of" 1.25 through 1.50" and 

tested under paragraph ( c )(2) of this section. 

(a) Except as provided in paragraph (b) of this section, each part 

that has clearance (free fit), and that is subject to pounding or 

vibration, must have a bearing factor large enough to provide for 

the effects of normal relative motion. 

(b) No bearing factor need be used for a part for which any larger 

special factor is prescribed. 

For each fitting (a part or terminal used to join one structural 

member to another), the following apply: 

(a) For each fitting whose strength is not proven by limit and 

ultimate load tests in which actual stress conditions are simulated 
14 CFR 25.787(a)(b) 

Stowage 

compartments 

14 CFR 25.789(a) 

Retention of items of 

mass in passenger and 

crew compartments 

and galleys 

14 CFR 25.853(a) 

Compartment 

interiors 

Enc,losure (a) to M-ABOH-14-00022 

Page 7 of 12 

in the fitting and surrounding structures, a fitting factor of at least 

1.15 must be applied to each part of--

(I) The fitting; 

(2) The means of attachment; and 

(3) The bearing on the joined members. 

(b) No fitting factor need be used--

(1) For joints made under approved practices and based on 

comprehensive test data (such as continuous joints in metal 

plating, welded joints, and scarf joints in wood); or 

(2) With respect to any bearing surface for which a larger special 

factor is used. 

(c) For each integral fitting, the part must be treated as a fitting up 

to the point at which the section properties become typical of the 

member. 

(a) Each compartment for the stowage of cargo, baggage, carryon articles, and equipment (such as life rafts), and any other 

stowage compartment must be designed for its placarded 

maximum weight of contents and for the critical load distribution 

at the appropriate maximum load factors corresponding to the 

specified flight and ground load conditions, and to the emergency . 

landing conditions of Sec. 25.561(b), except that the forces 

speCified in the emergency landing conditions need not be applied 

to compartments located below, or forward, of all occupants in the 

airplane. If the airplane has a passenger seating configuration, 

excluding pilots seats, of I 0 seats or more, each stowage 

compartment in the passenger cabin, except for underseat and· 

overhead compartments for passenger convenience, must be 

completely enclosed. 

(b) There must be a means to prevent the contents in the 

compartments from becoming a hazard by shifting, under the 

loads specified in paragraph (a) ofthis section. For stowage 

compartments in the passenger and crew cabin, if the means used 

is a latched door, the design must take into consideration the wear 

and deterioration expected in service. 

(a) Means must be provided to prevent each item of mass (that is 

part of the airplane type design) in a passenger or c~ew 

compartment or galley from becoming a hazard by shifting under 

the appropriate maximum load factors corresponding to the 

specified flight and ground load conditions, and to the emergency 

landing conditions of Sec. 25.561 (b). 

For each compartment occupied by the crew or passengers, the 

following apply: 

(a) Materials (inchiding finishes or decorative surfaces applied to 

the materials) must meet the applicable test criteria prescribed in 

part I of appendix F of this part, or other approved equivalent 

methods, regardless of the passenger capacity of the airplane. 
14 CFR 25.869(a)(4) 

Fire protection: 

systems 

14 CFR 

25.1301 (a)(b )(c)(d) 

Function and 

installation 

14 CFR 25.1309 

(a )(b)( d)(g) 

Equipment, systems, 

and installations 

. 

(a) Electrical system components: 

Enclosure (a) to M-ABOH-14-00022 

Page 8 of 12 

( 4) Insulation on electrical wire and electrical cable installed in 

any area of the airplane must be self-extinguishing when tested in 

accordance with the applicable portions of Part I, Appendix F of 

this part. 

Each item of installed equipment must--

(a) Be of a kind and design appropriate to its intended function; 

(b) Be labeled as to its identification, function, or operating 

limitations, or any applicable combination of these factors; 

(c) Be installed according to limitations specified for that 

equipment; and 

(d) Function properly. when installed. 

(a) The equipment, systems, and installations whose functioning isrequired by this subchapter, must be designed to ensure that they 

perform their intended functions under any foreseeable operating 

condition. 

(b) The airplane systems and associated components, considered 

separately and in relation to other systems, must be designed so 

that--

(1) The occurrence of any failure condition which would prevent 

the continued safe flight and landing of the airplane is extremely 

improbable, and 

(2) The occurrence of any other failure condition which would 

reduce the capability of the airplane or the ability of the crew to 

cope with adverse operating conditions is improbable. 

(d) Compliance with the requirements of paragraph (b) of this 

section must be shown by analysis, and where necessary, by 

appropriate ground, flight, or simulator tests. The analysis must 

consider--

(1) Possible modes of failure, including malfunctions and damage 

from external sources. 

(2) The probability of multiple failures and undetected failures. 

(3) The resulting effects on the airplane and occupants, 

considering the stage of flight and operating conditions, and 

(4) The crew warning cues, corrective action required, and the 

capability of detecting faults. 

(g) In showing compliance with paragraphs (a) and (b) of this 

section with regard to the electrical system and equipment design 

and installation,ccritical environmental conditions must be 

considered. For electrical generation, distribution, and utilization 

equipment required by or used in complying with this chapter, 

except equipment covered by Technical Standard Orders 

containing environmental test procedures, the ability to provide 

continuous, safe service under foreseeable environmental 

conditions may be shown by environmental tests, design analysis, 

or reference to previous comparable service experience on other 
14 CFR 25.1351(a)(l) 

General 

14 CFR 

25.1353(a)(b)(d) 

Electrical equipment 

and installations 

14 CFR 25.1357(a)(c) 

Circuit protective 

devices 

14 CFR 25.1541(a)(b) 

General 

14 CFR 25.1557(a) 

Miscellaneous 

markings and 

placards 

aircraft. 

Enclosure (a) to M-ABOH-14-00022 

Page 9 of 12 

(a) Electrical system capacity. The required generating capacity, 

and number and kinds of power sources must--

(1) Be determined by an electrical load analysis; 

(a) Electrical equipment, controls, and wiring must be installed so 

that operations of any one unit or system of units will not 

adversely affect the simultaneous operation of any other electrical 

unit or system essential to the safe operation. Any electrical 

interference likely to be present in the airplane must not result in 

hazardous effects upon the airplane or its systems except under 

extremely remote conditions. 

(b) Cables must be grouped, routed, and spaced so that damage to 

essential circuits will be minimized if there are faults in heavy 

current-carrying cables. 

(d) Electrical cables and cable installations must be designed and 

installed as follows: 

( 1) The electrical cables used must be compatible with the circuit 

protection devices required by Sec. 25.1357 of this part, such that 

a fire or smoke hazard cannot be created under temporary or 

continuous fault conditions. . (2) Means of permanent identification must be provided for 

electrical cables, connectors and terminals. 

(3) Electrical cables must be installed such that the risk of 

mechanical damage and/or damage caused by fluids, vapors, or 

sources of heat, is minimized. 

(a) Automatic protective devices must be used to minimize· 

distress to the electrical system and hazard to the airplane in the 

event ofwiring faults or serious malfunction of the system or 

connected equipment. 

(c) Each resettable circuit protective device must be designed so 

that, when an overload or circuit fault exists, it will open the 

circuit irrespective ofthe position of the operating control. 

(a) The airplane must contain--

(1) The specified markings and placards; and 

(2) Any additional information, instrument markings, and placards 

required for the safe operation if there are unusual design, 

operating, or handling characteristics. 

(b) Each marking and placard prescribed in paragraph (a) of this 

section-~ 

(1) Must be displayed in a conspicuous place; and 

(2) May not be easily erased, disfigured, or obscured. 

(a) Baggage and cargo compartments and ballast location. Each 

baggage and cargo compartment, and each ballast location must 

have a placard stating any limitations on contents, including 

weight, that are necessary under the loading requirements. 
Enclosure (a) to M-ABOH-14-00022 

Page 10 of 12 

However, underseat compartments designed for the storage of 

carry-on articles weighing not more than 20 pounds need not have 

a loading limitation placard. 

C. The Extent of Relief Being Sought 

Regulations Requirement Why relief is necessary 

14 CFR Part 25 Provide applicable JAMCO oven part number A233-1 has been 

sections: requirements for the previously installed on new 767 -300ER and 767-

25.301 (a)(b)(c) component level 300F airplanes produced by Boeing and delivered 

25.303 certification of JAMCO to All Nippon Airlines (ANA). Since the oven itself 

25. 305( a)(b )(c)( e )(f) oven, part number was not FAA-approved, exceptions were included 

25.307(a)(d) A233-1. on the Export Certificates of Airworthiness for those 

25.561 (a)(b)(c) airplanes per 14 CFR 21.329, citing Japan Civil 

25.601 Aviation Bureau (JCAB) Specification Approval 

25.603(a)(b)(c) Letters which include the oven part number and the 

25.605(a)(b) FAA regulations for which the JCAB indicates 

25.607(a)(b)(c) approval. 

25.609(a)(b) 

25.611 Boeing has been requested by our customer, to 

25.613(a)(b)(c)(e)(f) install the same oven on VS721 as part of the 

25.619(a)(b)(c) Boeing Converted Freighter modification project 

25.621 (a)(b)(c)(d) currently in work. Enclosure (b) is a copy of the 

25.623(a)(b) JCAB Spec Approval Letter (KOKU-KU-KI-114) 

25.625(a)(b)(c) that Boeing has received to support installation of 

25.787(a)(b) the A233-1 oven on the VS721 BCF modification. 

25.789(a) 

25.853(a) 

25.869(a)(4) 

25.1301 (a)(b)(c)(d) 

25.1309( a)(b )( d)(g) 

25.1351 (a)(1) 

25.1353(a)(b)(d) 

25.1357(a)(c) 

25.1541 (a)(b) 

25.1557(a) 

D. Description of the Issue 

Boeing initially proposed to the FAA the use of FCAA waivers for FCAA accepted 14 CFR Part 25 

regulations resulting from Boeing modifications of foreign registered airplanes. The FAA 

responded, via letter 1 OOB-13-57 (dated March 26, 2013), that the OMT did not concur with 

Boeing's proposal because 14 CFR Part 21.329 is not intended to apply to type design changes on 

an aircraft that has been previously exported, and that the proposed change, which is regulated by 

14 CFR Part 21.97, under subpart D, is not covered by section 21.329 for obtaining exception or 

deviation approval of a modification project from an FCAA. · 

The FAA further stated that Boeing may petition for an exemption requesting relief from the 

requirements of a current regulation in a major change to type design project, or for a rulemaking to 

amend section 21.329 to extend the exception or deviation to a major change to type design. 
Enclosure (a) to M-ABOH-14-00022 

Page 11 of 12 

Since 14 CFR Part 21.329 only applies to production airplanes in regard to waiver applicability, and 

is not intended to apply to approval of changes to type design of previously exported airplanes, 

Boeing is seeking relief from the 14 CFR Part 25 requirements identified in Table C above, to allow 

installation of the JAMCO oven (part number A233-1) on VS721 (SIN 32972). As noted in 

Enclosure (b), the oven has been granted Specification Approval by the JCAB to the regulations 

listed above and has been installed on new Boeing production aircraft. Therefore, Boeing is 

requesting an exemption to the listed 14 CFR Part 25 regulations. 

E. Statement of Public Interest 

Granting this exemption would benefit the public by helping to maintain international commercial 

trade of goods and services. It would allow Boeing to provide post-production services equivalent 

to those provided for production aircraft, and result in operational commonality among our 

customer's fleet. Denial of this petition would not be in the public's interest, and would reduce the 

operational capability of the affected aircraft, requiring our customers to operate a mixed fleet, and 

could cause Boeing to lose customers in the aircraft modification market, resulting in reduced 

potential US Gross Domestic Product. 

F. Statement of No Adverse Effect on Safety 

The oven to be installed on VS721 (S/N 32972) has been previously installed on new 767-300ER 

and 767 -300F model airplanes delivered to ANA. There have been no safety issues with the 

installation of these ovens on the airplane. Granting this exemption would allow Boeing to install 

the same part as delivered on ANA's productions airplanes, providing ANA functional commonality 

among its fleet. 

G. Request to Waive Publication and Comment 

Based on the limited scope of this proposed exemption (one airplane}, Boeing respectfully 

requests that the public comment period be deemed not required for this exemption. 

H. Conclusion 

Boeing Commercial Airplanes requests exemption from the listed 14 CFR Part 25 regulations for 

the certification of JAMCO oven A233-1 to be installed on Boeing 767-300BCF model airplane, 

VS721 (S/N 32972}. 

I. Privileges of this Exemption Outside the United States 

Per§ 11.81 (h), Boeing requests that the privileges of this Exemption be extended outside of 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 standard for transport category aircraft. 

Summary to be Published in the Federal Register 

PETITIONER: Boeing Commercial Airplanes 
Enclosure (a) to M-ABOH-14-00022 

Page 12 of 12 

SECTION OF 14 CFR AFFECTED: 14 CFR Part 25 regulations per the model certification basis 

as defined by Type Certification Data Sheet A 1 NM provided below: 

25.301 (a)(b)(c) 25.605(a)(b) 25.623(a)(b) 25.1309(a).(b )(d)(g) 

25.303 25.607(a){b)(c) 25.625(a)(b)(c) 25.1351 (a)(1) 

25 .305( a)(b ){c)( e )(f) 25.609(a){b) 25.787(a)(b) 25.1353(a)(b)(d) 

25.307(a)(d) 25.611 25.789(a) 25.1357(a)(c) 

25.561 (a)(b)(c) 25.613(a)(b)(c)(e)(f) 25.853(a) 25.1541(a)(b) 

25.601 25.619(a)(b)(c) 25.869(a)(4) 25.1557(a) 

25.603(a)(b)(c) 25.621 (a)(b)(c)(d) 25.1301 (a)(b)(c)(d) 

DESCRIPTION OF RELIEF SOUGHT: To permit the installation of an A233-1 JAMCO oven that 

has been installed on previously-delivered production airplanes when the FCAA has provided 

acceptance of the oven via letter to the FAA, for the modification of a foreign registered 767-300ER 

to a Boeing Converted Freighter configuration. Allowance will permit Boeing to install an FCAA 

accepted oven on a 767-300ER airplane during modification to a Boeing Converted Freighter 

configuration. 
Civil )f.viation (Bureau 

Enclosure (b) to M-ABOH-14-00022 

Page 1 o£3 

9dinistry Of £atuf, Irifrastnu:ture, tfransport}f.tuftfourism 

2-1-3, Kasumigaseki, Chiyoda·ku, 

KOKU-KU-KI-114 

Mr. Ross Landes 

Manager, ANM-1 OOS 

Department ofTranspotiation 

Federal Aviation Administration 

Seattle Aircraft Certification Office 

1601 Lind Avenue SW 

Renton, WA 98057-3356 

USA 

Dear Mt: Landes, 

TOKYO 100·8918, JAPAN 

Aug 7, 2013 

An All Nippon Airways' (ANA) Boeing 767-300 airplane (Registration Number JA603A, Block 

Number VS721) is now under the Boeing convetted freighter modification work at SASCO Modification 

Center, Singapore. This modification will be approved thi:ough Boeing Service Bulletins (SBs) by the FAA. 

This letter notifies you that certain equipment furnished by ANA, which is to be 

installed on the airplanes, has been granted Specification Approvals by the JCAB as shown in 

Attachment I. The compliance list with the applicable FAR requirements for the equipment 

is shown in Attachment II, which has been determined in the course of Specification Approval. 

Status of amendment of the FAR requirements in Attachment II corresponds to that of the 

certification basis ofB767·300F (FAA Type Certificate Data Sheet No. AlNM). 

It would be highly appreciated if you take into account of our approval when you 

approve SBs for B767·300BCF modification. 

Thank you for your consideration in advance. If you need any further information, 

please contact us. 

Sincerely, 

r::~ JM<Wlk 

Yasuhiro Yamada 

Chief Airworthiness Enginee1· 

Airworthiness Division 

C. C. Mr. Takeo Kikuchi 

Director, Engineering 

All Nippon Airways Co., LTD. 

Attachment I 

n 

BFE List per Each Mamifacturer 

FAR Compliance List 
KOKU-KU-KI-114 

Enclosure (b) to M-ABOH-14-00022 

Page 2 of3 

Attachment #I 

Equipment List per Each Manufacturer 

MANUFACTURER: JAMCO CORPORATION 

PARTS NAME 

Oven 

PART 

NUMBER 

A233-1 

DRAWING 

NUMBER 

A233 

S.A. NUMBER 

394 
KOKU-KU-KI-114 

Applicable JAM CO 

FAR Requirements A233-1 

Oven 

Subpart C 1§25.301 0 

Structure !§25.303 0 

1§25.305 0 

1§25.307 0 

1&25.561 0 

SubpartD [§25.601 0 

Design and [§25.603 0 

Construction 1§25.605 0 

1&25.607 0 

1&25.609 0 

[§25.611 0 

1§25.613 0 

1&25.619 0 1

&25.621 0· 

,&25.623 0 

1&25.625 0 

_.:;:;, [§25.785 0 

[§25.787 0 

1&25.789 0 

1&25.853 0 

[§25.869 0 

SubpartF [§25.1301 0 

Equipment 1&25.1309 0 

1§25.1351 0 

1&25.1353 0 ~ 1&25.1355 0 

1&25.1357 0 ~ 1&25.1363 0 

Subpart G 1&25.1541 0 

Operating Limitations §25.1557 0 

and Information 

Appendix F to Part 25 0 

Note; 

"0" denotes applicable, thru Amendment 25-117 

FAR Compliance List 

Endosure (b) to M-ABOH-14-00022 

Page 3 o£3 

Attachment #2 

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