AFS-14-444-E

January 23, 2015

 Exemption No. 8825D

 Regulatory Docket No. FAA-2000-7945

Ms. Caitlin M. Randles

Supervisor, Flight Test Engineering 

The Boeing Company

P.O. Box 3707

Seattle, WA 91824-2207

Dear Ms. Randles:

This letter is to inform you that we have granted your petition to extend Exemption No. 8825, 

as amended. It explains the basis for our decision, describes its effect, and lists the conditions 

and limitations.

The Basis for Our Decision

By letters dated, August 18, 2014 and December 2, 2014, you petitioned the Federal Aviation 

Administration (FAA) on behalf of The Boeing Company (Boeing) for an extension of 

Exemption No. 8825, as amended. That exemption from §§ 61.57(a) and (b) of Title 14, Code 

of Federal Regulations (14 CFR) allows Boeing production and engineering flight test pilots 

to use any type of Boeing airplane simulator that represents any type of Boeing airplane to 

meet the takeoff and landing recent experience requirements of § 61.57 without Boeing Flight 

Training holding a part 142 training center certificate. 

As noted above, on August 18, 2014, Boeing petitioned the FAA for an extension of 

Exemption No. 8825C. Subsequently, in a letter dated December 2, 2014, Boeing petitioned 

for a revision of Exemption 8825C, which superseded its petition letter dated August 18, 

2014. In the letter dated December 2, 2014, Boeing noted an airplane in its test fleet that did 

not meet the eligibility criteria specified in Exemption 8825C condition and limitation Nos. 2 

and 3. The petition described the Boeing Commercial Airplane Company’s maritime 

surveillance airplane, the P-8I. Boeing identified this aircraft as a 737-8FV on the airplane 

identification plate and indicated that it is a 737-800 (TCDS A16WE) that incorporates 
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modifications required to perform its maritime surveillance role. The FAA issues P-81 aircraft 

special airworthiness certificates in the category of experimental for the purpose of research 

and development, as well as market survey.

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of and amendment to the exemption 

would not set a precedent, and any delay in acting on this petition would be detrimental to 

Boeing.

Our Decision

The FAA is in the process of reviewing Boeing’s request to include the P-8I, and other aircraft

certificated in the experimental category, for which a type rating (identified by the listed 

standard category type certificate data sheets) is required by the aircraft’s operating 

limitations. To ensure continuity of operations the FAA is extending Exemption No. 8825C, 

with minor edits as noted below, for a limited period of time so that the FAA can complete its 

review and provide Boeing a response that addresses this request. The FAA will issue an 

additional extension of Exemption No. 8825, as amended, with a determination on the request 

concerning experimental aircraft within the next six months. Consequently, this extension is 

granted for six months.

Condition and limitation No. 2 was modified to clarify that pilots must meet the requirements 

of both §§ 61.57(a) and (b) in one of the listed Boeing airplanes in order for those 

requirements to be considered to have been met in all of the listed Boeing airplanes. This 

amendment was requested by Boeing and is consistent with the conditions and limitations for 

similar exemptions. In addition, condition and limitation No. 2 was modified with editorial 

edits to remove erroneous text and to change ‘Boeing Commercial Aircraft’ to ‘Boeing 

Commercial Airplanes’.

Condition and limitation No. 3 was modified to for consistency with similar exemptions, 

alignment with the language used in condition and limitation No. 2, and congruency with part 

60. New Condition No. 3(d) was previously found under condition and limitation No. 3(d)(i) 

and now identifies part 60 as the simulator qualification standard. New condition and 

limitation No. 3(e) requires the simulator instructor to be designated under specific regulatory 

requirements and qualified for the simulator type used. New condition and limitation No. 3(f) 

was previously found under condition and limitation Nos. 3(d)(i) and (ii). Former condition 

and limitation Nos. 3(e) and (f) are now found under condition and limitation Nos. 3(g) and 

(h). 

The FAA has determined that the justification for the issuance of Exemption No. 8825, as 

amended, remains valid with respect to this exemption and is in the public interest. Therefore, 
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under the authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, I grant the petition of The Boeing Company to allow 

Boeing production and engineering flight test pilots to use any type of Boeing airplane 

simulator that represents any type of Boeing airplane to meet the takeoff and landing recent 

experience requirements of § 61.57 without Boeing Flight Training holding a part 142 training 

center certificate, subject to the following conditions and limitations.

Conditions and Limitations

1. This exemption applies only to pilots employed by Boeing who hold a pilot certificate 

with a type rating in at least one model of Boeing-manufactured aircraft listed in 

Boeing aircraft type certificate data sheets A6WE, A16WE, A20WE, A2NM, A1NM, 

T00001SE, or T00021SE while engaging in flight operations in one of those airplanes 

on behalf of Boeing.

2. Each Pilot In Command (PIC) subject to this exemption meeting the requirements of § 

61.57(a) and (b) in any type of Boeing airplane listed in Boeing aircraft type certificate 

data sheets A6WE, A16WE, A20WE, A2NM, A1NM, T00001SE, or T00021SE, and 

Boeing Commercial Airplanes (BCA) experimental aircraft in developmental and 

certification flight test programs, will be considered to have met the requirements of 

§§ 61.57(a) and (b) for all those types of Boeing aircraft.

3. Each PIC subject to this exemption meeting the requirements of §§ 61.57(a) and (b) in 

a simulator that represents any Boeing aircraft listed in Boeing aircraft type certificate 

data sheets A6WE, A16WE, A20WE, A2NM, A1NM, T00001SE, or T00021SE, and 

BCA experimental aircraft in developmental and certification flight test programs, will 

be considered to have met the requirements of §§ 61.57(a) and (b) for all those types 

of Boeing aircraft, subject to the following:

a. Since the beginning of the preceding 12 calendar months, the pilot must 

complete the requirements of §§ 61.57 (a) or (b) in any type of Boeing 

airplane;

b. Since the beginning of the preceding 12 calendar months, the pilot must 

accomplish 100 hours of pilot time, 10 hours of which must be in any type of 

Boeing airplane; or

c. Since the beginning of the preceding 6 calendar months, the pilot must 

accomplish 50 hours of pilot time, 5 hours of which must be in any type of 

Boeing airplane;

d. The simulators used must be qualified under 14 CFR part 60 or be a previously 

qualified simulator as defined in § 60.17(a) and approved by the FAA for all 

maneuvers required by this exemption;
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e. The simulator instructor must be designated as a flight simulator instructor for 

the respective simulator type under the part in which the simulator is approved;

f. The pilot must make three takeoffs and three landings to a full stop, subject to 

the following requirements:

i. The takeoffs and landings must be accomplished under the supervision 

of a simulator instructor who certifies the pilot being observed is 

proficient in making takeoffs and landings; and

ii. The pilot must be the sole manipulator of the flight controls;

g. The takeoffs and landings must include at least one takeoff with a simulated 

failure of the most critical powerplant and at least one landing from an 

instrument landing system (ILS) approach to the lowest ILS minimums for 

which the pilot and airplane are authorized; and

h. The flight simulator’s visual system must be adjusted to display a visual scene 

representing the period between 1 hour after sunset until 1 hour before sunrise.

4. A copy of this exemption must be provided to each PIC who operates under the terms 

of this exemption.

5. A copy of this exemption must be presented to representatives of the Administrator 

upon request.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 8825, as amended, to 

July 31, 2015, unless sooner superseded or rescinded. 

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service