Enclosure (A) to RA-12-01541

Subject: Petition for Exemptions from 14 CFR 25.855(b) and (h)(2), 25.857(e)(2) and (e)(3) – 747-400 Large Cargo Freighter, Lower Lobe Cargo Compartments

Introduction:

The main deck cargo compartment of th e 747-400 Large Cargo Freighter (LCF) is currently certified to carry large 787 assemblies and has been granted an exemption to 14 CFR 25.855(b) and (h)(2), 25.857(e)(2) and (e)(3 ). As identified in FAA exemption 8769 / 8769A, the lower cargo compartments on the LCF were deactivated and an exemption from regulations applicable to car go fire protection was only requested for the main deck cargo compartment. There are currently four LCF in operation. Boeing expects to have no more than five LCF aircraft total.

The primary purpose of these aircraft is to carry components that support 787 production. The vast majority of the car go consists of large 787 airp lane modules (i.e. wings and fuselage sections). Boeing also carries some other smaller 787 part s that can be shipped with these large modules and some non- 787 large/outsized cargo that cannot be accommodated by traditional freighter aircra ft and that directly supports Boeing corporate business activities. For the purpos es of the petition, the term “cargo” means only those items identified above.

Although Boeing owns these aircraft, they are operated on behalf of Boeing by a Part 121 operator, and the aircraft are N-registered. As a condition of the previous exemption, these aircraft transport only the cargo descri bed above and are not used by Boeing or the aircraft operator to conduct comm ercial freight hauling operations.

The 787 program has teamed with several large aircraft part suppliers located outside of the United States. These supplier/partners are responsible for building and integrating large sections of the 787 that will be transpor ted to the Everett, WA or Charleston, SC for final assembly. This global arrangement with suppliers located around the world is a necessary condition to establishing a viable airplane program. The operations base for the LCF will be in Charleston, SC. Tran sportation of Boeing business products and associated tooling will be between assemb ly and subassembly sites in Nagoya, Japan, Grotaglie, Italy, Wichita, KS, Charleston, SC, and Everett, WA. Operation of the LCF requires use of specialized ground service equipment (GSE). The specialized GSE requires trained personnel to operate and maintain it. The GSE will be located only at the

identified facilities.

The 787 assemblies being transported are th e wings and horizontal stabilizer, and fuselage sections 41, 43, 11/45, 44, 46, 47 and 48. Fuselage sections will not have seats. These 787 composite assemblies that are bei ng shipped on the LCF ar e inert and will not propagate a fire.Enclosure (A) to RA-12-01541

The cargo compartment necessary to carry thes e large modules is more than twice the volume of the main deck cargo compartmen t on a Boeing 747-400 production freighter. Due to the design constraints necessary to carry large 787 aircraft modules, Boeing proposed that no fire protection systems w ould be installed in the main deck cargo compartment and showed an acceptable level of safety by adding other mitigating features and operational requi rements. Boeing requested an exemption from certain aspects of 14 CFR part 25, sections 25.855 and 25.857. These sections describe the certification requirements for transport ca tegory cargo and baggage compartments, including Class E cargo compartments. Th e FAA granted Boeing the Exemption from these requirements in Exemption 8769 a nd 8769A. When Boeing requested the exemptions, the existing 747-400 lower lobe car go compartments were deactivated as part of the modification; therefore, an exemp tion from the regulations applicable to cargo fire protection was only requested fo r the main deck cargo compartment.

In-service experience over the last four years has demonstrated that the mitigating features and operational restrict ions for the 747-400 LCF aircra ft have been effective in preventing cargo fires on these aircraft. Additionally, operational experience has indicated that the spare car go carrying capacity not curren tly available due to the deactivation of the lower cargo compartments could greatly increase the utility of the 747-400 LCF if that space were available to carry the same type of Boeing business products allowed on the Main Deck. The lo wer cargo compartments are particularly suited to carrying the sm aller 787 parts that can be shippe d with the large modules but are frequently shipped separately due to floor area constraints on the Main Deck.

Boeing is planning on reactiva ting the lower cargo compartments to more efficiently utilize the LCF aircraft in support of the 787 program and other Boeing business activities. Boeing is theref ore requesting an exemption similar to FAA Exemption 8769 / 8769A for some cargo fire protection require ments for the lower cargo compartments, providing a similar acceptable le vel of safety as currently approved for the main deck cargo compartment. If Boeing decides to offer these or similar aircraft for sale to other parties, Boeing will initiate a new certification project with the FAA in order to establish any configuration changes appropriate fo r the carriage of commercial cargo.

(a) Name and Address of the Petitioner

The Boeing Company

c/o Mr. Bob Beaudreau

3855 N Lakewood Blvd

P.O. Box 200

Mail Code: D800-0018 Long Beach, CA 90846-0200

(b) Section of 14 CFR from which Exemption is Requested

Boeing is seeking an exemption from the fo llowing sections of 14 CFR for the Model

747-400 LCF:Enclosure (A) to RA-12-01541

14 CFR 25.855(b) and (h)(2): Cargo or baggage compartments.

(b) Class B through Class E cargo or baggage compartments, as defined in §25.857, must have a liner, and the liner must be separate from (but may be atta ched to) the airplane

structure.

(h) Flight tests must be conducted to s how compliance with th e provisions of §25.857 concerning—

(2) The entries of hazardous quantities of smoke or extinguishing agent into compartments occupied by the crew or passengers, and

14 CFR 25.857(e):

(e) Class E. A Class E cargo compartment is one on airplanes used only for the carriage of cargo and in which—

(1) [Reserved]

(2) There is a separate approved smoke or fire detector system to give warning at the pilot or flight engineer station;

(3) There are means to shut off the ventilati ng airflow to, or within, the compartment, and

the controls for these means are accessible to the flight cr ew in the crew compartment;

Boeing has already requested Exemptions for 14 CFR 25.855(b) and (h)(2) and 25.857(e)(2) and (e)(3) for the Main Deck. Th ese exemptions were granted and approved in Exemption 8769 and 8769A.

(c) Extent of Relief Sought and Reason

Extent of Relief Sought Boeing is requesting relief from the desi gn and performance requirements of 14 CFR 25.855(b) and (h)(2), and 14 CFR 25.857(e )(2) and (e)(3) for the lower cargo compartments of the 747-400 LCF. This exemption is requested for a limited number of aircraft (5 maximum) with certain limitati ons which include that these aircraft may transport only the cargo described above and are not permitted to be used for commercial operations.

ReasonEnclosure (A) to RA-12-01541

14 CFR 25.855(b) requires that Class E cargo co mpartments must have a liner, and that the liner must be separate from (but may be a ttached to) the airplane structure. Providing a complete cargo liner throughout the lowe r lobe cargo compartments on the LCF requires a completely new design relative to the standard 747-400 aircraft, due to the stairway located in the forward lower car go compartment providing access to the main deck during ground operations, existing system wire routing below the floor beams different from the original production wiring runs, and a different closeout of the aft cargo compartment due to the swing tail.

Boeing considers that the requirement for pr oviding a complete liner is mitigated by:

 Installing partial liners that meet the requirements associated with Class E cargo compartments in order to provide imp act protection and i ndication of potential inadvertent damage to critical systems resulting from ground/cargo handling operations. These liners will be used to closeout the sidewalls and sloping

sidewalls in the lower lobe areas used to transport cargo and will also aid in preventing FOD from collecting within the compartment volume. This will reduce the likelihood of the buildup of debris behind or under the liners. Critical areas and systems not covered by car go liners meeting the requirements associated with Class E cargo compartmen ts will be protected with enclosures that will provide indication of potential damage.

 Limiting the cargo that is carried to only approved 787 and other components described above, and thereby assuring that there will not be a fire hazard in the lower cargo compartments. The 787 compos ite assemblies that are being shipped in the LCF will not propagate a fire. Boeing has developed flammability related cargo acceptance criteria (Boeing Document D926U013-44). This Boeing proprietary document has been approved by the cognizant FAA Directorate. These flammability criteria also apply to the tooling used to transport the allowable cargo. As a result, the tool ing and cargo will not create an ignition

source or create a fire hazard.

 Conducting periodic Visual Inspections of the lower cargo compartments.

Boeing maintains that the mitigating factors id entified above greatly minimize the risk of

an aircraft loss due to a car go fire in comparison to genera l commercial cargo aircraft. Boeing considers that an acceptable level of safety will be provided by the 747-400 LCF design and strict control of cargo carried, a nd therefore requests an exemption from 14 CFR 25.855(b).

14 CFR 25.855(h)(2) requires fli ght tests to show complian ce with the provision of 14 CFR 25.857 concerning the entries of hazardous quantities of smoke or extinguishing agent into compartment occupied by the crew or passengers. Relief from 14 CFR 25.855(h)(2) is requested due to the impr acticality of conducting a cargo smoke penetration test, as described in FAA Adviso ry Circular 25-9A, in an extremely large, unpressurized cargo compartment. In addi tion, a cargo smoke penetration test, asEnclosure (A) to RA-12-01541

described in FAA Advisory Ci rcular 25-9A, would not be f easible due to the limitations of existing test equipment and instrumentati on used to conduct cargo smoke penetration

tests.

The design of the 747-400 LCF includes a pr essure bulkhead at STA 532, separating the cargo compartments from the occupied areas, including the flight d eck. The main deck and lower cargo compartments remain virtually unpressurized, while the flight deck and other regions forward of the pressure bulkh ead are pressurized. This design and the pressure differential between the pressurized and non-pressurized compartments will exclude the possibility of smoke, flames, or noxi ous gases penetrating in to the flight crew compartment from the cargo compartments. Bo eing considers that th is design alleviates the need to conduct the tests required by 14 CFR 25.855(h)(2). Boeing therefore requests exemption from 14 CFR 25.855(h)(2 ), similar to the exemption already approved in Exemption 8769 / 8769A.

14 CFR 25.857(e)(2) requires an approved smoke or fire det ector system that provides warning to the flight crew in the event of a car go fire. Boeing maintains that the lack of a fire detection system is compensated for by the limitations described earlier on the cargo

carried on the 747-400LCF. The limitations will ensure that any possi ble cargo fire that could occur will not represent a thermal threat to the airplane at any time. The 787 end item assemblies and components described a bove will be subjected to flammability related cargo acceptance criteria. These criteri a will require that all of the parts carried will be essentially inert, and there will not be any ignition sources or sufficient fuel within the cargo to sustain or propagate a ca rgo fire. This will ensure that there will never be any cargo allowed which could provide sufficient fuel for a sustainable cargo

fire.

Boeing believes that these factors combine to pr ovide an acceptable level of safety for the type of cargo carriage missions described above for these four to five special use, special purpose, special intended use airplanes, and Boeing therefore requests relief and exemption from 14 CFR 25.857(e)(2).

14 CFR 25.857(e)(3) requires means to shut off the ventilating airflow to, or within, the cargo compartment, and that the controls fo r these means area accessible to the flight crew in the crew compartment. Conditioned pa ck air is directed into the main deck cargo compartment to ensure the 787 and other appr oved components remain above a specific temperature. The ventilation system design also includes open vent holes located in the aft end of the main deck compartment, which are needed for the outflow of air from the cargo compartment. The flow of air resulti ng from the open vent holes is not controlled and for this reason, the complete control of ventilation air to and within the cargo compartment is not possible. An exempti on to 14 CFR 25.857(e)(3 ) was granted for the carriage of cargo on the main deck by Ex emption 8769 / 8769A. There is no dedicated

ventilation in the forward or aft lowe r cargo compartments, but air from these compartments is in communication with air fr om the main deck and therefore the same inability to shut off the ventilation on the main deck applies to the lower cargo compartments. In addition to this constant exposure to ventilation air from the mainEnclosure (A) to RA-12-01541

deck, the avionics cooling system will allo w the flow of air from the pressurized compartment due to pressure differential into the forward cargo compartment under the following conditions:

 At the top of descent, once every 10 f lights, the avionics cooling overboard exhaust valve will be open (allowing airflow into the compartment) for two

minutes.

 If smoke is detected in the E/E bay or smoke is present in the Flight Deck, the overboard exhaust valve will be open.

 If there is a loss of avionics cooling airflow due to 2 fans failing, the overboard exhaust valve will open.

Compliance with 14 CFR 25.855(d)(e), and (g), and cargo limited to that which will not create a fire hazard, will provide an acceptable level of safety equivalent to that of an airplane designed to carry a ny allowable cargo. These standards and criteria eliminate the need for cargo compartment ventilation cont rol. Therefore, Boeing requests relief and exemption from 14 CFR 25.857(e)(3) for the lower cargo compartment, similar to the exemption request 8769 / 8769A.

Boeing requests this exemption petition include allowance for the carriage of components that will be used for any necessary testing of this aircraft major change, required for gathering test data for the LCF.

(d) Public Interest

The public interest would be advanced by the gr ant of these petitions since the use of air shipment of aircraft parts contributes to the competitiv e position of air transport

manufacturers in the United States. More e fficient utilization of the LCF will reduce the need for shipping some parts on standard comm ercial cargo flights, reducing the time and expense associated with shipments of these part s. More efficient airc raft utilization uses fuel more efficiently and promotes a healthier environment. Sales of transport aircraft

contributes to the balance-of -trade, the gross domestic product and the economic health of the United States. The level of safety is not compromised in comparison to similar existing large transport airplane designs and the airplane will not carry passengers. In addition to creation of jobs and promotion of United States commerce, the large cargo freighter global logistical transportation system contributes to the competitiveness of Boeing airplanes in the global market through the use of lean manu facturing concepts on a global level. These are all in the public interest and the design proposed in combination with these petitions maintains an acceptable level of safety.

(e) Reasons why Granting the Exemptio n Would Not Adversely Affect Safety Boeing maintains that an acceptable level of ai rplane safety will exist by ensuring that a fire hazard cannot exist in the lower cargo compartments that would compromise continued safe flight and landing. This includes the following considerations:Enclosure (A) to RA-12-01541

 The cargo bay will be virtually unpressurize d. In combination with cargo carriage restrictions, this aspect w ill greatly reduce the likelihood of a sustainable in-flight

fire.

 Boeing has developed flammability relate d cargo acceptance criteria (Boeing Document D926U013-44). These flammability criteria also apply to the tooling used to transport the allo wable cargo. As a result, the tooling and cargo should not create an ignition source or create a fire hazard. This document has already been approved by the cognizant FAA Direct orate in support of the Main Deck Exemption 8769 / 8769A.

 The 747-400 LCF airplane design minimizes ignition sources within the main deck and lower cargo compartment, and construction materials for the cargo compartments are metal, self-extinguish ing or fire resistant and should not provide fuel for a se lf-sustaining fire.

 A pressure bulkhead installed at St ation 532 combined with the pressure differential between the pressurized S ection 41 and the cargo compartment will preclude any smoke penetration into the flight deck from the main deck or lower

cargo compartment.

 By design and compliance to 14 CFR 25.855(e)(2) and 14 CFR 25.869 the

electrical wires will be fire resistant a nd self-extinguishing, an d installation of the

wires will not create a fire hazard.

 Cargo sidewall liners will be installed throughout the lower cargo compartments (from the forward end of the forward car go door to the aft end of the aft cargo door). The liners will prevent foreign obj ect debris build-up between frames and damage to insulation and syst ems due to cargo handlers.

 A standard cargo floor will be installed to limit damage to insulation and systems due to cargo handlers.

 A periodic visual inspection of the lower cargo compartments will be conducted to limit the buildup of FOD and other contaminants.

 Wiring routed underneath the main deck fl oor beams will be protected with cargo liners meeting the requirements associated with Class E cargo compartments or will be protected with enclosures that will provide indication of potential damage.

 Control cables are also r outed through the structural frames which provide protection from damage due to cargo move ment, and are further protected from cargo handlers by the cargo liners or damage indication panels. The control cables routed through the forward pressu re bulkhead (STA 532) are protected with enclosures to prevent inadvertent damage from cargo handlers. Control cable pulleys are protected with enclosur es. The enclosures protect the pulleys from a FOD fire or jamming.

 Control cables and hydraulic lines are pr otected by cargo movement or cargo handlers by design.

 New insulation blankets, where used, will meet 14 CFR 25.856 requirements and

therefore are not a source of combustible material. Where insulation blankets are not used, the exposed airplane structure does not provide a source of combustible

material.Enclosure (A) to RA-12-01541

 Limited fleet exposure with only four to five 747-400 LCF being built, these special use special intended airplanes ha ve a very small fleet hour exposure which further mitigates the potential hazard exposure.

As identified in the FAA approval of Exemption 8769 / 8769A, the Camera Viewing System is a required system, necessary (in co mbination with other design features and operational limitations) to show an acceptable le vel of safety for these aircraft to be exempted from the requirements of 14 CFR §§ 25.855(b), 25.855 (h)(2), 25.857(e)(2), and 25.857(e)(3). It is unde rstood that the Camera Viewing System provided some capability of determining the status of the main deck cargo compartment at any time and it is required to be operational wh en cargo is carried in flight.

 Additional capability will be added to th e Camera Viewing System to provide the capability of determining the status of each lower cargo compartment at any time.

The MMEL and DDG will be amended to re quire that the components of the camera viewing system necessary for pr oviding coverage of each lower cargo compartment will be functional prior to each flight for which cargo is loaded into that lower cargo compartment.

Boeing developed and maintains a Cargo C ontrol Process to define the method of ensuring compliance to Document 926U013-44, the Flammability Acceptance Criteria for Cargo Carriage on the LCF. This is a Bo eing Process Instructi on (BPI) document that governs the process by which the configurati on control of the 787 shipping assemblies is

maintained.

The 747-400 LCF Airplane Flight Manual include s a limitation for carg o carriage in the Certificate Limitations section, identify ing the FAA approved 747-400 LCF Weight and Balance Manual (WBM) for a list of allowabl e cargo. The Weight and Balance Manual refers to the “Allowable Cargo” document to identify the subassemblies acceptable for shipment, and the acceptable shipment confi gurations. The WBM also lists the allowed Shipping Mechanical Equipment (SME) numbers and configurations and requires that each assembly being shipped come with a “Flammability Conformance Certificate” signed by the manufacturer/assembler’s designa ted representative. The LCF Loadmaster can verify the SME is listed in the WBM, and verify that the manuf acturer has provided a signed “Flammability Conformance Certificate” with the composite assembly.

These procedures and controlling document s will ensure that only approved cargo is transported on the 747-400LCF. The main deck and lower cargo compartments will state cargo loading restrictions a nd refer to the airplane Weight and Balance Manual for

further information.

These aircraft will be operated on behalf of Boeing by a Part 121 operator. Boeing restricts the aircraft’s usage such that they cannot be offered for hire by Boeing or the operator for any other purpos es than described above, su ch as conducting commercial freight hauling operations.Enclosure (A) to RA-12-01541

(f) Summary for Publication in the Federal Register

Rule from which the exemption is being sought:

In accordance with 14 CFR 11.81, the Boeing Company hereby petitions for an exemption from the requirements of 14 CFR 25.855(b) and (h)(2), and 14 CFR 25.857(e)(2) and (e)(3) for the lower cargo co mpartments of the 747-400 LCF. The FAA previously granted a similar exemption to these requirements for the main deck cargo compartment of the 747-400LCF in 2007 as Exemption No. 8769 / 8769A. Exemption No. 8769 / 8769A was granted for up to five aircraft.

Brief description of the nature of the exemption:

Boeing has converted four 747-400 passenge r aircraft into 747-400 Large Cargo Freighters (LCF). The primary purpose of th ese aircraft is to carry components that support 787 production. The vast majority of the cargo consists of large 787 airplane modules (i.e., wings and fuselage sections). Th ese aircraft are also allowed to carry other smaller 787 parts and some non-787 large/out sized cargo that cannot be accommodated by traditional freighter aircraft and that directly supports Boeing corporate business

activities.

These aircraft are operated on behalf of Bo eing by a Part 121 operator. Boeing restricts the aircraft’s usage such that they cannot be offered for hire by Boeing or the operator for any other purposes than described above, su ch as conducting commerc ial freight hauling operations. In addition, the LCF main deck has a special cargo handling system with rails which will not interface with air cargo industry standard pallets. All Boeing enterprise cargo carried is required to meet the Boeing-developed, FAA-approved flammability criteria and must be carried in certified shipping mechanical equipment (SME) or on pallets meeting the approved flammability criteria.

The cargo compartment necessary to carry the large, out-sized modules for the 787 program is more than twice the volume of the main deck cargo compartment on a Boeing 747-400 production freighter. Due to the design constraints necessary to carry large 787 aircraft modules, no fire protection system s were installed in the main deck cargo compartment. This required an exemption from 14 CFR part 25, sections 25.855(b) and (h)(2), and 25.857(e)(2) and (e)(3). The lower cargo compartments were initially deactivated and the previously granted Ex emption 8769 / 8769A was only applicable for the Main Deck cargo compartment.

The Boeing Company has identified improvement s in operating efficiencies if the lower cargo compartments are reactivated. More effi cient utilization of the LCF will reduce the need for shipping some parts on standard comm ercial cargo flights, reducing the time and expense associated with shipments of these part s. More efficient airc raft utilization uses fuel more efficiently and promotes a healthier environment. Sales of transport aircraftEnclosure (A) to RA-12-01541

contributes to the balance-of -trade, the gross domestic product and the economic health

of the United States.

Implementation of the features in the lo wer lobe cargo compartments necessary to comply with 14 CFR Part 25, sections 25.855( b) and (h)(2), and 25.857(e)(2) and (e)(3) are not warranted, given that exemptions to these requirements have already been granted for the main deck. Boeing will provide the sa me compensating features in the lower lobe cargo areas as were required for Exemption 8769 / 8769A on the main deck. The level of safety will not be compromised in comparison to similar existing large transport airplane designs and the airplane will not carry passe ngers. Boeing therefore requests the same exemptions allowed for the main deck also be allowed for the lower cargo compartments.

The cargo compartments on these aircraft will be unpressurized, and all cargo will comply with Boeing-developed and FAA-approve d flammability criteria in order to be eligible for carriage on the 747-400 LCF. Thes e flammability criteria are enclosed as a proprietary submittal in support of this ex emption request. These criteria and the operating environment will ensure that the cargo carried will not present a fire hazard to the 747-400 LCF. Airplane limitations will be es tablished to ensure that only approved cargo is carried.

The Boeing Company maintains that the propos ed airplane configuration in conjunction with cargo carriage limitations will result in a design which cannot cr eate a fire hazard. This will provide an acceptable level of safety in comparison to that of an airplane designed to carry any allowabl e cargo, with fully compliant cargo fire protection systems as required by 14 CFR, Part 25.

(g) Additional Information in suppo rt of the exemption request

Boeing requests that the FAA not publish a summary of this petition for exemption and not request comments for this petition for exemption because the relief requested is identical to exemptions granted previously in Exemption 8769 / 8769A.

Additional Proprietary Encl osure that will be submitted to the cognizant FAA

Directorate:

Enclosure 2.1: Boeing Document D 926U013-44, Rev D, “747-400 LCF Flammability Acceptance Criteria for Cargo Ca rriage,” dated February 26, 2007.

(h) Application of Exemptions outside the United States

This exemption applies to the type design for a transport airplane designed to transport major assemblies built outside of the United States. The privileges for this exemption for this aircraft are necessary to be made availa ble outside of the United States in order to recognize the economic benefit of this means of air transport.