rzi-aoE.ING 

CP-L4L-15-00 122 

May I, 2015 

U.S. Department of Transportation 

Docket Operations M-30 

1200 New Jersey A venue, SE 

Room WI2-140, West Bldg. Ground Floor 

Washington DC 20590-0001 

·-. j 

Attention: FAA Transport Airplane Directorate 

Applicant: The Boeing Company 

Boeing Commercial Airplanes 

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Southern California Engineering Design Center 

2401 E. Wardlow Road, Mail Code D800-0022 

Long Beach, CA 90807-5309 

Contact: Mr. Thomas A. Enyart 

Email: Thomas.a.Envart@boeing.com 

Phone: (562) 797-8956 

Seal Beach, CA 90740-1515 

The Boeing Company 

2401 E. Wardlow Road 

Long Beach, CA 90807-5309 

Subject: Petition for Exemption from 14 CFR §Part 26, 26.21 (b)(2)(ii) for the Boeing 

Model DC-8 airplanes as related to the list of maintenance actions not yet 

developed. 

References: 

(a) Docket No. F AA-2006-2481, Widespread Fatigue Damage issued May 24, 2012, Title 14, Code 

of Federal Regulations ( 14 CFR) 26.21 (b )(ii) 

(b) Boeing Document MDC 12K9001 DC-8 Widespread Fatigue Damage Summary Document, 

datedJuly 11,2012 

(c) Boeing Letter RA-14-01655 dated April 10,2014 Petition for Exemptionfrom Title 14, Code of 

Federal Regulations (14 CFR) 26.21(b)(ii) ,"Limit of Validity", for Model 737CL 

Certification Item No: 4 7984 

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 Boei"ng Model DC-8 airplanes as 

related to the list of maintenance actions not yet developed. The original Boeing Inspection Start 

Point (ISP) maintenance calculation has significantly changed with the DC8 fleet reduction. 

Within the reference (a) Widespread Fatigue Damage (WFD) final rule, §26.21 (b)(2)(ii) requires 

a Type Certificate Holder (TCH) to submit a list identifying each of those maintenance actions 

for which service information has not been mandated by airworthiness directive as of January 14, 
Page 2 of3 

CP-L4L-15-00 122 

20 II and a binding schedule for providing in a timely manner the necessary service information 

for those actions. 

Reference (b), the Boeing DC-8 Widespread Fatigue Damage Summary Document, provides the 

list of those maintenance actions not yet in the form of Boeing service bulletins (SB) as well as a 

binding date by which those maintenance actions will be issued as new SBs and will be 

submitted to the FAA. The Boeing proposed SBs to be published, would address the DC-8 wing 

lower skin for some DC-8 airplanes and which has a binding schedule date of September 30th 

2016 for submittal ofthe new inspection SB 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 proposed new service bulletin revealed that the 

Inspection Start Point (ISP) would occur after the Limit ofYalidity (LOY) for the remaining 

DC8 series airplanes. At the LOY, any active airplanes would be withdrawn from service. In 

light of this, there is no need for Boeing to publish a new service bulletin. As a result, Boeing is 

respectfully petitioning that the service action with proposed new 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. 

Boeing previously submitted a request for a similar exemption reference (c) for a WFD related 

737CL proposed revision to an existing 737CL service bulletin. This request was granted as 

Exemption No. II 026. 

Background 

As the result of a WFD analysis a proposed new 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 publication of a proposed new service bulletin would 

provide instructions to repetitively inspect the lower wing skin at the outer row of fasteners of 

the external production doublers at wing station Xw = 408, no later than an Inspection Start Point 

(ISP). 

The original DC-8 fleet-consisted of 556 airplanes. The proposed new service bulletin would be 

addressing only the 139 DC-8 airplanes constructed with the external doublers configuration. Of 

these 139 airplanes, Ill are believed to be permanently out of service. Last year the potentially 

active fleet for all DC-8 series aircraft was 33 airplanes, but at least 5 of those were built without 

the external doubler configuration. Boeing assumed the potentially active DC-8 fleet with the 

external doubler configuration was 28 worldwide. Out of 33 DC-8s, only 12 of those reported 

being commercially active in the world during most recent 36 month period, and less than 5 

active DC-8 aircraft in the last 18 months. Therefore, Boeing used 28 potentially active airplanes 

with the doubler configuration in the most recent re-analysis. 

At the time of the original WFD Part 26 rule compliance date Boeing did not anticipate the rapid 

acceleration of the rate of permanent retirements for DC-8 series aircraft. Operators of the DC-8 

reported 90 commercially operated airplanes in 2008. Operators of the DC-8 reported over 30 

commercially operated airplanes during 20 II. Early last year operators reported only a couple 

airplanes in commercial operation. At present no DC-8 operators, with this structural doubler 

configuration, are reporting commercial flights. *Since the most recently active airplanes each 

had a 20,000 flight cycle margin prior to LOY, even if these airplanes were returned to service, 

the chances any of these airplanes reaching the proposed ISP or LOY limit before retirement is 

highly unlikely. 
Page3of3 

CP-L4L-15-00 122 

• Note: There are two government owned and operated DC-8s that have flights which are 

not commercial but these were still accounted for in the 28 airplanes counted as 

potentially active last year used in the most recent re-analysis. 

Noting that a conservative analysis approach was used originally, the WFD analysis was 

recalculated and the resulting Inspection Start Point (ISP) exceeds the LOY of 56,000 flight 

cycles for these airplanes. Boeing met with the Los Angeles Aircraft Certification Office 

(LAACO) on April 30, 2015 to present the specific .details of the technical analysis. The FAA 

accepted the analysis as presented. Therefore, no additional service actions are required to 

address WFD and there is no reason to issue a proposed new service bulletin by the binding 

schedule date of September 30, 2016. 

Safety 

The recalculated ISP for the maintenance actions for the proposed new service bulletin exceeds 

the LOY. At the LOY, any active airplanes would be withdrawn from service. In light of this, 

there is no need for Boeing to publish a new service bulletin. 

Justification for Exemption: 

The DC8 fleet has reduced significantly with no commercial operations reported this year to 

Boeing. Exemption of the proposed new service bulletin from the requirements of 14 CFR 

26.21 (b )(2)(ii) would have no adverse affect on pub! ic safety. Exclusion of the proposed new 

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 proposed or existing 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 proposed new service bulletin. 

Therefore, granting this exemption would reduce the burden on FAA resources and consequently 

public expenditure. 

Sincerely, 

Tim Hendrix 

Manager, Certification & Airworthiness 

Southern California Engineering Design Center 

Boeing Commercial Airplanes 

(562) 593-7074, MC 0800-0022 

TE/DP:ap 

Enclosure: Reference (c) 
APR U 0 2014 

RA-14-01655 

The BOeing Company 

P.O. Box 3707 

Seattle. WA 98124-2207 

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Avenue S.E. 

Room Wl2-140, West Bldg. Ground Floor 

Washington, DC 20590-0001 

Subject: 

Model: 

RA Project No.: 

EASA Project No.: 

EASA Level: 

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 

NIA 

NIA 

NIA 

(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 dared November 26, 

2013 

Please forward a copy to FAA Specialist Alan 

Rauschendorfer (ANM-1 OOS) 

(X) Petition for Exemption 

This Jetter 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 th.e list of maintenance actions not 

mandated by Airworthiness Directives. 

The subject letter supersedes the reference (d) letter dated November 26, 2013. 
I 

~O.EIND 

APR U 0 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, 

/or /-1~ 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-Ol 

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 Federal 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) ofthis 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 

14 CFR 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 of those 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 Safety 

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 Federal 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 737-52A1038 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.