# ~DEI.IVD

9R-TE-BBXA-BRB-14-0769 December 2, 2014

Docket Management Facility U.S. Department ofTransportation 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 ofExemption 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 ofExemption 8825 from 14 CFR, Sections 61.57(a) & 

### (b)," dated August 18, 2014 [Enclosure 2] (d) Seattle FSDO email, SUBJECT: PilotType Rating for P-81, dated April25, 2012 [Enclosure 3]

The Boeing Company was granted, by Reference (a), an exemption from the requirements ofthe 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 ofexemption from the Subject regulatory requirements that permits any Boeing pilot, who is type-rated in one ofthe 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 ofBoeing airplane, specified in Condition and Limitation No. 2 ofthe exemption, or 2. A Level B, C or D simulator that represents any ofthe 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 ofthe 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 ofidentified Boeing airplane or a simulator representative ofany type ofidentified 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 ofsafety

# ~OEING

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

### 2, 2014

maintained

. To support continued use ofthe reliefprovided by the Reference (b) exemption, Boeing submitted the Reference (c) letter petitioning the FAA for renewal ofthat 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 ofExemption 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 takeoffand 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 ofview, the P-8I flies like any othercommercial customer's 737-800. Boeing Defense, Space and Security division (BDS) operates the P-8I airplanes on FAA Special Airworthiness Certificates in the category ofExperimental for the purpose ofResearch 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 of737-8FV 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 ofqualifying airplanes to include military commercial derivative airplanes such as the P-8I that retain the flight characteristics ofthe 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 ofa 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 ofqualifying airplanes. Boeing therefore requests that the wording of Condition and Limitation No. 2 ofExemption 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
, A16WE, A20WE, A2NM, A 1NM, 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 ofCondition and Limitation No

. 3 ofthe Reference (b) exemption, allowing the use ofLevel 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 requi rements 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-manufactu red 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 A2N M
, 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 ofthis intermittent request for a change to the wording ofCondition and Limitation Nos. 2 and 3 ofthe Reference (b) exemption be expedited to provide continuous coverage.

Please contact Colin S. Fender at (206) 544-1974 with any questions orcomments 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

### Enclosure 1 to Boeing Letter 9R-TE-BBXA-BRB-14-0769 Page 1 of 4

### Enclosure 1 to Boeing Letter 9R-TE-BBXA-BRB-14-0769 Page 2 of 4

### Enclosure 1 to Boeing Letter 9R-TE-BBXA-BRB-14-0769 Page 3 of 4

### Enclosure 1 to Boeing Letter 9R-TE-BBXA-BRB-14-0769 Page 4 of 4

### Enclosure 2 to Boeing Letter 9R-TE-BBXA-BRB-14-0769 Page 1 of 2

### Enclosure 2 to Boeing Letter 9R-TE-BBXA-BRB-14-0769 Page 2 of 2

### Enclosure 3 to Boeing Letter 9R-TE-BBXA-BRB-14-0769 Page 1 of 1