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Petition for Amendment to Exemption No

. 6425B which permits relief from 14 CFR 25. 562(b)(2) Amendment 25

- 64 from floor warpage testing requirement for flight deck seats

Name and Address of the Petitioner

Douglas Lane, D eputy Lead Administrator The Boeing Company PO Box 3707, M/S 03

- 56 Seattle, Washington, 98124

Section(s) of the Regulation ( s ) to which an Amendment is sought :

Section 25.562(b)(2), as amended by Amendment 25

- 64, requires the floor tracks used to attach the seat to the floor to be misaligned with respect to the adjacent seat tracks by at least 10 degrees vertically (i.e. out of parallel), with one rolled 10 degre es. The misalignment is used during the forward loading dynamic test condition and applies t o both crew and passenger seats

.

Extent of Amendment Sought and Reason(s)

Boeing hereby petitions for an exemption from the floor warpage testing requirements of FAR 25.562 Amendment 25

- 64, for flight deck seats on Boeing Airplane Model 737 MAX ( 737

- 7/

- 8/

- 9). The 737 MAX m odels ( 737

- 7/

- 8/

- 9) are derivatives of corresponding 737NG models (737

- 700/

- 800/

- 900ER). The significant product level change for the 737 MA X models is the new engine and related changes . With respect to FAR 25.562(b)(2) , the 737 MAX flight deck seats are unchanged relative to th e 737NG model airplanes, which were granted an exemption

.

Description of Issue

Boeing 737

- 600/

- 700/

- 700C/

- 800/

- 900/

- 900ER, 757

- 300 , 767

- 200C/

- 400ER /

- 2C

, 777 series/

- 200 /

- 300 , and 787 models were exempt from this requirement based on the following justif i cation :

FAR 25.562 states that “... where floor rails or floor fittings are used to attach the seating devices t o the test fixture, the rails or fittings must be misaligned with respect to the adjacent set of rails or fittings by at least 10 degrees vertically (i.e., out of parallel) with one rolled 10 degrees.”

The preamble to Amendment 25

- 64 states: “Crash investigations have shown that localized cabin floor deformation can occur in survivable crashes. This has beenRA

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confirmed by the controlled impact demonstration and drop tests involving transport category air planes. The inability of some seats to accommodate such deformations, remain in place, and restrain the occupants can contribute significantly to [the] degree of injury during a crash. The simulated floor deformation used in the dynamic tests

... will demons trate the tolerance of the seat and its attachments to deformations that could occur in an actual crash.

The preamble also states the benefit of this amendment is believed to be that “... some lives are expected to be saved that otherwise may not have been. ”

This test requirement makes no distinction between passenger and crew seats, while the evidence mentioned in the preamble is believed to be based on passenger seats only. There is evidence to suggest that floor warpage has not been a significant factor in flight deck seat failures during survivable crash conditions.

The FAA acknowledged in the preamble to Amendment 25

- 64 that the likelihood of seats designed to meet this amendment costing more to manufacture and therefore to purchase, as well as increa sing the airplane operating cost due to a weight increase. In order to justify the increased costs, it must be expected that some lives will be saved that otherwise may not have been. This does not appear to be the case for flight deck seats. These incr eased costs will create an economic disadvantage for the 737

- 7/

- 8/

- 9 without a commensurate expectation of saving lives that otherwise may have been lost.

Statement of Public Interest

Granting of this exemption is in the public interest because it will :

 Not adversely affect flight safety;

 Improve the efficiency of the Model 737

- 7/

- 8/

- 9;

 Tend to reduce air transportation fares;

 Improve the potential for sales to foreign operators, which in turn improves the U.S. balance of payments;

Statement of No Adverse Effect on Safety

This test requirement makes no distinction between passenger and crew seats, while the evidence mentioned in the preamble is believed to be based on passenger seats only. There is evidence to sug gest that floor warpage has not been a significant factor in flight deck seat failures during survivable crash conditions. In Exemption No. 6425, the FAA noted, “Although some cockpit floor distortion have been observed after accidents, there has not been a problem with flight deck seat separations due to floor buckling on narrow body and larger airplanes which have a minimum of 40 inches of frangible structure between the flight deck floor and theRA

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lower fuselage contour. The FAA now considers that requiring testing of pilot seats with floor warpage cannot be justified on narrow body and larger airplanes.”

Summary to be Published in the Federal Register

PETITIONER : Boeing Commercial Airplanes

SECTION OF 14 CFR AFFECTED : 14 CFR 25.562(b)(2)

DESCRIPTION OF RELIEF SOUGHT : Exemption to permit relief from the 14CFR Part 25.562(b)(2) Amendment 25

- 64 compliance with the 10 degrees of track misalignment and roll test requirements for flight deck seats installed on Boeing Model 737

- 7/

- 8/

- 9 series airplanes.

Request to “Waive Publication and Comment”

The petitioner would like to request waiving the requirement for Federal Register publication because the exemption, if granted, would not set a precedent. This is not a new exemption but rather a revision to the existing one s to add additional model series aircraft. This request is based on the rationale of similarity to the 737

- 600 /

- 700/

- 700C/

- 800/

- 900/

- 900ER and exemptions granted on other Boeing models.

Privileges of the Exemption Outside of the United States

The petit ioner would like to extend the privilege of the exemption outside of the United States. The same f light deck seats are applicable to all 737NG and 737 MAX airplanes.

Conclusion

With re ference to the FAA position when granting the exemption s for previous Boeing m odels

, Boeing petitions for an exemption from the floor warpage testing requirement of 14 CFR Part 25.562(b)(2) Amendment 25

- 64 for flight deck seats installed on Boeing 737 MAX Models ( 737

- 7/

- 8/

- 9 )

.