0-^ Ronald J . Hinderberger 

Lead Administrator 

Delegated Compliance Org. 

Commercial Airplanes 

1"he Boeing Company 

^;^?:spoRWiON 

„;;:iOFtR/V[IONS 

OCT 0 1 2010 

BDCO-10-04186 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

A !C: 3 1 

Subject: 

Model: 

Petition for Exemption from Title 14 Code of 

Federal Regulations section 25.1309(c) at 

Amendment 25-116 With Respect to Crew 

Annunciation of the Status of Fuel System 

Components 

787-8 

The Boeing Company respectfully submits this petition for exemption from 

specific aspects of Title 14 Code of Federal Regulations Section 25.1309(c) at 

Amendment 25-116 for a limited number of Rolls Royce (RR) Trent 1000 

powered 787-8 airplanes as described in the summary below. The enclosure to 

this letter provides the details of the petition in accordance with Title 14 Code of 

Federal Regulations Section 11.81. The following summary is provided for the 

Federal Register in accordance with 14 CFR Section 11.81(f). 

Summary for Federal Register 

Petitioner: The Boeing Company. 

Section of 14 CFR Affected: Section 25.1309(c). 

Description of Relief Being Sought: 

Boeing is requesting relief from frill compliance to Section 25.1309(c) for the 

Rolls Royce (RR) Trent 1000 powered 787-8 for the unambiguous and timely 

indication to the flight crew to alert them of an anticipated fuel system 

contamination. If granted, this exemption will allow sufficient time for Boeing to 

develop, certify and incorporate into production a new alerting system that is 

fully compliant with Section 25.1309(c). The exemption would allow relief from 

the requirement in Section 25.1309(c) to provide indication to the crew of 

anticipated fuel system contamination for Rolls Royce Trent 1000 powered 787-8 

airplanes delivered up to June 30, 2014 and December 31, 2018 for retrofit 

incorporation. 
^ . 

Page 2 

Docket Management System 

BDCO-10-04186 

Very truly yours, 

/ 7 ^ f /^/y^-^ 

Christine Thompson 

Lead Project Administrator, Development Projects 

(425) 266-6572, MC 03-56 

FAX: (425)294-9340 

Enclosure: Petition for exemption from 14 CFR 25.1309(c) at Amdt. 25-116 

cc 

Name 

Ali Bahrami 

Ken Schroer 

Tom Thorson 

Sherry Vevea 

David Solar 

Ken Fontaine 

Letter 

EDT 

Paiper 

EDT 

EDT 

EDT 

EDT 

Enclosures 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Comments 

ANM-IOOS 

ANM-IOOS 

ANM-140S 

ANM-140S 

EASA 

EASA 
Enclosure to BDCO-10-04186 

Page 1 of5 

Petition for Partial Exemption from 14 CFR 25.1309(c) Amendment 25-116 for Rolls 

Royce Trent 1000 Powered 787-8 Airplane FAA Project Number PS06-0413 

Name and Address of the Petitioner 

CM. Thompson, Manager, Lead Project Administrator, Development Projects 

The Boeing Company, 

PO Box 3707, 

Seattle, Washington, 98124 

B. Section of the Code of Federal Regulations (CFRs) that are affected 

As provided for in 14 CFR 11.61(b), Boeing hereby petitions for a partial exemption 

to the following CFR: 

Reaulation 

14 CFR 

25.1309(0) 

At 

Amendment 

116 

Which Requires 

(c) Warning information must be provided to alert the crew to unsafe 

system operating conditions, and to enable them to take appropriate 

corrective action. Systems, controls, and associated monitoring and 

warning means must be designed to minimize crew errors which 

could create additional hazards. 
Enclosure to BDCO-10-04186 

Page 2 of 5 

The extent of relief being sought 

Regulation Requires: Extent of relief being sought: 

14 CFR 

Part 25 

Section 

25.1309(c) 

Amendment 

116 

The FAA has 

determined that in 

order to comply 

with §25.1309(c) for 

the RR Trent 1000 

fuel system, as it 

applies to the 

FOHE and fuel 

filter, an 

unambiguous and 

timely indication to 

the flight crew is 

required to alert 

them of an 

anticipated fuel 

system 

contamination. 

Boeing seeks time limited relief from full compliance to 

§25.1309(c) for the Rolls Royce (RR) Trent 1000 powered 787-

8 for the unambiguous and timely indication to the flight crew to 

alert them of an anticipated fuel system contamination. The 

time limit being sought is until June 30, 2014 for production 

incorporation and Boeing recommends December 31, 2018 for 

retrofit incorporation by the operators of the airplanes delivered 

under this exemption. 

Relief is necessarv because: 

The RR Trent 1000 engine is the first engine to incorporate a 

bypass in the Fuel Oil Heat Exchanger (FOHE). The bypass 

was added to address the condition of a transient high 

concentration of ice In fuel which could potentially block the 

FOHE and result in significant loss of thrust. The FOHE 

bypass is not presently designed to provide crew alerting to 

indicate an impending or actual bypass condition. 

The FAA recently provided Boeing guidance regarding what is 

needed to show compliance to §25.1309(c) for flight crew 

alerting of FOHE impending or actual bypass. The FAA has 

also provided additional guidance regarding FOHE and fuel 

filter flight deck indication for dual engine impending or actual 

bypass. The 787-8 is not currently designed to provide the 

FAA-required dual impending bypass indication for the filter and 

does not currently provide impending and/or bypass indication 

for the FOHE. 

Boeing is requesting relief for a limited number of 787-8 

airplanes to allow sufficient time to develop, validate, certify and 

incorporate into production a compliant FOHE bypass 

indication and alerting scheme as well as adding additional 

alerting for dual engine impending fuel filter bypass. Following 

incorporation of the compliant design into production, Boeing 

will issue a service bulletin that recommends all airplanes 

delivered under this time limited exemption be retrofitted. 

The relief sought is limited to those 787-8 aircraft completed 

prior to the production incorporation of the compliant message. 

The production incorporation of the compliant message will be 

accomplished no later than June 30, 2014. A service bulletin 

will be available no later than June 30, 2014 such that all 787-8 

airplanes delivered under this exemption can order parts and 

install a compliant configuration. The Boeing Service Bulletin 

will recommend that all airplanes delivered under this 

exemption be retrofitted by December 31, 2018. 
Enclosure to BDCO-10-04186 

Page 3 of5 

D. Description of the Issue 

As currently designed, the 787-8 provides the following flight deck indication for impending 

and/or actual bypass of the FOHE and fuel filter. 

• Fuel filter impending bypass: EICAS advisory messages with clear indication of Left or 

Right engine fuel filter impending bypass. 

• Non-normal checklist procedures ejxplaining the potential condition and pilot action for 

one engine alert or for alerts received for both engines. 

• FOHE impending and/or actual bypass is not directly indicated with EICAS messages to 

the flight crew. 

The FAA has stated that recent events in service and in experimental flight test have led to a 

recognition that fuel systems have the potential to become clogged by ice or large 

contaminants (beyond that which is consider under 14CFR Part 33 certification) and restrict 

fuel flow to engines, and potentially resulting in a multiple engine power loss event. 

The FAA recently clarified that flight crew alerting for impending and/or actual FOHE bypass, 

and additional flight crew alerting when both engines on the same flight are subjected to fuel 

filter or FOHE impending bypass condition are required to be compliant to §25.1309(c). 

Boeing intends to comply with these requirements by implementing flight deck indication for 

the FOHE and elevating the EICAS flight deck alert for a dual engine impending and/or bypass 

condition of either the FOHEs or fuel filters. Given the advanced stage of the 787-8 program 

relative to gaining basic type design certification, Boeing is requesting this time limited partial 

exemption to enable an orderly, robust and reliable design, implementation and verification of 

the subject alerting. 

Boeing's assessment of the required design and implementation activities suggests that the 

first opportunity to implement the new alerting scheme could take as long as June 30, 2014. 

To incorporate a compliant design, it is anticipated that software changes to the electronic 

engine control (EEC) and display and crew alerting are required as well as hardware changes 

to the EEC (and associated wiring) and the FOHE casting. Hardware changes to the EEC and 

the FOHE casting are long lead design changes. This production cut-in position will provide 

adequate alert development and testing time and avoid unscheduled revisions of the above 

mentioned software, and allow adequate time for design and qualification of the EEC (and 

associated wiring) and design and procurement of the FOHE. 

Based on current understanding, there would be approximately 100 RR Trent 1000 equipped 

787-8 airplanes delivered under this exemption that may be subsequently retrofitted via 

service bulletin that will be available no later than June 30, 2014. Selection of December 31, 

2018 will enable operators to accomplish this retrofit in a scheduled base maintenance check. 
Enclosure to BDCO-10-04186 

Page 4 of5 

Statement of No Adverse Effect on Safety 

The RR Trent 1000 fuel system architecture is similar in its design to other RR engines 

installed on Boeing and non-Boeing aircraft. This fuel system design has accumulated many 

millions of in-service hours (more than 50 million hours on Boeing powered aircraft only) and 

no engine in-flight shutdowns or in-flight power loss events have been associated with FOHE 

blockage due to solid contamination being introduced in the worldwide fuel supply or solid 

contamination left in the airplane fuel tanks. The introduction of the FOHE bypass in the RR 

Trent 1000 further improves the design by providing an alternate path for the fuel, reducing the 

likelihood of a sudden engine shutdown due to fuel starvation. 

The RR Trent 1000 main fuel filter complies with the requirements of §25.997(d) and 

§25.1305(c)(6). The fuel filter is sized to protect all downstream fuel metering components, 

high pressure (HP) pump, and burners from gross contamination. When the filter is exposed to 

contaminated fuel and debris accumulates to the point that it reaches impending bypass, an 

alert is provided to the flight deck via an advisory level message according to the requirements 

of §25.1305(c)(6). Each engine monitors the pressure drop (delta P) across the fuel filter and 

an alert is provided to the flight crew via an EICAS Advisory message (ENG FUEL FILTER L 

or ENG FUEL FILTER R) well before the delta P reaches a level that would result in bypassing 

the fuel filter. This alerting scheme provides an adequate level of safety for the airplanes 

affected by this exemption. This is the same fuel filter alerting on all Boeing production 

airplanes. 

The RR Trent 1000 FOHE unit itself has been qualified according to the fuel contamination 

requirements in EASA AMC E 670. These requirements have been used in the past for 

qualification of FOHEs on other RR engines. The levels of contamination in the fuel used 

during the qualification process are much greater than the standard concentration limit used to 

determine the acceptability of the fuel for use in jet aviation according to industry standards. 

The FOHE successfully completed all qualification testing. 

The proven service history of the RR fuel system architecture, the maintenance actions 

defined to preclude the introduction of solid contamination into the fuel tank's and the existing 

flight deck messages and associated crew procedures provide an adequate level of safety for 

the airplanes affected by this exemption. 

Under this proposed partial exemption it is expected that there will be approximately 100 

airplanes delivered, and Boeing recommends these airplanes be retrofitted into a fully 

complaint configuration in 8 years or less. It is expected that this small fleet size and exposure 

duration will result in an extremely low likelihood of a contamination event of concern 

occurring. 
Enclosure to BDCO-10-04186 

Page 5 of 5 

Statement of Public Interest 

Granting this petition is in the public's interest because it would allow adequate time for Boeing 

and Rolls Royce to develop an effective and robust design solution for the flight deck 

indication of the dual fuel filter impending bypass requirement and FOHE impending and/or 

bypass requirement. Conversely, if the requested relief is not granted, the addition of a flight 

deck indication that both engines on the same flight are subjected to a fuel filter impending 

bypass condition and FOHE impending and/or bypass at this late stage of the airplane 

development program would lead to delays in the deliveries of Model 787-8 airplanes. 

Availability of 787-8 airplanes with the RR Trent 1000 engines will reduce fuel burn and hence 

reduce emissions of carbon dioxide, reduce global emissions of NOx, and reduce operating 

costs of airlines from current in-service airplanes. 

In addition, without adequate time to develop a robust solution, nuisance flight deck alerts inservice have the potential to reduce operational safety when flight crews are tasked to respond 

to false indications potentially resulting in unnecessary flight diversions, landing at airports that 

they are not familiar with, and conceivably, shutting down an engine unnecessarily. 

The public interest will be advanced by the grant of Exemption as it is in the best economic 

interest of the United States. Many 787-8 customers are overseas. Further delivery delays of 

the 787-8 are not in the interest of the public due to the potential negative impact to export 

sales, the balance-of-trade, the gross donnestic product and economic health of the United 

States. 

Privileges of this 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 within 

foreign countries having bilateral agreements with the United States accepting FAA 14 CFR 

Part 25 as their airworthiness standards for transport category aircraft. The 787-8 is intended 

for the global market place with a launch customer based in a country utilizing the United 

States ainA/orthiness standards. 

H. Conclusion 

The requested time limited exemption will allow the Boeing Model 787-8 time to comply with 

the requirements recently put forth by the FAA. The relief sought is limited to those 787-8 

aircraft completed prior to the production incorporation of the compliant message. The 

production incorporation of the compliant message will be accomplished by June 30, 2014. 

The Boeing Service Bulletin will recommend that all airplanes delivered under this exemption 

be retrofitted by December 31, 2018. 

As discussed above, passenger and crew safety will not be appreciably affected by a grant of 

exemption in this case.