Exemption No. 10905 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

The Boeing Company 

for an exemption from §§ 25.901(c) and 

25.981(a)(3) of Title 14, Code of Federal 

Regulations 

Regulatory Docket No. FAA-2012-1137 

TIME-LIMITED PARTIAL GRANT OF EXEMPTION

By letter dated October 18, 2012, Douglas M. Lane, Director, Regulatory Administration, The 

Boeing Company, P.O. Box 3707, Seattle, WA 98124, petitioned the Federal Aviation 

Administration (FAA) for an exemption from the requirements of §§ 25.901(c) and 25.981(a)(3) 

of Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted would allow 

planned changes to the fuel quantity indication system (FQIS) for the fuel quantity processor unit 

(FQPU) parts obsolescence modification on the 737-600/-700/-700C/-800/-900/-900ER (also 

referred to as the 737NG). 

The petitioner requests relief from the following regulation(s): 

Section 25.901(c) – Installation. For each powerplant and auxiliary power unit 

installation, it must be established that no single failure or malfunction or probable 

combination of failures will jeopardize the safe operation of the airplane except that the 

failure of structural elements need not be considered if the probability of such failure is 

extremely remote. 

Section 25.981(a)(3) – Fuel tank ignition prevention. (a) No ignition source may be 

present at each point in the fuel tank or fuel tank system where catastrophic failure could 

occur due to ignition of fuel or vapors. This must be shown by: (3) Demonstrating that 

an ignition source could not result from each single failure, from each single failure in 

combination with each latent failure condition not shown to be extremely remote, and 

from all combinations of failures not shown to be extremely improbable. The effects of 

manufacturing variability, aging, wear, corrosion, and likely damage must be considered. 

 
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Related sections of 14 CFR

Section 25.1309 – Equipment, systems, and installations, states that required equipment, 

systems, and installations be designed to ensure that they perform their intended 

functions under any foreseeable operating condition and that the occurrence of any failure 

condition that would prevent the continued safe flight and landing of the airplane be 

extremely improbable. 

The petitioner supports its request with the following information: 

 

This section quotes the relevant information from the petitioner’s request. The complete petition 

is available at the Department of Transportation’s Federal Docket Management System, on the 

Internet at http://regulations.gov, in Docket No. FAA-2012-1137. 

Description of Issue 

Boeing and its suppliers have been producing the 737NG for fourteen years and have 

successfully delivered more than 4200 of these highly reliable airplanes to satisfied 

customers. As it is to be expected after a very long and successful production run, 

improvements will be needed to adjust for such things as parts obsolescence and 

manufacturing process improvements. Three such changes are currently planned that will 

require Boeing to modify the FQPU and two runs of FQIS wiring. 

The 3 changes include: 

 Upgrade the FQPU for obsolete parts 

 Re-route and separate FQIS wire between station 397.1 and 400 as part of a 

production improvement which will relocate the forward bulkhead 

 Re-route the in-tank FQIS wire along the side of body rib as part of a production 

improvement that will change that rib to a semi-monolithic part. 

In making these changes without an approved exemption, Boeing believes that they 

would be held accountable for showing full compliance to 25.901(c) Amendment Level 

126 and 25.981(a)(3) Amendment Level 125 for the FQIS at the system level which 

would require a significant number of changes associated with the FQIS tank-side circuit. 

The system has been shown compliant to §25.1309; however, presently both §25.901(c) 

and §25.981(a)(3) have additional failure combination requirements. For systems that 

may cause a catastrophic hazard, §25.1309 requires no single failure and no combination 

of failures greater than extremely improbable; §25.901(c) requires no single failure or 

probable combination of failures; and §25.981(a)(3) requires no single failure, no single 

plus latent (greater than extremely remote), and no multiple combination greater than 

extremely improbable. 

This exemption is being sought for the no single plus latent (greater than extremely 

remote) as is stated in §25.981(a)(3) and interpreted by the FAA for §25.901(c). An 

exemption is also being sought for the non-environmental aspects of §25.901(c) provided 
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by FAA interpretation, and the explicit §25.981(a)(3) requirements of manufacturing 

variability, aging, wear, corrosion, and likely damage, as these considerations are already 

covered by factory manufacturing processes, and airline maintenance of the type design 

of airplane. 

In April of 2006 a production change aimed at developing and incorporating a Transient 

Suppression Device (TSD) for non-densitometer equipped airplanes and a Remote Data 

Concentrator (RDC) for densitometer equipped airplanes was canceled. This 

development effort was pursued in parallel with the Nitrogen System Generation System 

(NGS) development effort and when the decision was made to incorporate NGS as the 

means to minimize center tank flammability Boeing suspended further activity on this 

production change. Boeing believed that NGS protected against all potential ignition 

sources and not just FQIS wiring. Boeing also believed that their position was consistent 

with what was later documented in the FAA Reduction of Fuel Tank Flammability in 

Transport Category Airplanes; Final Rule, July 21, 2008. In section K. Cost/Benefit 

Analysis of this final rule, it is stated that "Since this rule requires FRM or IMM to 

mitigate an unsafe condition by converting these tanks into low flammability fuel tanks, 

TSUs will no longer be needed." 

In 2009 Boeing completed an evaluation comparing the effort and cost required to 

implement a compliant FQIS by isolating the intrinsically safe side wire through wire 

separation or by adding barrier devices. Both of these solutions were found to be 

technically challenging and expensive. The recurring cost for adding barrier devices was 

much greater than the cost to separate the FQIS wire. In addition the following challenges 

associated with incorporating such a barrier device had been identified: 

 The Transient Suppression Device (TSD) would not work with the densitometer 

as it is a passive filter and it would interfere with the densitometer circuitry, so a 

Remote Data Concentrator (RDC) would be needed. 

 The RDC's would need to be mounted in unpressurized regions of the airplane 

near the tank penetration to minimize the need for wire separation. This 

represented a challenging temperature and vibration environment for this type of 

microprocessor centric device. For example, the wing mounted devices would be 

adjacent to the anti-ice duct. 

 There was no clearly identified space near the tank penetrations that would 

accommodate an RDC. 

 The FQPU would require modifications and requalification as the signal 

conditioning function would be moved from the FQPU out to the RDCs. The 

FQPU would act as an interface between the RDCs and the avionics. This level of 

architectural change would add additional cost and complexity. 

 Because RDCs are microprocessor based devices the cost would be higher than 

that for the TSD. 

Due to the high recurring cost and technical complexity associated with the barrier device 

solution, Boeing had determined that if full compliance to 25.981 at amendment level 

102 were required, the following changes would need to be incorporated on the 

737-600/700/700C/800/900/900ER airplanes: 
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 Extensive redesign of the Airplane Wiring System to ensure FQIS wire separation 

for more than 100 unique customer driven airplane configurations. 

 Modify the FQPU mother board and associated connectors. The solution would 

require the FQPU to grow in size. 

 Relocate the FQPU from the Forward Equipment Center to the forward cargo 

compartment to allow for a larger FQPU and enable a clear path for wire 

separation. 

 Make new main tank penetrations in-board of the struts and procure new in-tank 

wiring harnesses. 

 In-tank Component Changes (new brackets, shorter probe, revised in-tank wire 

harness and retention means). 

 Software changes related to Fuel Tank Gauging Function (to account for 

capacitance change due to in-tank component changes). 

The time needed to successfully implement these changes would extend beyond the 

fourth quarter of 2014. This is when the FQPU obsolete parts would be completely 

consumed leaving no additional parts for building production FQPUs or supporting the 

fleet with repaired or replaced units. Operators would be required to incorporate the 

extensive changes described above in retrofit prior to replacing a malfunctioning FQPU 

of the current configuration with a new one. Boeing views this as an excessive burden on 

their customers that does not provide a proportionate improvement in safety or reliability 

of the FQIS. However, Boeing does remain committed to making incremental safety 

enhancements to the 737NG fuel system. We believe that making these changes does not 

have an adverse affect on this system, but in fact enhances what is already a proven good 

in-service safety record. As such, Boeing is requesting that the FAA consider this petition 

for exemption for 14 CFR 25.981(a)(3) Amendment 25-125 and 14 CFR 25.901(c) 

Amendment 25-126 for the three changes that impact the FQIS as described in more 

detail below: 

With regard to the 737NG FQPU, several electronic components within the Signal 

Conditioning Circuit Card (SCCC) have become obsolete. The inventory of the obsolete 

parts available only supports production through 2014. As a result, a redesign of the 

SCCC within the FQPU is required to provide a solution for this typical type of product 

lifecycle parts obsolescence situation. The redesigned SCCC will meet the requirements 

of 25.981(a)(3) per AC 25.981-1C and will therefore provide an additional level of safety 

in the FQPU as compared to the current configuration. 

To gain more room in the EE bay to support a more producible and ergonomic 

configuration, the forward bulkhead will be relocated from Station 397.1 to Station 401 

and there will be an associated redesign of wiring in that area (transverse rack and cross 

over wiring). The associated FQIS wiring will be separated from the other wiring 

between station 400 and 420 which will add an incremental safety improvement. 

In order to support a production rate increase and improve manufacturability, Boeing 

plans to implement a semi-monolithic side of body rib change which will significantly 

reduce the complexity of that build. As part of this structural change, the current 

stiffeners located on the inboard side of the rib will be moved to the outboard side which 
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will require that the center fuel tank FQIS wiring be moved outboard approximately 2 

inches from its current routing. The FQIS wire run is located entirely in the center tank 

and this change will not degrade the safety of the system. 

Below listed are the incremental improvements Boeing has opportunistically made over 

time to add increased levels of safety to the FQIS. These and other future improvements 

include: 

 2005: A hot short protector was added to the densitometer installation 

 2008: NGS was incorporated into production 

 2011: NGS Retrofit Service Bulletin provided for US Operators 

2011: Analysis was completed showing the FQPU as a barrier device which 

inhibits the 

propagation of up-stream hot shorts of up to 115VAC onto the intrinsically safe 

FalS wiring 

 2014: FQIS wire will be separated between station 400 and 420 - as part of the 

forward bulkhead relocation change 

2014: The SCCC will be 25.981 compliant - as part of the FQPU parts 

obsolescence upgrade 

Beyond 2014: The 737MAX FQIS will be made fully 25.981 Amendment 125 

compliant. 

In summary, this exemption will be applied such that today's certified FQIS configuration 

will largely remain the same until the introduction of the 737MAX and it will continue to 

include the following specific features: 

 The FQPU motherboard is not compliant to UL 913 for circuit board trace 

separation 

 The tank-side FQIS wiring is not separated from other airplane system wires 

 The failure of two in-tank wire clamps could allow wire to make contact with 

structure 

 The failure of a tank unit clamp screw could allow the unit to make contact with 

structure 

 Tank unit separation from structure may not provide redundant lightning 

protection 

 Leading edge FQIS wire shield lacks redundancy. 

Statement of Public Interest 

The granting of this exemption is in the public interest for the following 2 reasons: 

1. The three changes described above do not degrade the current level of safety on 

the 737NG and in the case of the SCCC modification and the bulkhead relocation an 

additional level of safety to the FQIS system would be achieved. 

2. Denial of this petition for exemption would result in the operators having to 

perform extraordinary work which would result in disruption of operations and would 

pose significant burden on the airlines whenever an in-service FQPU fails. The 
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potential for unidentified collateral damage during this extensive modification is 

likely more significant than any safety benefit achieved by implementing the 

improvements. 

Statement of No Adverse Effect on Safety 

The current FQIS system has been thoroughly evaluated for safety aspects in such forums 

as Boeing's safety assessment that was required per 14 CFR Special Federal Aviation 

Regulation No. 88 (SFAR88) for the Fuel Quantity Indicating System and no safety 

issues were identified other than a single failure mode on the densitometer that was 

corrected by mandating the hot short protector. However, the FAA's review of that 

assessment per SFAR88 Mandatory Action Decision Criteria resulted in release of an 

FAA AD-Worksheet (Worksheet Number 04-AD-59) related to the Fuel Quantity 

Indicating System for the Center Fuel Tank only, primarily due to its classification as a 

High Flammable Fuel Tank. Boeing believes that this classification has since been 

changed due to the installation of a Nitrogen Generation System (NGS) for the center fuel 

tanks of all 737-600/700/700C/800/900/900ER airplanes as required by the Fuel Tank 

Flammability Reduction Rule. Note that even prior to the implementation of NGS which 

further reduces any risk, the Boeing assessment was that the risks for the 737NG FQIS 

installation were extremely improbable, which is the typical industry and CFR 25.1309 

standard for an acceptable systems installation. 

The FQPU, SCCC parts obsolescence driven design changes will be shown compliant to 

UL 913 per the guidance documented in section 10(c)(9) of AC 25.981-1C which will 

provide for an additional level of FQIS safety. In addition, the FQIS wiring changes 

associated with the semi-monolithic side of body change and the forward bulkhead 

relocation will not adversely affect safety; therefore, Boeing requests that this exemption 

be approved allowing for these changes without requiring the additional changes required 

to show the FQIS compliant to 14 CFR 25.901(c) Amendment Level 126 and 

25.981(a)(3) Amendment Level 125. 

Request to ‘Waive Publication and Comment’ 

The relief sought by this exemption does not result in any reduction in level of safety for 

a previously type certificated product with a highly reliable system; rather, it allows for 

an incremental enhancement to the level of safety of the product. The exemption would 

result in an overall enhancement in the product’s safety and because the current 

configuration cannot be sustained beyond 2014, Boeing respectfully requests that in order 

to expedite the exemption process the FAA waive the requirement for publication and 

comment. 

Privileges of the Exemption Outside the United States 

Because the 737NG is used by customers around the world, Boeing requests that the 

privileges of this exemption be extended outside the United States, per 14 CFR 11.81(h) 

This extension of privileges is necessary for operations based within foreign countries 

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

their airworthiness standards for transport category aircraft. 
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Conclusion 

Boeing is petitioning for an exemption from the provisions of 14 CFR 25.901(c) [25-126] 

and 25.981(a)(3) [25-125] at the system level as they apply to the FQIS installed on the 

737-600/700/700C/800/900/900ER airplanes for the FQPU parts obsolescence 

modification, the semi-monolithic side of body and forward bulkhead production 

improvement changes. 

The re-design of the SCCC of the FQPU is necessary due to obsolescence of several 

electronic components. The re-designed SCCC assembly will not adversely affect the 

FQIS safety and will be shown to meet the requirements of 14 CFR 25.901(c) and 

25.981(a)(3). The existing level of safety will be improved at the card level. In addition 

the changes made to the FQIS wiring runs associated with the semi-monolithic side of 

body change and the forward bulkhead relocation add an incremental improvement to the 

FQIS level of safety. 

FAA Approval of this exemption request will allow use of this improved interchangeable 

LRU (SCCC) for repairs without extensive rework to an in-service aircraft. 

Federal Register publication 

Although the petitioner requested that action on its petition not be delayed for publication in the 

Federal Register, the FAA found that the petition, if granted, would set a precedent. Therefore, 

to allow an opportunity for the public to comment on the petition, a summary of it was published 

in the Federal Register on December 4, 2012 (77 FR 71865). Comments were received from the 

National Air Traffic Control Association (NATCA) National Safety Committee. The commenter 

agreed with granting a time-limited exemption for in-service airplanes to support needed spare 

parts. However, they did not agree with granting a permanent exemption for production 

airplanes. NATCA recommended the FAA not grant the exemption requested in the petition for 

exemption submitted in docket number FAA-2012-1137 for newly produced airplanes. They 

recommended instead that the FAA require newly produced airplanes produced in 2014 to 

comply with the regulations. To facilitate continued operation of in-service 737s, NATCA 

recommended only granting a time-limited exemption for the existing fleet of airplanes. That 

would provide the minimum time necessary for operators to modify their existing airplanes so 

the installation complies with the regulations listed in the petition for exemption. This would be 

consistent with and compliment issuance of the airworthiness directive (AD) required by FAA 

policy memorandum PS-ANM100-2003-112-15, “SFAR 88 – Mandatory Action Decision 

Criteria,” dated February 25, 2003, for the airplanes covered by this petition for exemption. 

NATCA supported their recommendations as follows: 

NATCA has reviewed the subject petition for exemption and has similar concerns as 

those raised in our comments to the 757 NPRM (see docket item FAA-2012-0187-0005) 

and the similar petition for exemption for the Model 767 airplanes (docket FAA-2012-

1132). NATCA questions how allowing the noncompliant design features described in 

the petition for exemption to remain in 737 airplanes indefinitely "would not adversely 

affect safety, or how the exemption would provide a level of safety at least equal to that 

provided by the rule from which you seek the exemption" (see 14 CFR 11.81). Those 
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design features are defined by the FAA as unsafe in airworthiness directives issued for 

similar designs on 747 and 737 classic model airplanes and in the FAA’s own published 

SFAR 88 “Mandatory Action Decision Criteria” document; FAA Memorandum number 

2003-112-15, dated February 25, 2003. Granting an exemption for a "phased 

compliance" approach clearly doesn't provide the level of safety that requiring an initially 

compliant design would provide. The petition states that they would not be able to 

deliver 737s past the fourth quarter of 2014 without an exemption. Therefore, NATCA 

recommends the FAA not grant the Petition for Exemption submitted in docket number 

FAA-2012-1137 for newly produced airplanes and instead require newly produced 

airplanes produced in 2013 [sic 2014] comply with the regulations. 

The FAA’s analysis 

In June of 2011 Boeing met with the FAA to describe the changes to the 737NG FQIS that are 

the subject of this exemption request. The FAA informed Boeing that we could not approve 

modifications to the FQIS since the ignition source prevention features of the system could not 

be shown to meet § 25.981 at amendment 25-102. We also reminded Boeing of our decision to 

issue SFAR 88 related ADs for FQIS and of our letters of August 2009 and April 2011 

requesting Boeing develop design changes and service information describing the corrective 

actions for FQIS protection. Boeing stated in their request: 

However, the FAA's review of that assessment per [14 CFR part 21 Special Federal 

Aviation Regulation No. 88 (SFAR 88)] Mandatory Action Decision Criteria resulted in 

release of an FAA AD-Worksheet (Worksheet Number 04-AD-59) related to the Fuel 

Quantity Indicating System for the Center Fuel Tank only, primarily due to its 

classification as a High Flammable Fuel Tank. Boeing believes that this classification has 

since been changed due to the installation of a Nitrogen Generation System (NGS) for the 

center fuel tanks of all 737-600/700/700C/800/900/900ER airplanes as required by the 

Fuel Tank Flammability Reduction Rule. 

The petitioner’s justification for requesting a permanent exemption to §§ 25.901 and 25.981 

relies largely on the availability of a design modification, installation of NGS, that provides fuel 

tank flammability reduction means (FRM) meeting criteria determined to be equivalent to the 

standards established by the FAA through the Fuel Tank Flammability Reduction (FTFR) rule 

introduced into 14 CFR part 25 at Amendment 25-125. However, not all 737 series airplanes in 

the fleet are required to be retrofitted with NGS. 

Mandating retrofit of FRM was found to be in the public interest on newer transport airplanes in 

passenger service with high flammability fuel tanks. All 737 series passenger airplanes operated 

in the United States under 14 CFR parts 121, 125, and 129 will be required to have FRM. 

However, FRM is not required to be incorporated into cargo airplanes, airplanes operated under 

14 CFR parts 91 and 135, and airplanes operated in foreign countries unless the foreign country 

has adopted regulations that implement the fleet safety improvements provided by FRM. 

For clarity, we do not agree with the petitioner’s statement that, “The current FQIS system has 

been thoroughly evaluated for safety aspects as was required per SFAR 88 for the Fuel Quantity 

Indicating System, and no significant safety issues were identified.” As identified in the notice 

of proposed rulemaking (NPRM) for 757 series airplanes, Docket No. FAA-2012-0187, the FAA 
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intends to issue ADs for other airplane models, such as the 737, with high flammability fuel 

tanks that are not required to retrofit FRM. These ADs will incorporate FQIS protection to 

prevent potential sources of fuel tank ignition per SFAR 88. This includes all airplanes in cargo 

operation and airplanes in 14 CFR part 91 and 135 operations. The ADs are expected to affect 

many foreign-registered airplanes produced before Boeing incorporated NGS in production in 

2008 as well. We are currently preparing a supplemental NPRM to add another method of 

compliance for airplanes in cargo operation in order to achieve an acceptable level of safety for 

those airplanes. Boeing is required by §§ 21.99 and 183.63(d) to submit appropriate design 

changes as well as service information for FAA approval and has agreed to do so in a timely 

manner to support these ADs. We do not anticipate that changes to the FQIS resulting from 

these planned ADs will involve changes to the FQPU itself but may include some or all of the 

wire separation-related design changes planned by Boeing with additional wire separation as 

well. 

The FAA’s current fuel tank safety airworthiness standards rely upon a balanced approach of 

limiting fuel tank flammability exposure time and precluding ignition sources that could form in 

the fuel tanks. For this reason, § 25.981 includes separate and distinct requirements for limiting 

fuel tank flammability and preventing ignition sources in the fuel tanks. 

The Boeing NGS was shown to meet criteria equivalent to the flammability requirements of 

§ 25.981, Amendment 25-125; however, fuel tank ignition failure modes described in the petition 

for exemption do not comply with the ignition prevention requirements of § 25.901(c), 

Amendment 25-46, or § 25.981(a)(3), Amendments 25-102 or 25-125. When considering the 

FQPU design change along with the partial wire separation planned by Boeing, that design 

change has no negative effect on potential fuel tank ignition and no negative effect on the level 

of safety in the 737 FQIS. However, granting a permanent exemption would not provide a level 

of safety at least equal to that provided by the rule from which Boeing seeks the exemption (see 

14 CFR 11.81) because areas affected by this change would not be compliant, as required by 

§ 21.101. 

NATCA recommended the FAA not grant the petition for exemption for newly produced 

airplanes, but instead recommended a time-limited exemption for in-service airplanes only to 

allow the operators to replace FQPUs on 737s as needed and to require newly produced airplanes 

fully comply. We partially agree. Completing the design changes necessary to fully comply 

with the fuel tank ignition prevention standards of §§ 25.901(c), Amendment 25-46, and 

25.981(a)(3), Amendment 25-102 or 25-125, and incorporating the changes into newly-produced 

airplanes will further reduce the risk of fuel tank ignition and enhance safety by restoring the 

balanced approach to fuel tank safety required by 14 CFR part 25. However, the changes 

described by Boeing in the exemption request that are needed to directly comply are extensive 

and more time would be needed to complete the design and incorporate it into production. 

Not granting the exemption would not be in the public interest because it would result in delivery 

delays for newly manufactured airplanes due to this proposed change to the FQPU and FQIS 

partial wire separation. Also it would not allow operators to replace FQPUs on in-service 

airplanes when replacements are needed, without unintended impact to scheduled operations. In 

addition, the timing of the transition from the 737NG to the next planned version of the 737 

series, the 737-7/-8/-9 (also referred to as the 737Max), contributes to a determination that full 

compliance for the 737NG FQIS is not practical. Therefore, partial grant of exemption is in the 
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public interest. Boeing plans for the 737Max FQIS to fully comply with the fuel tank ignition 

prevention requirements. 

As indicated in the 757 FQIS NPRM, the FAA plans to mandate FQIS protection similar to that 

discussed in the NPRM on other Boeing airplanes, which includes the 737 series airplanes. The 

AD planned for the 737 series is expected to incorporate the long term FQIS protection for 

airplanes to which this exemption applies. Boeing is required by 14 CFR 21.99 and 183.63(d) to 

develop design changes and service information describing the corrective action for FQIS 

protection. Boeing has committed to provide the data necessary to support these modifications 

mandated by the ADs in a timely manner to support these ADs. 

The FAA’s decision 

In consideration of the foregoing, I find that a partial grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701 delegated to me by 

the Administrator, The Boeing Company is hereby granted a time-limited exemption for up to 48 

months after the effective date from 14 CFR 25.901(c), Amendment 25-126, and 25.981(a)(3), 

Amendment 25-102 or later, as they pertain to fuel tank ignition prevention associated with the 

following FQIS changes on in-service and newly-produced 

737-600/-700/-700C/-800/-900/-900ER airplanes: 

 Replacement of the SCCC and the ARINC display card within the FQPU; and 

 Changed areas for the re-routing and separation of FQIS wires where the changed areas 

of the FQIS wire routing meet the installation requirements for separation and fault 

tolerance required to comply with § 25.981(a)(3) as associated with the: 

o Semi-monolithic side-of-body change, and 

o Forward bulkhead relocation. 

After expiration of this time-limited exemption, the FQIS on all newly-produced airplanes must 

be shown to comply with §§ 25.901(c), Amendment 25-46, and 25.981(a)(3), Amendment 25-

102, or later amendments. 

Issued in Renton Washington, on December 18, 2013. 

/s/ Jeffrey E. Duven 

Jeffrey E. Duven 

Manager, Transport Airplane Directorate 

Aircraft Certification Service