i•" AEROMEXICO. f~ 

June.241

h, 2013 

REF.: MEXLH-312/13 

U.S. Department of Transportation 

Docket Operations 

1200 New Jersey Avenue. 

S.E. West Building, Ground Floor 

RM W12-140, Washington D.C. 20590 

ATT'N: TO WHOM IT MAY CONCERN: 

. ·.-... 

·. i·:.-

-- ·.·: l· ·. 

·.· ·: .. · .. 

We kindly request your ·authorization for ail exemption to comply with: the ·14 CFR, Part 129;117, 

paragraph (e)(1). · 

The·exemption we are requesting is an additional year for the 50% requirement due by December 

2!;>'; 2014. 

The Federal Aviation Administration Issued FAR 129.117, which requires operators of transport 

categor)t airplanes with U.S. registered transport category, turbine- powered airplanes with a type 

certificate issued after January 1, 1958, to install a Flammability Reduction Means (FRM) in fifty 

percent of eachopera~or fleet no later than December 26, 2014, and one hundred percent of each 

op_erator fleet no later than December 26, 2017. To comply with.this requirement Aeromexico will 

install a Nitrogen Generation· System (NGS) on its United States registered aircraft in accordance 

with the Boeing Service BUI.Ietins. No. 737-47-1002R1 ".Installation of the Provisions for Nitrogen 

Generation System", dated April 24, 2012; 737-47-1003R1 ''Installation of the Nitrogen Generation 

System'', dated April24, 2012 and 777~47-0002R2 "Nitrogen Generation System-Installation", dated 

November 21, 2012. · · 

As support for the exemption application we provide the followin~ information: 

The development ofthe ·oEM modification instructions, as well as' the fabrication and availability of 

required parts,· took much more time than had originally been anticipated, Boeing issued in 

pecember 2010 actions for FRM and re)ease NGS SB & kits in August 2011 for B-777 & 

September 2011 for B-737 which represents 8 months 'delay. This effectively reduced the time 

rermiining to modify airplanes before the December 261h, 2014 deadline. · · 

The in~tallation of the. NGS requires approximately 620 man-hours for the· B-737, and 900 

man-hours for the B-777 as estimated by Boeing, and it is inefficient to schedUle the modification 

separated from each airplane's heavy maintenance visit. Even when optimizing aircraft downtime 

by performing the modification together with the heavy checks, the resulting aircraft downtime is still 

increased and causing producti.oh lines saturation. ' . ' . . .. 

We require the mentioned exemption because the plarined maintenance workload for 2013 and 

2014 includes a relevant increase, mainly related to additional activities added to our maintenance 

program, additional airworthiness requirements (Airworthiness Directives arid Alert Service Bulletins 

Compliance); fle'et changes (incorporations and lease returns), and cabin reconfiguration changes 

to improve passenger comfort. Additionally, our MRO operation will be relocating from Guadalajara,· 

Mexico, to au·eretaro, Mexico, ·during this year, which will impact: our maintenance capacity, . 

increasing the complexity of modifying 50% of our affected fleet before the deadline (26 Dec 2014). 

the requested one year extension of the 50%dea'dliile would help to distribute-the workload without 

affecting the 100 % deadline, arid would also alleviate the impact to our operations and allow for the 

perfprmance of all of the modification's in house, as opposed to· outsourced, which in our case 

would significantly increase the cost. ' ' . 
ii AERO MEXICO. fiJ . th June24 , 2013. 

REF.: MEXLH~312/13 

.· . .· ' . . ' . . 

itis our belieft.hat granting the requested e~emption ~ouldbe .in the. public interest because it 

would. reduce the unavailability of aircraft for operation, allowing Aeromexico to provide the 

demanded air transportation. Because of the relatively small size of Aeromexico's fleet, increasing 

t~e.airplane on ground time for thi~ installation without an extension, would. put Aeromexico .in a 

pisadvantaged position as compared. tq co,mpetitors that will not incorporate the modification 

because they do not operate US registered airplanes, as well as to competitors that operate much 

larger fleets and can manage multiple airplanes on ground without major impact to their operation. 

In addition, the Mexican economy is projecting important growth for this and the following years, 

and therefore additional availability of airplanes will be required to cover the demand. 

. . ; . . . 

Safety will not be adversely affected by the one year exemption, as Aeromexico is constantly 

renewing its fleet, and the airplanes are maintained to meet all the aeronautical authority and 

manufacturer requirements. Moreover Aerotnexico airplanes have not been involved in· any related 

flammability fuel tank issues. It is also··· important to mention that during 2012 Aeromexico 

incorporated 3 new 737-800's equipped with NGS and during 2013 and 2014, will be incorporating 

7 additional 737-SOO's and 5 new Boeing ?87's, all of which will have the NGS system in$talled 

during production. Although the additional ?37's will not be US registered and will therefore ho~ be 

accountable for compliance with FAR129.117; they will in fact be improving the status of the overall 

Aeromexico fleet, which is also relevant to .the. United States because they will be flying to US 

destinations and .transporting US citizens. 

Aeromexico wishes tci exercise the privileges of this exemption outside the United States because 

it is ·a Foreign Operator of U.S. Registered Aircraft. · 

Additional information 

The following tables show the Aeromexico schedule for the NGS installation, considering the one 

year exemption. 

Boeing 777 J 

No. REG. 2013 2014 2015 2016 2017 Total NUMBER 

1 N776AM •1:-;.'.':Jx •,i!i,,;.:.;;~ 

;; ' .~•.r":'t:::~~~A 

2 N745AM m.~k~~~~·l~i~il 

3 N746AM •. ~6;Al'H7,J '•' .1:dil;;t; :·t:·Q. < 4 N774AM •. : l)·r 

.~........ .·•. '• . 

1 1 1 1 4 

% 25 50 75 100 100 

COMPLIANCE 
.·. ft'AEROMEXICO. f~ June241

h, 2013 

REF.: MEXLH-312/13 

Boeing 737 

No. REG. 2013 . ~Oi4 . 2015. 2017. Total NUMBER 

1 ·N997AM .. ' ... 

2 . · N784XA 

3 N851AM 

4 N788XA 

. : 5 . N853AM· 

. ' 6 . N904AM 

7 N855AM 

8 N857AM 

9 N906AM 

10 N908AM 

11 N842AM 

12 . N423AM 

13 . N126AM 

14 N950AM 

15 N359AM 

16 N520AM 

17 . N858AM 

. . 18 N859AM 

19 N86iAM 

20 N860AM 

21 N342AM 

7 3 6 4 21 

% COMPLIANCE 5 38 52 81 100 100 
li AEROMEXICO. f~ 

June 241h, 2013 

REF.: MEXLH-312/13 

do not have airplanes manufa;ctured before 2011 that have been fitted·in production with 

Flammability Reduction Means (FRM). 

Our preliminary .airplane retirement plan includes three Er737-700 u.s. ·registered airplanes to be 

removed from our fleet during next year. With this removal the percentage of compliance at the 

end of 2015 will be 61% instead of the.proposed 52% from the tables. 

Aeromexico has already ordered the required parts forfifty percent of the affected airplanes since 

December 2011. The parts will be received before each scheduled airplane as shown in the tables. 

The special too.ls and the. consumable materials have been ordered too and they will be available 

before each airplane modification. · · ··· · · 

The parts for the remaining fifty percent will be ordered during this year, however if the one. year 

exemption is granted, the parts would be ordered during' 2014 due to the modification kits indude 

life limited parts and the lead time is about one year. 

As part of the plans and arrangements to retrofit the aircraft, Aeromexico's personnel performed or 

will perform the following: 

• Prepared the incorporation calendar of this modification, as indicated above. 

• Placed the purchase orders for the kits, consumable materials and special tools, as 

indicated above. · · · 

• Issued tWo Eng.ineering Orders for the installation on the B-737 aircraft, and one Engineering 

Order for the B"'777 aircraft is being issued, in accordance with the aforementioned Boeing 

Service Bulletins. 

• Visited .. an MRO that is performing the modification to obtain knowledge, expertise and best 

practices for this installation. 

• Will prepare and classify all the material, in order to facilitate its use during the NGS's 

installation. 
••• AERO MEXICO. ~~ 

June 24th, 2013 

REF.: MEXLH-312/13 

The summary that can . b~ published in the Fed~ral Register regarding Aeromexico exemption 

request, is the following "A.eron'iexic:o ~s seeking for'Cme exemption to comply with the 14 CFR 

Part 129.117, paragraph (e){1), due to BOEING had an eight months defay for releasing the 

OEM modifications instructions, Aeromexico·s· maintenance workload increased, fleet 

changes,· high aircraft downtime for this modification. and relocation of Aeromexico's MRO. 

The exemption Aeromexico is requesting is an additional year for the ~0% requirement due 

by December 26, 2014". · · · · · · · · · 

Please find enclosed herewith a Compact Disc (CD) which contains the following data: 

The Boeing Service Bulletins numbers 737-47-1002R1 and 737-47-1003R1 for the B-737 

aircraft. 

The Boeing Service Bulletin number 777-47-0002R2 for the B-777 aircraft. 

Copies of Aeromexico Engineering Orders numbers 3747001 R2 and 3747002R2. 

~. · Copies of Aeromexico purchase orders for modification kits and tools. 

lf.you require additional information regarding this application, .please do. not hesitate to contact me 

at t~E! following: · · · · · · 

Alberto Castro.Luna 

Aerovfas de Mexico; S.A. de C.V. 

Av. Fuerza Aerea Mexicana No. 416 

. Col. Federal, C.P. 15700, Mexico, D. F. 

Phone numbe((5255) 9132-6330 

E-mail address acastro@aeromexico.com.mx 

Sincerely, 

. . . ' . 

A.lb~rto Castro Luna . 

Director, Maintenance Programs Engineering 

Enclosures. 

cc RAYMOND HABROCK 

Principal Maintenance Inspector 

VICTOR WICKLUND 

Transport Airplane Directorate, ANM-112 

. STEVEN W. DOUGLAS 

Flight Standards, AFS-300 

JOHN BARBAGALLO 

Flight Standards, AFS-50 

flY~ 

.. '·. 

FAA 

FAA 

FAA 

FAA