FAA FAR 21.9 Exemption

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Name and Mailing Address

Boeing

Boeing-Cargo Helicopter Sustainment 

PO Box 16858

Philadelphia, PA 19142-0858

Care of: Steven Dooley

Mail Stop P01-05

Summary

Current FAR Part 21.9 requires manufacturers of aircraft replacement parts, who sell those parts for 

installation on a certified product, to hold an FAA Production Approval for those parts. This request for 

exemption is based on Boeing being the original designer and manufacturer of the CH-47D aircraft 

which have been sold as surplus to civil operators. Those operators have obtained restricted category 

airworthiness certificates for their CH-47D helicopters. Surplus parts sold by the US Army are eligible for 

installation on these restricted category Chinooks, and these surplus were designed by Boeing and 

either manufactured or procured by Boeing in accordance with the Boeing design. Boeing is seeking an 

exemption from the requirement of FAR Part 21.9 for the purpose of selling replacement parts for 

installation on CH-47D Chinook helicopters certified under FAR 21.25 (a) (2) and operated as restricted 

civil helicopters. Boeing will use the same Defense Contractor Management Agency (DCMA) approved 

production and quality control system to produce new parts for these Civil Registered Chinooks as was 

used to manufacture the helicopters and replacement parts for the US Army, thus there is no adverse 

impact to safety or benefit to the public for Boeing to obtain a separate FAA production approval for 

these parts. To develop and maintain an FAA production approval system would pose an additional 

burden on Boeing without providing any added benefit to the public.

CFR from Which Exemption is Sought

FAR Part 21.9 requires manufacturers of aircraft replacement parts, who sell those parts for installation 

on a certified product, to hold an FAA Production Approval for those parts. Boeing is seeking an 

exemption from this requirement for the purpose of selling replacement parts for installation on CH-47D 

Chinook helicopters certified under FAR 21.25 (a) (2) and operated as restricted civil helicopters.

The Extent of Relief Sought and Reason

Boeing is the current manufacturer of CH-47F aircraft which are derived from and in general share 

common rotor head, blades, drive, control and hydraulic systems, landing gear utility systems and cabin 

installations with the CH-47D. Most of the parts required by operators of civil restricted category 

Chinooks are common between the D and F and would be supplied from current US Army managed 

production systems. Thus these are the same parts produced in the same manner under the same 

controls as what are acceptable, if sold as surplus by the US Army, for installation on these civil CH-47D 

helicopters under FAR 21.9 (c).
FAA FAR 21.9 Exemption

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How Request Would Benefit the Public as a Whole

These CH-47D civil operators are seeking, or have obtained, contracts from the US Forest service to 

provide forest or wild fire fighting contracts. The CH-47D is an aircraft well suited for these aerial 

firefighting efforts with capability for carrying a several thousand gallon water bucket suspended under 

the aircraft or with an internal water/foam suppressant tank. Firefighting is a service to the US 

Government and provides the attendant benefit to the public of reducing or eliminating property 

damage and hazards associated with forest fires. Providing rapid response to fires through helicopter 

water tankers also reduces the potential loss of life or injury for ground based firefighters. Granting this 

exemption would allow these operators to obtain the required parts to support these operations sooner

and without having to wait for Boeing to obtain the otherwise necessary FAA production approvals for 

these parts.

Another potential use for these helicopters is stream reclamation work to restore damaged streams to 

closer to their natural configuration by placing forest debits in the stream to slow water flow and reduce 

run-off and erosion. One of the ways this is accomplished is through use of rotorcraft to move and place 

logs, rocks, and associated fill into waterways, thus promoting more conducive environments for fish. 

The demilitarized restricted type certificated CH-47D is again well positioned to serve this market due to 

its heavy lift, precision placement, and long line capability.

In addition, Federal and State agencies support relief efforts when natural disasters happen across the 

US, and will routinely contract with commercial operators to provide and supplement the services 

rendered by the National Guard. Aerial support is a key component of these programs and the CH-47D 

is capable of filling this requirement in an exemplary fashion.

In addition, by utilizing the existing process oversight provided by the DCMA here at Boeing, there is no 

additional FAA burden in the production and sale of these parts.

Why the Exemption Would Not Adversely Affect Safety, or How the Exemption Would Provide a Level 

of Safety at Least Equal to the Existing Rule

The design used for production of these parts is the same as what Boeing has developed and maintained 

for the US Army. The CH-47D is part of the Chinook helicopter evolution over the last 50 years, from the 

YCH-47, CH-47A, CH-47B, CH-47C to the CH-47D, the latter resulting from a modification program of the 

previous three CH-47 models. Subsequently Boeing, under contract with the US Army, has developed 

the CH-47F to replace all of the Army’s CH-47D aircraft. The CH-47F uses all the same basic aircraft 

systems of the CH-47D, which are removed from retired “Ds”, overhauled and reinstalled in new 

airframes.

MH-47E and MH-47G are Special Forces versions of the Chinook with large fuel tanks and other 

equipment for that mission. These aircraft also share the same rotor, drive and mechanical hydraulic 

control system as the CH-47D and –F.
FAA FAR 21.9 Exemption

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Safety is not adversely affected by this exemption request as the parts in question are the same parts as 

were originally produced and used to manufacture the Chinooks or currently manufactured or procured

by Boeing as replacement parts for the US Army. These parts are manufactured in accordance with the 

Boeing Quality Management System (QMS). This QMS is overseen by the US Government through the 

Defense Contractor Management Agency (DCMA), and is part of our AS9100 Certification. In addition,

the QMS is the same system used to support our PMA approvals for Columbia Helicopters Inc. Model 

107-II and 234 helicopters designed and built by Vertol, Boeing Vertol or Boeing. Thus safety is not 

adversely affected by this exemption request.

This exemption will be limited to only those parts that are authorized by the Boeing engineering 

configuration as eligible for installation on the CH-47D. Should Boeing wish to add additional parts to 

the CH-47D after this time, the configuration change would require US Army approval for that change. 

Boeing could also obtain FAA PMA or STC approval for installation of such new parts on the current 

approved CH-47D type designs.

If you want to exercise the privileges of your exemption outside the United States, the reason why 

you need to do so

This request is only to support sale and shipment of parts to domestic CH-47D Civil Chinook operators

based in the USA.