Enclosure RA

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Petition for Amendment to Exemption No. 10376, which permits temporary relief from 14 CFR 25.809(a), Amendment 25

- 116

Name and Address of the Petitioner Doug Lane, Director The Boeing Company PO Box 3707 Seattle, Washington, 98124

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

Exemption No. 10376, The FAA’s Decision section, Limitation 2 This exemption does not apply to any airplanes delivered after August 1, 2014.

The Extent of Amendment Sought and Reason(s)

Regulation Allows / Requi res: Amendment is Necessary because: Exemption No. 10376 Allows partial relief from §25.809(a) for a limited number of 747

- 8 airplanes (those delivered on or before August 1, 2014). Due to unforeseen 747

- 8 build, flight test and revised airplane delivery schedules, not all 747

- 8 airplanes originally targeted for relief under Exemption No. 10376 can be delivered prior to August 1, 2014. However, this requested amendment still results i n fewer airplanes being covered by the exemption than was originally envisioned when the exemption was granted.

Production of the initial 747

- 8 airplanes started prior to the decision to include § 25.809(a) at Amendment 25

- 116 in the certification basis of the 747

- 8. Subsequently, the FAA granted E xemption No. 10376, which provided Boeing with temporary relief from the “all lighting conditions” requirement in § 25.809(a). This relief provided the time necessary to develop, certify and incorporate in

- sequen ce a fully

compliant exterior lighting system. This new lighting system is scheduled to be incorporated as an “and

- on” change and an airplane with that system will be certified and delivered prior to August 1, 2014. Boeing is anticipating a difference in the build versus the delivery sequence of the airplanes. As such, the first line number with the new lighting system incorporated is not anticipated to be the first line number with the new lighting system to deliver. However, all 747

- 8 airplanes manufact ured after the first line number incorporation will include the fully compliant exterior emergency lighting system.

Due to unforeseen flight testing requirements using an early 747

- 8 airplane and completion of some of the production 747

- 8 airplanes bein g delayed due to unforeseen circumstances, the delivery dates of a few of these airplanes will extend beyond August 1, 2014. These airplanes were specifically intended to be covered by the relief permitted by Exemption No. 10376. It would create a signifi cant and unwarranted burden if these airplanes had to be reworked out of sequence to incorporate the fully

- compliant exterior emergency lighting system. Boeing hereby requests that the exemption be amended to provide relief for all 747

- 8 airplanes manufac tured prior to the “and on” incorporation point and not based on the individual airplane delivery dates.

Description of IssueEnclosure RA

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As discussed in Exemption No. 10376, §25.809(a) at Amendment 25

- 116 was a late decision for the certification basis of the Model 747

- 8. Since that addition occurred after the 747

- 8 production line had already started, the FAA granted relief for a limited number of airplanes to allow Boeing sufficient time to develop, certify and incorporate into production a new, fully

- compli ant exterior lighting system. The exemption grants relief for all 747

- 8 airplanes delivered on or before August 1, 2014.

Boeing is currently in the process of certifying the new exterior lighting system. The new system will be incorporated as part of a 74 7

- 8 “and

- on” change on airplane manufacturing line number 1499. Boeing is anticipating a difference in the build versus the delivery sequence of the airplanes. As such, the first line number with the new lighting system incorporate d (1499) is not anticipa ted to be the first line number with the new lighting system to deliver; however the new exterior lighting system will be certified and delivered on a LN (expected to be LN 1500) prior to August 1, 2014. This “and

- on” incorporation of a fully compliant ex terior lighting system meets the intent of Exemption No. 10376 since an airplane will be fully

compliant with §25.809(a) at Amendment 25

- 116, and it will be certified and delivered to the airline customer prior to August 1, 2014. Therefore, only those 747

- 8 airplanes built prior to LN 1499 need relief from the “all lighting conditions” requirement in § 25.809(a).

Due to unforeseen 747

- 8 build, flight test and revised airplane delivery schedules, a couple of 747

- 8 airplanes will not support build/change in corporation, certification and delivery prior to August 1, 2014. As discussed in Exemption 10376, the 747

- 8’s complexities and schedule challenges for integrating a new lighting system into the hybrid design make it very challenging to incorporate a new i ntegrated exterior lighting system into the already built airframes. The FAA recognized the complexity of modifying fuselage structure and the fact that the system being designed and installed is unique and does not serve other certification functions when it granted the temporary relief needed for the development, certification and an in

- sequence production incorporation of the new exterior lighting system. While it was unforeseen that the delivery of some of the 747

- 8 airplanes would occur after August 1 , 2014, the rationale and justification for continued relief for these airplanes is the same as that provided in Exemption No. 10376. That is, it would create a significant and unwarranted burden, and would lead to further delivery delays if these airplan es that will be delivered after August 1, 2014 are required to undergo the extensive rework needed to incorporate the new integrated exterior emergency lighting system. Therefore, Boeing requests that the exemption be amended to provide relief from the “a ll lighting conditions” requirement for non

- compliant 747

- 8 airplanes based on the “and

- on” incorporation point instead of being based on their individual delivery dates. Per the current production schedule, amending the original grant as is being request ed herein will actually result in the fewer airplanes entering service without the fully

- compliant emergency lighting system than was originally envisioned when Exemption No. 10376 was granted.

Statement of Public Interest The Model 747

- 8 fully complies with §25.809 (a) as required by the certification basis, except as related to the “all lighting conditions” requirement. Granting this petition for amendment is in the public’s interest because it would allow the 747

- 8 airplanes that were designed and bui lt without a fully compliant exterior lighting system to be delivered without requiring the very significant rework necessary to incorporate the integrated lighting system. This is consistent with the intent of the relief permitted by the original grant o f exemption No. 10376. Conversely, if this requested relief is not granted, it would certainly lead to further delays in the deliveries of these 747

- 8 airplanes due to the need for modifications associated with incorporating the new external lighting syst em. Since the 747

- 8 provides many industry

- leading operating economics, environmental improvements and safety improvements relative to previously certificated airplanes, it would be in the public’s interest to allow these 747

- 8 airplanes to enter service without further delivery delays. Also, given that all the current 747

- 8 customers are overseas, further delivery delays of the 747

- 8 are not in the interest of the public due to the potential negative impact to export sales and the balance of trade.

Sta tement of No Adverse Effect on Safety The amendment being requested herein will not adversely affect safety

. The original grant provided relief to a limited number of airplanes based on their delivery dates. Boeing is simply requesting that the applicabili ty of the grant be revised to correspond to the “and

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external lighting system. It is worthy of note that Boeing is not requesting that additional airplanes be granted relief beyond those originally envisioned in the original grant.

Request to ‘Waive Publication and Comment’ Boeing requests to waive the requirement for publication and comment since there is no appreciable change to the intent of the relief permitted by Exemption No. 10376. As part of an “and

- on” change, a fully compliant exterior lighting system will be impl emented, certified and delivered on a 747

- 8 airplane prior to August 1, 2014, thus meeting the spirit of Exemption No. 10376. However, due to unforeseen circumstances, the delivery of some of the airplanes (without the exterior lighting system) will be af ter August 1, 2014. The rationale for relief for these early production airplanes remains unchanged from that discussed in Exemption No. 10376. This petition for amendment simply requests that relief be allowed for airplanes manufactured prior to the “an d

- on” change incorporation airplane, regardless of their actual delivery dates.

Privileges of the Exemption Outside the United States The privileges of Exemption No. 10376 outside the United States are unchanged by this petition for amendment.

Conclusion Boeing is incorporating an exterior lighting system that is fully compliant with §25.809 (a) at Amendment 25

- 116 as part of an “ and on” change on airplane manufacturing line number 1499. All 747

- 8 airplanes manufactured after LN 1499 will be eq uipped with the fully compliant exterior lighting system. Boeing is anticipating a difference in the build versus the delivery sequence of the airplanes. As such, LN 1500 is expected to be the first production airplane that will be certified and delivered with the new exterior lighting system prior to August 1, 2014 and LN 1499 with new exterior lighting system is expected to be delivered after August 1, 2014. It is requested that the relief from the “all lighting conditions” aspect of §25.809(a) at Amendme nt 25

- 11 6 apply to all 747

- 8 airplanes manufactured prior to LN 1499. Boeing’s request herein is consistent with the original intent to incorporate an “and on” production change prior to August 1, 2014. However, due to unforeseen circumstances with some o f the airplanes , some airplane delivery dates are being delayed longer than previously planned. Therefore, for the reasons discussed above and in Exemption No. 10376, Boeing requests that the FAA amend Exemption No. 10376 to allow relief for all 747

- 8 air planes manufactured prior to LN 1499 regardless of the actual airplane delivery date. As described above, g ranting this petition is in the public’s interest and it will not adversely affect safety.

Summary to be published in the Federal Register

PETITI ONER : Boeing Commercial Airplanes

SECTION OF 14 CFR AFFECTED : 14 CFR 25.809(a) at Amendment 25

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DESCRIPTION OF RELIEF SOUGHT : It is requested that exemption No. 10376 be amended to clarify that relief from the “all lighting conditions” requirement applies to 747

- 8 airplanes built prior to an “and

on” incorporation of a fully compliant exterior lighting system. An airplane with the fully compliant exterior lighting system will be certified and delivered prior to the exemption expiration date specifi ed in the existing exemption.