Petition for Extension of Limitation from Exemption No. 10193 

The Boeing Company 

Douglas M. Lane, Director, Commercial Airplanes 

The Boeing Company 

PO Box 3707 

Seattle, Washington, 98124 

Section(s) of the Regulations from which Relief is Sought: 

Section 25.1535, as specified in Appendix K, § K25.1.4(a)(3) - Low-fuel alerting. 

K25.1.4(a)(3) - An alert must be displayed to the flight crew when the quantity of fuel available 

to the engines falls below the level required to fly to the destination. The alert must be given 

when there is enough fuel remaining to safely complete a diversion. This alert must account for 

abnormal fuel management or transfer between tanks, and possible loss of fuel. This paragraph 

does not apply to airplanes with a required flight engineer.

The Extent of Relief Sought and Reason(s) 

Regulation Requires: Relief is Necessary because: 

Limitation from FAA 

Exemption No. 10193

Extension of time limitation 

established in FAA Exemption 

No. 10193 until January 14, 2015

A) The AIMS software updates needed 

to make Boeing 777 model airplanes 

compliant to K25.1.4(a)(3) will not be 

available to operators prior to 

expiration of Exemption No. 10193, 

as currently written. Late addition of 

product improvement functionality in 

the software update packages resulted 

in disagreement between the 

certification schedule and the 

exemption period.

B) Relief allows airlines currently 

operating greater than 180-minute 

ETOPS routes, and airlines pursuing 

greater than 180-minute ETOPS 

operational approval, to continue 

without interruption.

Description of Issue 

Proposed Revision of Limitation 

On January 11, 2011 FAA Time-Limited Exemption No. 10193 was published allowing 

operators of the Boeing 777 airplane to use it to its full capability to conduct their flight 

operations in the most fuel efficient manner using ETOPS greater than 180 minutes. The 

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exemption required flight crews to conduct fuel monitoring procedures for a time period of three 

(3) years until an automated low fuel monitoring feature could be installed and certified on the 

777 in accordance with 14 Code of Federal Regulations Part 25 Appendix K25.1.4(a)(3). The 

automated low fuel monitoring feature is being incorporated as part of a broader product 

improvement package to the 777’s Airplane Information Management System (AIMS). The 777 

AIMS product improvement package is taking longer than expected to develop, validate, and 

certify. The AIMS product improvement package will not be available prior to expiration of the 

time-limited exemption. To allow airlines to continue to operate the 777 in the most fuel 

efficient manner while managing their fuel planning using flight crew procedures, Boeing is 

requesting an extension to FAA Exemption No. 10193 for one additional year, until January 11, 

2015. 

Statement of Public Interest 

Granting the continuance of the exemption allows the airlines to provide the benefits desired by 

the public of reduced ticket prices, reduced travel times, and reduced carbon footprint through 

more direct routes. Although ETOPS operations beyond 180-minutes are occurring at a slower 

rate than originally predicted, 777 operators are still interested in ETOPS greater than 180-

minutes. Currently, an operator in the southern hemisphere is frequently dispatching on 240-

minute routes with the 777-300ER airplane, with plans to expand these operations to their 777-

200 airplanes. Several other operators are in various stages of planning for eventually obtaining 

approval for ETOPS operations greater than 180-minutes. ETOPS operations greater than 180-

minutes does benefit the flying public, both economically and environmentally. 

Statement of No Adverse Effect on Safety 

The 777 has flown over 2.5 million ETOPS flights over the last 18 years. All of these ETOPS 

flights have been successfully conducted with the existing flight deck instruments and flight 

crew monitoring and procedures. The fuel monitoring procedures required during the exemption 

period, identified in the Airplane Flight Manual, have shown to be effective in increasing the 

flight crew’s awareness of fuel quantity while operating beyond 180-minutes. Boeing proposes 

that these procedures remain in-place throughout the extended exemption period, to mitigate the 

risk of having insufficient fuel to safely complete an ETOPS mission. By continuing to use the 

fuel monitoring procedure, an extension of the Exemption will not have a negative effect on 

safety. 

Request to ‘Waive Publication and Comment’ 

The Boeing Company is requesting to waive publication and comment period since exemption 

No. 10193 already underwent public review and comment, prior to publication. The extension of 

the exemption time limit is consistent with what was previously proposed in the public review 

and comment period and reposting of the exemption request would not serve any additional 

purpose. Previous comments to the request for exemption encouraged FAA to continue to work 

with Boeing to develop a more aggressive schedule. Boeing continues to work aggressively to 

develop, validate, and certify the automated low fuel monitoring feature and AIMS product 

improvement package. 

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Privileges of the Exemption Outside the United States 

Per 14 CFR 11.81(h), Boeing requests that the privileges of this exemption be extended outside 

the United States. This extension of privileges is necessary for operations based in foreign 

countries having bilateral agreements with the United States accepting FAA 14 CFR part 25 as 

their airworthiness standards for transport category aircraft. The model 777 airplane is intended 

for the global market place. 

Conclusion 

The Boeing Company requests an additional year to implement the K25.1.4(a)(3) compliant low 

fuel alerting system, resulting in an exemption termination date of January 11, 2015. The first 

half of this extension would be used to complete the certification of the AIMS-1 and AIMS-2 

software updates. The remaining time on the extended exemption period would allow operators 

a reasonable timeframe for incorporating the required Service Bulletins without interrupting 

normal operations. Boeing will continue to inform the FAA of the status of the AIMS updates, 

on a quarterly basis, through the time-period of the exemption. 

Summary to be Published in the Federal Register 

PETITIONER: Boeing Commercial Airplanes 

SECTION OF 14 CFR AFFECTED: 14 CFR 25.1535, Appendix K25.1.4(a)(3) 

DESCRIPTION OF RELIEF SOUGHT: The Boeing Company, has requested additional 

compliance time until 11 Jan 2015 (an additional 1 calendar year) in order to fully develop, 

certify, and deploy to Operators; the 14 CFR 25, K25.1.4(a)(3) Low Fuel Alerting software (and 

associated documentation updates) required to support the beyond 180-min Type Design 

approval" 

RA-13-04134 Enclosure 

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