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6-1 032-GQA-MKQ15-440 

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Subject: Petition for Renewal of Existing Exemption from 14 CFR 45.29(b)(1)- Temporary 

Aircraft Registration Markings 

Reference: Exemption No. 8429D, Grant of Renewal of Exemption, Regulatory Docket No. 

FAA-2004-18023, dated October 22,2013 

The Boeing Company (Boeing) hereby petitions for a renewal of the referenced Grant of 

Exemption from Title 14 CFR, Section 45.29(b)(1 ). The cited regulation requires registration 

markings for fixed-wing aircraft to be at least 12 inches in height. 

Exemption 84290 was granted by the Federal Aviation Administration (FAA) for all Boeing aircraft 

flying under the authority of a Special Flight Permit, issued pursuant to 14 CFR 21.197(a)(3), for 

Production Acceptance Flights prior to the aircraft being painted with the particular customer's 

livery and permanent registration markings, compliant with 45.29(b)(1 ), of the country of intended 

registry. 

The Boeing Quality Management System, approved by the FAA Certificate Management Office, 

has provisions/processes in place to utilize "window numbers" for the display of registration 

marking per 14 CFR 45.23(a). The "window numbers" are mounted for display on the interior side 

of the aft six (6) windows of the aircraft, both sides, and are retained in place by sliding the 

window shade to the closed position thereby trapping the letter/number designation placard 

against the window and meeting the registration marking location requirements of 14 CFR 

45.25(b)(2). Additionally, the temporary registration markings or placards, as installed noted 

previously, comply with the spacing requirements of 14 CFR 45.29(e) and the width requirements 

required by 14 CFR 45.29(c). 
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it is considered the practice employed complies with the contrast requirements of 14 CFR 

45.21 (c)(3). However, due to the size limitations of the aircraft window itself, the characters 

displayed within the aircraft aft windows range in height from 11.87" to 11.93", which does not 

meet the 14 CFR 45.29(b )( 1) requirement for minimum 12 inches in height. 

Boeing was granted the initial Exemption from 14 CFR 45.29(b)(1) based on our intent to utilize 

the "window numbers" only when aircraft are being flown, unpainted, from Boeing Field. Our "B1 " 

flight departures from our Renton manufacturing facility have a temporary "N" registry that is 

applied using temporary paint on the exterior of the aircraft and fully comply with the requirements 

of the previously cited CFR's. When it is necessary to fly the airplane from Boeing Field for 

Production Acceptance Flights prior to the aircraft being painted, the temporary "N" registration 

applied at the Renton manufacturing facility is removed, and the Boeing Field Customer Delivery 

Center (CDC) then installs the temporary registration characters between the window and window 

shade as previously described. We believe the installation of the "window numbers" for this 

purpose, and in the manner described, complies with the requirements of 14 CFR 45.21 (d)(2). 

For the record, Boeing does not deploy this practice of "window numbers" for any aircraft intended 

to be operated under the auspices of 14 CFR 21 .197(a)(5) as the aircraft will have been painted 

with the Customer's livery and registration. Lastly, we do not deploy this practice for any aircraft 

being operated under 14 CFR 21 .191 Experimental Certificates. 

All conditions which were in place upon granting of Exemption 8429D remain in effect with no 

changes to process steps initiated. However, the Exemption provides relief from §45.29(b)(1) to 

allow the use of ''window numbers" at the following locations: (1) Boeing Field; (2) Renton 

Municipal Airport; and (3) Paine Field Everett. With this petition for extension, Boeing requests 

the FAA also allow the practice at our Boeing South Carolina facility (Airport ID CHS, Charleston 

AFB-International Airport). 

In conclusion, we believe there are no adverse affects on the safety of the public because the 

aircraft in question, utilizing the ''window numbers" process, have operating limitations associated 

with the Special Flight Permit issued to Boeing for Production Acceptance Flights that control/limit 

the operation regime and locations of the aircraft. In addition, all aircraft operated under this 

process have aboard a Dealer Aircraft Registration Certificate, FAA Form 8050-6, issued for the 

aircraft via 14 CFR Part 47, Subpart C. 

Granting of this renewal is in the public interest because it enables Boeing to limit costs and 

remain competitive in the international aviation market, given the importance of the sale of 

commercial jet aircraft on the U.S. balance of trade, by allowing continued delivery of airplanes in 

a timely and cost effective manner while maintaining the intended levels of safety and quality. 
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response to our request to extend our existing Exemption 84290, and to also include allowance of 

the practice at our Boeing South Carolina facility. 

If additional information is required pursuant to this petition, please do not hesitate to contact the 

undersigned, or Michael K. Quinn at 425-237-2438. 

Kim Durnwirth, Director 

Regulatory & Quality System Oversight 

Boeing Commercial Airplanes 

P.O. Box 3707, MC 67-XC 

Seattle, Washington 98124-2207 

(425) 717-3778