# i•"AEROMEXICO.

# f~ June.241 h, 2013 REF.: MEXLH-312/13 U.S. DepartmentofTransportation Docket Operations 1200 NewJerseyAvenue. S.E. West Building, GroundFloor RM W12-140, Washington D.C. 20590 ATT'N: TOWHOM 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 laterthan December 26, 2017. Tocomply 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 ofthe Nitrogen Generation System'', dated April24, 2012 and**777~47-0002R2** "Nitrogen Generation System-Installation", dated November21, 2012. · · As supportfortheexemption application we provide the

## followin~ information: The development ofthe·oEM modification instructions, aswell 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 December261 h, 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 togetherwith 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 relevantincrease, mainly relatedto additional activities added

## toour 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 willbe relocating from Guadalajara,· Mexico, to au·eretaro, Mexico, ·during this year, which will impact: our maintenance capacity,

. increasing the complexity of modifying 50% ofouraffected fleet before the deadline (26 Dec2014). 

## the requested one year extension ofthe 50%dea'dliilewould help to distribute-theworkload without affecting the 100 % deadline, arid would also alleviatethe impactto ouroperations and allowforthe perfprmance of all of the modification's in house, as opposed to· outsourced, which in our case would significantly increasethe cost. ' '

.

# iiAEROMEXICO.

# fiJ

. th 

### June24 ,2013. REF.:**MEXLH~312/13**

.· . .· ' . . ' . . 

### itisour 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 ofthe 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 largerfleets and can manage multiple airplanes on groundwithout major impactto their operation. In addition, the Mexican economy is projecting important growth for this and the following years, and therefore additional availability ofairplanes will be required to coverthe 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. MoreoverAerotnexico 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 ofthe 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 ofthis exemption outside the United States because it is ·a Foreign Operatorof U.S. Registered Aircraft. ·
Additional information
The following tables show the Aeromexico schedule for the NGS installation, considering the one year exemption. 

## Boeing777 

# 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

# liAEROMEXICO.

# f~ June 241 h, 2013 REF.: MEXLH-312/13 do nothave airplanes manufa;ctured before2011 thathave 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 of2015 will be 61% instead ofthe.proposed 52% from the tables. Aeromexico has already ordered the required parts forfifty percent ofthe affected airplanes since December2011. 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 beforeeach 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 ofthe plans and arrangements to retrofit the aircraft, Aeromexico's personnel performed or will perform the following:

• Prepared the incorporation calendarofthis modification,as indicated above.

• Placed the purchase orders for the kits, consumable materials and special tools, as indicated above. · · ·
• Issued tWo Eng.ineering Ordersfor the installation on the B-737 aircraft, and one Engineering Order for the B"'777 aircraft isbeing issued, in accordance with the aforementioned Boeing Service Bulletins.

• Visited

..an MRO that is performing the modification to obtain knowledge, expertise and best practices forthis installation.

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

# •••AEROMEXICO.

# ~~ 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 complywith 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.andrelocation ofAeromexico's MRO. The exemption Aeromexico is requesting is an additionalyearfor the**~0%** requirement due byDecember

### 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 forthe B-777 aircraft. Copies ofAeromexico Engineering Orders numbers 3747001 R2 and 3747002R2.**~.** · Copies ofAeromexico purchase orders for modification kits and tools. lf.you require additional information regarding thisapplication, .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 TransportAirplane Directorate, ANM-112

. STEVEN W. DOUGLAS

Flight Standards, AFS-300 JOHN BARBAGALLO Flight Standards, AFS-50

# flY~

.. '·. FAA FAA FAA FAA