Enclosure to BDCO-1 0-03071

Boeing Response to FAA Letter Regarding Petition for Time-Limited Partial Exemption to 14

CFR 25 Appendix K Section K25.1.4(a)(3), for Model 777~200. 777~200LR. 777~300ER, and

777F Airplanes, as it relates to Low Fuel Alerting, dated June 10, 2010

FAA Question 1)

Boeing reply:

What specific design changes will you be making to comply with

section K25.1.4(a}(3)?

Boeing will answer this question in response to Issue Paper EE-1.

FAA Question 2)

Boeing reply:

How many operators (and airplanes) want to enter such operations

immediately after greater·than~ 180~minutes ETOPS approval is

granted? How many of those are U.S. operators?

The number of operators, to date, that have expressed interest in entering the 180 minutes

+ ETOPS operations immediately after approval is granted is eight. Of those eight, three

are U.S. operators. The estimated number of airplanes involved is between thirty and thirtyfive. I

FAA Question 3)

FAA Question 4)

Boeing reply:

How many operators would be operating in greater·than·180~minute

ETOPS during the exemption period?

How many airplanes would be operating in greater·than~180~minute

ETOP$ during the exemption period?

Our currenl analysis surmises that the 777 will generate historic growth in the Southern and

Mid-Pacific regions routes over the next five years. The extrapolation assumes that the

trends seen in the North Atlantic and North Pacitic will continue in the Southern Oceans

once the 777 is certified for beyond 180/207.

The analysis assumes a total of 780 flights in 2Q09 ramping up to 65.00 8777 flights in 2015

for the Southern and Mid Pacific oceans. It is assumed that these flights will utilize greater

than 180/207 as it becomes available. The estimated fleet size that corresponds to 6500

flights per year is approximately 70 to 100 airpla,nes by 2015. That translates into a fleet

increase of 62+ airplanes.

Furthermore, other regions, like the polar region, are expected to need greater-than180/207 ETOPS capability for increased flexibility, depending on the availability of

alternates. It is expected that a US carrier operating in the polar region would utilize 240

minute ETOPS approximately 50 times a year. A separate marketing analysis has

projected a fleet size of 13 airplanes for operations that provide increased flexibility with 240

minute ETOPS.

Consideration must also be given to whether the Western and Southern Pacific routes are

saturated. Approval of greater-than-180 minute ETOPS and its attendant increased profit

potential is certain to attract additional carriers into that market sector.

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Enclosure to BDCQ-l0-03071

The above dissertation translates into the following numbers for the 5-year exemption

period:

Additional airplanes: 70 - 100

Additional operators: 12·15 Boeing is unable to predict al this time

How many of those would be U.S carriers.

FAA Question 5)

Boeing reply:

What will be the schedule for incorporating the design changes,

particularly for the operators who will be operating in greater-than~

lSo-minute ETOPS during an exemption period?

Boeing requested a 5-year exemption period based on the following timeline for evenls:

a) l-year for Issue Paper EE-l Closure and Firm Design on software change

b) 2-3 years for software development and certification (standard flow)

c) l-year for operator incorporation after software change is certified

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