FAA FAR 21.9 Exemption White Paper **N ame and M**  **ailing A** **ddr ess**  Boeing Boeing - Cargo Helicopter Sustainment PO Box 16858 Philadelphia, PA 19142 - 0858 Care of: Steven Dooley Mail Stop P01 - 05 **Summary** Cu rrent FAR Part 21.9 requires manufacture r s of aircraft replacement parts, who sell those parts for installation on a certified product , to hold an FAA Producti on Approval for those parts. This request for exemption is b ased on Boeing being the original d esigner and manufacturer of the CH - 47D aircraft which have been sold a s surplus to civil operators . Those operators have obtained r estricted category airworthiness certificates for their CH - 47D helicopters . Surplus parts sold by the US A rmy are eligible for installation on the se restricted category Chinooks , and these surplus were desi gned 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 us e 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 th e helicopters and replacement parts for the US Army, thus there is n o 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 be nefit to the public. **CFR from Which E xemption**  **is Sought** FAR Part 21.9 requires manufacture r s 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 o perators 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 man ner 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 White Paper **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 pr ovide 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 suppr essant 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 th e 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, Fe deral 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 n o additional FAA burden in the production and sale of thes e 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 latt er resulting from a modification program of the previous three CH - 47 models. Subsequently Boeing, under contract with the US Army, has developed the CH - 47 F 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. M H - 47E and M H - 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 White Paper 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 manufacture d or procure d by Boeing as replacement parts for the US Army. T hese 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 b e 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 part s 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 y** **ou 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 .