~DEI.IVD 

9R-TE-BBXA-BRB-14-0769 

December 2, 2014 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Attention: Federal Aviation Administration 

Director, Flight Standards Service, AFS-1 

The Boeing Company 

P.O. Box 3707 

Seattle, WA 98124-2207 

Subject: Petition for Revision of Exemption 8825 from 14 CFR, Sections 61.57(a) & (b) 

References: (a) Exemption No. 6843, Regulatory Docket No. FAA-2000-7945, 14 CFR Sections 

61.57(c) and (d), dated November 20, 1998. 

(b) Exemption No. 8225C, Regulatory Docket No. FAA-2000-7945, 14 CFR Sections 

61.57(a) and (b), dated December 5, 2012 [Enclosure 1]. 

(c) Boeing Letter 9R-TE-BBXA-BRB-14-0562, "Petition for Revision of Exemption 8825 

from 14 CFR, Sections 61.57(a) & (b)," dated August 18, 2014 [Enclosure 2] 

(d) Seattle FSDO email, SUBJECT: Pilot Type Rating for P-81, dated April25, 2012 

[Enclosure 3] 

The Boeing Company was granted, by Reference (a), an exemption from the requirements of the noted 

regulations that specified the requirements for pilot recent experience. As 14 CFR Part 61 was amended, 

the requirements of 14 CFR Sect. 61.57(c) and (d) became the current 14 CFR Sect. 61.57(a) and (b) as 

reflected in the Reference (b) exemption (Enclosure 1 ). 

Reference (b) is the most recent renewal of exemption from the Subject regulatory requirements that 

permits any Boeing pilot, who is type-rated in one of the Boeing airplane types identified in the Type 

Certificated Data Sheets (TCDS) listed in Condition and Limitation No. 1, to conduct the takeoffs and 

landings required by 14 CFR Sect. 61.57(a) and (b) in: 

1. Any type of Boeing airplane, specified in Condition and Limitation No. 2 of the exemption, or 

2. A Level B, C or D simulator that represents any of the Boeing airplanes specified in Condition and 

Limitation No. 2 subject to the conditions specified in Condition and Limitation No. 3, which 

include minimum airplane flight time requirements. 

The rationale and need for renewal of the Reference (b) exemption have not changed from the original 

application- by permitting the requirements of§ 61.57(a) and (b) for recent flight experience to be met 

in any type of identified Boeing airplane or a simulator representative of any type of identified Boeing 

airplane, as opposed to each airplane type for which a pilot holds a type rating has, over the years, 

increased Boeing's ability to efficiently conduct business with no impact to the level of safety 
~OEING 

9R-TE-BBXA-BRB-14-0769 

December 2, 2014 

maintained. To support continued use of the relief provided by the Reference (b) exemption, Boeing 

submitted the Reference (c) letter petitioning the FAA for renewal of that exemption. Boeing has since 

realized it has an airplane in its test fleet that does not meet the eligibility criteria specified in Condition 

and Limitation Nos. 2 and 3 in a literal sense but does meet the intent. Consequently, Boeing is 

submitting this letter as a replacement for the Reference (c) letter to petition the FAA for minor revisions 

to the Reference (b) exemption. 

With this petition for renewal of Exemption 8825C, Boeing would like to request a minor wording 

change to Condition and Limitation Nos. 2 and 3 to further increase the company's flexibility to ensure 

our qualifying pilots are able to meet the takeoff and landing requirements of§ 61 .57(a) and (b). In 

addition to the airplanes identified in the Type Certificate Data Sheets (TCDS) listed in Condition and 

Limitation Nos. 2 and 3, the Boeing Commercial Airplane company also produces a maritime 

surveillance airplane, the P-8I, for the Indian Navy that is identified as a Boeing customer model 737-

8FV on the airplane identification plate. The P-8I is a 737-800 (TCDS Al6WE) that incorporates 

modifications required to perform its maritime surveillance role. However, from a flight characteristics 

point of view, the P-8I flies like any other commercial customer's 737-800. Boeing Defense, Space and 

Security division (BDS) operates the P-8I airplanes on FAA Special Airworthiness Certificates in the 

category of Experimental for the purpose of Research and Development and Market Survey. The 

Operating Limitations associated with those Experimental airworthiness certificates include a 

requirement for the pilot in command to hold either an appropriate type rating or a Letter of 

Authorization (LOA) issued by an FAA Flight Standards Operation inspector. Discussions with the 

Boeing Principal Operations Inspector (POI) at the Seattle Flight Standards District Office (SEA FSDO) 

led to the agreement that a 737 pilot type rating was appropriate for operation of 737-8FV P-8I airplanes, 

as documented by the Reference (d) email [Enclosure 3]. 

Based on the discussion in the preceding paragraph, Boeing would like to expand the list of qualifying 

airplanes to include military commercial derivative airplanes such as the P-8I that retain the flight 

characteristics of the commercial airplane model from which they are derived. Boeing proposes to 

implement this expansion by adding the word "manufactured" after "Boeing Commercial Aircraft 

[NOTE: Aircraft should be Airplanes] (BCA)" in Condition and Limitation Nos. 2 and 3 and, as was the 

case for the P-8I, to use the applicability of a pilot type rating in the commercial airplane model from 

which the military variant was derived, as deemed by a FAA Flight Standards Operations Inspector, as 

justification for the expansion of qualifying airplanes. Boeing therefore requests that the wording of 

Condition and Limitation No. 2 of Exemption 8825C be changed to read as follows: 

2. Each PIC subject to this exemption meeting the requirements of§ 61.57(a) Sf-and (b) in any 

type of Boeing airplane listed in Boeing aircraft type certificate data sheets (TCDS) A6WE, 

A 16WE, A20WE, A2NM, A 1 NM, GR-T00001 SE, or T00021 SE, and Boeing Commercial 

Airor=aft Airplanes (BCA) manufactured experimental aircraft in developmental and 

certification flight test programs for which a pilot type rating in a Boeing airplane listed in 

TCDS A6WE, A16WE, A20WE A2NM, A1NM, T00001SE orT00021SE is deemed to be 

appropriate by a FAA Flight Standards Operations Inspector, will be considered to have 

met the requirements of§ 61.57(a) and (b) for all those types of Boeing aircraft. 
9R-TE-BBXA-BRB-14-0769 

December 2, 2014 

Similarly, Boeing requests that the introductory wording of Condition and Limitation No. 3 of the 

Reference (b) exemption, allowing the use of Level B, CorD simulators to meet the requirements of§ 

61.57(a) and (b), be revised to read: 

3. Each PIC subject to this exemption may meet the requirements of§ 61.57(a) and (b) in a 

simulator that represents any Boeing aircraft listed in Boeing aircraft type certificate data 

sheets (TCDS) A6WE, A1 6WE, A20WE, A2NM, A1 NM, GR--T00001SE, or T00021SE, and 

BCA-manufactured experimental aircraft in developmental and certification flight test 

programs, in which the person tG-will serve as PIC, for which a pilot type rating in a Boeing 

airplane listed in TCDS AGWE, A16WE, A20WE A2NM, A1 NM, T00001SE or T00021 SE is 

deemed to be appropriate by a FAA Flight Standards Operations Inspector, will be 

considered to have met the requirements of § 61.57(a) and (b) for all those types of Boeing 

aircraft. 

The Boeing Company requests that the revised exemption retain the current two-year renewal period. 

Since the Reference (b) exemption will expire on January 31,2015, Boeing respectfully requests that the 

processing of this intermittent request for a change to the wording of Condition and Limitation Nos. 2 

and 3 of the Reference (b) exemption be expedited to provide continuous coverage. 

Please contact Colin S. Fender at (206) 544-1974 with any questions or comments related to this matter. 

Sincerely, 

Caitlin M. Randles 

Supervisor, Flight Test Engineering 

FAA Coordination, M/C 14-KF 

Tel. (206) 304-0075 

Fax (206) 544-9875 

Enclosures: 1. Exemption 8825C 

2. Boeing Letter 9R-TE-BBXA-BRB-14-0562 

3. Seattle FSDO email 
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