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 the 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 cargo 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 cargo consists of large 787 airplane modules (i.e. wings and 

fuselage sections). Boeing also carries some other smaller 787 parts that can be shipped 

with these large modules and some non-787 large/outsized cargo that cannot be 

accommodated by traditional freighter aircraft and that directly supports Boeing 

corporate business activities. For the purposes 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 described above and are not used by Boeing or the 

aircraft operator to conduct commercial 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 transported 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. Transportation of Boeing business products and 

associated tooling will be between assembly 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 the 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 being shipped on the LCF are inert and will not 

propagate a fire. 
Enclosure (A) to RA-12-01541 

The cargo compartment necessary to carry these large modules 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, Boeing 

proposed that no fire protection systems would be installed in the main deck cargo 

compartment and showed an acceptable level of safety by adding other mitigating 

features and operational requirements. 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 category cargo and baggage compartments, 

including Class E cargo compartments. The FAA granted Boeing the Exemption from 

these requirements in Exemption 8769 and 8769A. When Boeing requested the 

exemptions, the existing 747-400 lower lobe cargo compartments were deactivated as 

part of the modification; therefore, an exemption from the regulations applicable to cargo 

fire protection was only requested for the main deck cargo compartment. 

In-service experience over the last four years has demonstrated that the mitigating 

features and operational restrictions for the 747-400 LCF aircraft have been effective in 

preventing cargo fires on these aircraft. Additionally, operational experience has 

indicated that the spare cargo carrying capacity not currently 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 lower cargo compartments are particularly 

suited to carrying the smaller 787 parts that can be shipped with the large modules but are 

frequently shipped separately due to floor area constraints on the Main Deck. 

Boeing is planning on reactivating the lower cargo compartments to more efficiently 

utilize the LCF aircraft in support of the 787 program and other Boeing business 

activities. Boeing is therefore requesting an exemption similar to FAA Exemption 8769 / 

8769A for some cargo fire protection requirements for the lower cargo compartments, 

providing a similar acceptable level 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 for 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 following 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 attached to) the airplane 

structure. 

(h) Flight tests must be conducted to show compliance with the 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 ventilating airflow to, or within, the compartment, and 

the controls for these means are accessible to the flight crew 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. These 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 design 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 limitations which include that these aircraft may 

transport only the cargo described above and are not permitted to be used for commercial 

operations. 

Reason
Enclosure (A) to RA-12-01541 

14 CFR 25.855(b) requires that Class E cargo compartments must have a liner, and that 

the liner must be separate from (but may be attached to) the airplane structure. Providing 

a complete cargo liner throughout the lower 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 cargo 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 providing a complete liner is mitigated by: 

 Installing partial liners that meet the requirements associated with Class E cargo 

compartments in order to provide impact protection and indication 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 cargo liners meeting the requirements 

associated with Class E cargo compartments 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 composite 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 tooling 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 identified above greatly minimize the risk of 

an aircraft loss due to a cargo fire in comparison to general 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, and therefore requests an exemption from 14 

CFR 25.855(b). 

14 CFR 25.855(h)(2) requires flight tests to show compliance 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 impracticality of conducting a cargo smoke 

penetration test, as described in FAA Advisory Circular 25-9A, in an extremely large, 

unpressurized cargo compartment. In addition, a cargo smoke penetration test, as 
Enclosure (A) to RA-12-01541 

described in FAA Advisory Circular 25-9A, would not be feasible due to the limitations 

of existing test equipment and instrumentation used to conduct cargo smoke penetration 

tests. 

 The design of the 747-400 LCF includes a pressure bulkhead at STA 532, separating the 

cargo compartments from the occupied areas, including the flight deck. The main deck 

and lower cargo compartments remain virtually unpressurized, while the flight deck and 

other regions forward of the pressure bulkhead are pressurized. This design and the 

pressure differential between the pressurized and non-pressurized compartments will 

exclude the possibility of smoke, flames, or noxious gases penetrating into the flight crew 

compartment from the cargo compartments. Boeing considers that this 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 detector system that provides 

warning to the flight crew in the event of a cargo 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 possible 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 above will be subjected to flammability 

related cargo acceptance criteria. These criteria 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 cargo 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 provide 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 for these means area accessible to the flight 

crew in the crew compartment. Conditioned pack air is directed into the main deck cargo 

compartment to ensure the 787 and other approved 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 resulting 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 exemption to 14 CFR 25.857(e)(3) was granted for the 

carriage of cargo on the main deck by Exemption 8769 / 8769A. There is no dedicated 

ventilation in the forward or aft lower cargo compartments, but air from these 

compartments is in communication with air from 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 main 
Enclosure (A) to RA-12-01541 

deck, the avionics cooling system will allow 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 flights, 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 any allowable cargo. These standards and criteria eliminate 

the need for cargo compartment ventilation control. 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 grant of these petitions since the use of air 

shipment of aircraft parts contributes to the competitive position of air transport 

manufacturers in the United States. More efficient utilization of the LCF will reduce the 

need for shipping some parts on standard commercial cargo flights, reducing the time and 

expense associated with shipments of these parts. More efficient aircraft 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 manufacturing 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 Exemption Would Not Adversely Affect Safety 

Boeing maintains that an acceptable level of airplane 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 unpressurized. In combination with cargo carriage 

restrictions, this aspect will greatly reduce the likelihood of a sustainable in-flight 

fire. 

 Boeing has developed flammability related cargo acceptance criteria (Boeing 

Document D926U013-44). These flammability criteria also apply to the tooling 

used to transport the allowable 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 Directorate 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-extinguishing or fire resistant and should not 

provide fuel for a self-sustaining fire. 

 A pressure bulkhead installed at Station 532 combined with the pressure 

differential between the pressurized Section 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 and self-extinguishing, and 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 cargo door to the aft end of the aft cargo 

door). The liners will prevent foreign object debris build-up between frames and 

damage to insulation and systems 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 floor 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 routed through the structural frames which provide 

protection from damage due to cargo movement, and are further protected from 

cargo handlers by the cargo liners or damage indication panels. The control 

cables routed through the forward pressure bulkhead (STA 532) are protected 

with enclosures to prevent inadvertent damage from cargo handlers. Control 

cable pulleys are protected with enclosures. The enclosures protect the pulleys 

from a FOD fire or jamming. 

 Control cables and hydraulic lines are protected 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 have 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 combination with other design features and 

operational limitations) to show an acceptable level 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 understood 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 when cargo is carried in flight. 

 Additional capability will be added to the 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 require that the components of the 

camera viewing system necessary for providing 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 Control 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 Boeing Process Instruction (BPI) document that 

governs the process by which the configuration control of the 787 shipping assemblies is 

maintained. 

The 747-400 LCF Airplane Flight Manual includes a limitation for cargo carriage in the 

Certificate Limitations section, identifying the FAA approved 747-400 LCF Weight and 

Balance Manual (WBM) for a list of allowable cargo. The Weight and Balance Manual 

refers to the “Allowable Cargo” document to identify the subassemblies acceptable for 

shipment, and the acceptable shipment configurations. 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 designated representative. The LCF Loadmaster 

can verify the SME is listed in the WBM, and verify that the manufacturer has provided a 

signed “Flammability Conformance Certificate” with the composite assembly. 

These procedures and controlling documents will ensure that only approved cargo is 

transported on the 747-400LCF. The main deck and lower cargo compartments will state 

cargo loading restrictions and 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 purposes than described above, such 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 compartments 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 passenger aircraft into 747-400 Large Cargo 

Freighters (LCF). The primary purpose of these 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). These aircraft are also allowed to carry other 

smaller 787 parts and some non-787 large/outsized cargo that cannot be accommodated 

by traditional freighter aircraft and that directly supports Boeing corporate business 

activities. 

These aircraft are 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 purposes than described above, such as conducting commercial 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 systems 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 Exemption 8769 / 8769A was only applicable for 

the Main Deck cargo compartment. 

The Boeing Company has identified improvements in operating efficiencies if the lower 

cargo compartments are reactivated. More efficient utilization of the LCF will reduce the 

need for shipping some parts on standard commercial cargo flights, reducing the time and 

expense associated with shipments of these parts. More efficient aircraft utilization uses 

fuel more efficiently and promotes a healthier environment. Sales of transport aircraft 
Enclosure (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 lower 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 same 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 passengers. 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-approved flammability criteria in order to be 

eligible for carriage on the 747-400 LCF. These flammability criteria are enclosed as a 

proprietary submittal in support of this exemption 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 established to ensure that only approved 

cargo is carried. 

The Boeing Company maintains that the proposed airplane configuration in conjunction 

with cargo carriage limitations will result in a design which cannot create a fire hazard. 

This will provide an acceptable level of safety in comparison to that of an airplane 

designed to carry any allowable cargo, with fully compliant cargo fire protection systems 

as required by 14 CFR, Part 25. 

(g) Additional Information in support 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 Enclosure that will be submitted to the cognizant FAA 

Directorate: 

Enclosure 2.1: Boeing Document D926U013-44, Rev D, “747-400 LCF Flammability 

Acceptance Criteria for Cargo Carriage,” 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 available outside of the United States in order to 

recognize the economic benefit of this means of air transport.