Enclosure to BDCO-10-03041

Page 1 of 10 Petition for Exemption to 14 CFR 25.783( g) Amendment 23, 14 CFR 25.807(a)(1) Amendment 67, 14 CFR 25.809(a) Amendment 116, 14 CFR 25.813(a) Amendment 46 and Petition to Amend Exemption 9793A

A. Name and Address of the Petitioner

C.M. Thompson, Manager, Lead Project Admi nistrator, Development Projects The Boeing Company, PO Box 3707, Seattle, Washington, 98124

B. Section of the Code of Federal Re gulations (CFRs) that are affected

As provided for in 14 CFR 11.61(b), Boeing hereby petitions for exemption to the following CFRs:

Regulation At

Amendment Which Requires

14 CFR 25.783(g) 23 Each passenger entry door in the side of the fuselage must qualify as a Type A, Type I, or Type II passenger emergency exit and must meet the requirements of Secs. 25.807 through 25.813 that apply to that type of passenger emergency exit......

14 CFR 25.807(a)(1) 67 Type and location. For the purpose of this part, the Types and locations of exits are as follows: (1) Type I. This Type must have a rectangular opening of not less than 24 inches wide by 48 inches high, with corner radii not greater than one-third the width of the exit. Type I exits must be floor level exits.

14 CFR 25.809(a) 116 Each emergency exit, including eac h flight crew emergency exit,

must be a movable door or hatch in the external walls of the fuselage, allowing an unobstructed opening to the outside. In addition, each emergency exit must have means to permit viewing of

the conditions outside the exit w hen the exit is closed. ... Means must also be provided to permit viewing of the likely areas of evacuee ground contact. The likely areas of evacuee ground contact must be viewable during all lighting conditions with the landing gear extended as well as in all conditions of landing gear collapse.

14 CFR 25.813(a) 46 A passageway between individual passenger areas, and leading from each aisle to each Type I and Type II emergency exit. These passageways must be unobstructed and at least 20 inches wide.

As provided for in 14 CFR 11.61(b), Boeing hereby petitions for revision to Limitation 16 in Exemption 9793A:

Requiremen

t Limitation Which Requires

Exemption

9793A 16 For airplanes with the optional e scape slide installed at the crew door Boeing must develop instructi ons for moving the escape slide

aft to clear the projected opening of t he exit from outside the airplane. These instructions must be added to the outboard side of the escape slide assembly so that rescue personnel can read the instructions and move the escape slide out of the way. These

instructions must be demonstrated to be effective for rescue personnel.Enclosure to BDCO-10-03041

Page 2 of 10Enclosure to BDCO-10-03041

Page 3 of 10 C. The extent of relief being sought

Regulation Requires: Relief is necessary because:

14 CFR 25.783 (g)

Amendment

23 The crew door

and Door 1 LH to

be considered entry doors and

thus would need to be a Type A, I

or II exit. Main deck Door 1 LH is a Type A size door without any

evacuation assist means and thus does not meet this regulation. This is unchanged from the 747-400F design. The configuration of the upper deck crew door does not meet all Type I exit requirements in section 14 CFR 25.807 through 14 CFR 25.813 although the fuselage cu tout meets the Type I exit dimensions. Some of the requirements not met are covered in Exemption No. 9793/9793A for the 747-8F;however the Exemption 9793/9793A does not provide relief from this requirement to provide a Type A, I, or II size exit.

14 CFR 25.807(a)(1)

Amendment

67 The crew door as a Type I exit to be

a floor level exit. The crew door can no longer be considered a Type I floor level exit due to a step-up to the exit when the airplane is configured with inertia reels as the only evacuation means. A previously granted Exemption No. 9735 has acknowledged this same

condition on the 747-400F and consi dered the rating of the exit as a Type III.

14 CFR 25.809(a)

Amendment

116 The crew door as an emergency exit

to have a means

to view the evacuee ground

contact area in all

combinations of gear collapse. The provided viewing window on the crew door is not capable of viewing the evacuee ground contact area in all combinations of gear collapse for either evac uation means prior to the exit being opened. The configuration of the 747-8F airplane includes exterior body-mounted lights which will meet the requirement for lighting for both evacuation means.

A similar grant of Exempti on No. 9696 was extended for the 767-300BCF based on the exit porthole combined with inertia reel assist means, six person occupancy, and additional crew procedures which will be drawn upon for the 747-8F.

14 CFR 25.813(a)

Amendment

46 The crew door as a Type I exit to

have a 20 inch

passageway The passageway to the exit is less than 20 inches with the manually deployed slide installed in the 747-8F interior configuration. As a customer selectable option, the 747-400F manually-deployed escape slide at the crew door has been selected by a majority (5 of 6) of 747-8F airline customers as

an additional evacuation means at that location. Although the interior configuration for the 747-8F is changed from the 747- 400F, a similar condition exist on the 747-400F.

Limitation 16

from Exemption

9793A The crew door escape slide be

labeled with

instructions to move the escape

slide aft to clear the projected opening of the exit The interior configuration of the 747-8F does not allow the escape slide to be moved far enough aft to directly comply with the requirement to “clear” the projected opening. However, the design and configuration of the 747-8F does allow the slide to be moved aft to allow outside access by rescue personnel

which will be demonstrated. Thus the Limitation could instead require the crew door be shown to allow access into the airplane from the outside by rescue personnel. Limitation 16 is to address a concern in Exemption 9793A that “the escape slide is partially blocking the access to the airplane when the crew service door is opened from the outside, which may prevent rescue personnel from rapidly entering the airplane in an emergency.” This concern can be addressed without fully clearing the projected door opening.

There is no similar requirement in Exemption series 1870 for this similar configuration and condition on the 747-200F/400F airplanes which have a proven safety record.Enclosure to BDCO-10-03041

Page 4 of 10 D. Description of the Issue

The Model 747-8F is a derivative aircra ft based on the 747-400F. The fuselage of the 747-8F is 220” longer than the 747-400F . The 747-8F emergency exits, crew door window, exterior body-mounted light fo r the escape slide, and the escape

means are identical to the 747-400F with t he exception that the escape slide is a customer selectable option on the 747-8F w here as it was basic on the 747-400F. For the 747-8F, the escape slide has been selected by a majority (5 of 6) of the

airline customers as the evacuati on means at the crew door.

Like the 747-400F, the 747-8F has a required flight crew of two (2) and is allowed the carriage of up to six (6) supernumer aries. Like the 747-400F and its predecessors, the 747-8F AFM will limit the airplane to eight (8) occupants. The eight (8) inertia reel descent devices locat ed on the flight deck are identical in part number and location to the 747-400F and will be included on all 747-8F airplanes, with one for each airplane occupant to use ei ther through the crew door or from the flight deck overhead exit. Additionally, ther e are eight (8) harnesses installed basic in the 747-8F supernumerary seating areas , two (2) more than the 747-400F, one for each occupant to don and connect to their descent device before evacuating the airplane.

The optional manually-deployed escape slide is attached to a platform that moves fore and aft on rails inside of the upper deck crew door. When the escape slide is deployed through the crew door, the forward si de of the platform is stationary and remains in the interior creating the boundar y to the passageway out the exit. The escape slide system also has a flexible, non- inflatable, chute hinged to the platform to assist as a guide in slide deployment. This chute also remains in the interior creating a boundary to the passageway out t he exit. When the optional escape slide is installed the 20 inch passageway leading to the exit is not maintained from the slide platform to the interior monument, nor is the escape slide chute itself 20 inches

The current design on the 747-8F provides the capability to move the escape slide aft providing access for rescue personnel with instructions that are affixed to the outboard side of the slide pack such that they can be seen when the door is opened from the outside. The ability to gain a ccess, including the effectiveness of the instructions, will be demonstrated by rescue personnel in accordance with Exemption 9793A Limitation 16.

A new body-mounted exterior light was added to the 747-8F. This new light illuminates the ground contact area of the iner tia reels, in all combinations of gear collapse, before and after door opening. The existing exterior body-mounted light illuminates the ground contact area of the esc ape slide, in all combinations of gear collapse when the slide is usable, before and after door opening. Both exterior lights will be installed on all airplanes regardle ss of evacuation means selected by the customer. These lights are activated (1) aut omatically upon loss of main electrical power (28 VDC bus) when the system is a rmed, or (2) manually via the emergency light switches located on the flight de ck or in the supernumerary seating area.Enclosure to BDCO-10-03041

Page 5 of 10 E. Statement of No Adverse affect on Safety

The petitioner strives to provide acceptable safety conditions such that 747-8F cargo operators can safely operate their airp lane with evacuation means and procedures consistent with the current fleet. The majority (5 of 6) of the airline customers that have purchased the 747-8F also operate fl eets of earlier model 747 Freighters, including the 747-400F. The surest, safest, and most cost effective manner of operating these cargo aircraft is to have consistent airplane designs and crew/supernumerary training with respect to evacuation safety features of the airplane. A grant of Exemption will result in consistent operator’s procedures for

evacuation of the 747-8F with the 747-400F fl eet when the escape slide is installed and similar to other airplane models with only inertia reels installed, thus enhancing safety.

Granting the Exemption to 14 CFR 25.783(g) Amendment 23 for Door 1 LH and the upper deck crew door will not have an appreciable affect on safety based upon the following factors which are summarized here and discussed as necessary in more

detail below:

• Limited number of trained supernumeraries

• Specific to Door 1 LH, while it will be used for entry it will not be marked with any exit signs visible from t he upperdeck supernumerary seating area

• Specific to the crew door, while it is sized as a Type I door, it will not practically be used as an entry door due to it’s location on the upper deck approximately 26 feet above the ground.

• The crew door will be marked with exit signs visible from the upperdeck supernumerary seating area and have appropriate evacuation means

available at the exit.

Previously the FAA recognized in Exemption No. 4808 for the 757-200PF “The intent of 14 CFR 25.783(g) is to ensure that the door through which people enter an airplane is also useable as an emergency exit”. “Because of the better trained, operator-approved, small number of noncrewmem bers allowed in the flight deck, the FAA finds that the entry door provided in the Model 757-200PF can safety be used as an emergency exit and that the requirements that the entry door be a Type A, I or II is unnecessary.” Although the 747-8F has a diffe rent configuration than the 757- 200PF, the circumstances are similar in training and small number of non-crew members. The personnel (maximum of 8) aboard the 747-8F are required to be briefed by the flight crew prior to each f light on the use of the exits in accordance with Exemption No. 9793/9793A. This additional level of knowledge afforded to these occupants when compared to the normal passenger provides an enhancement in evacuation normally afforded. Door 1 LH will be used as the entry

door on the 747-8F however it will not be us ed as the emergency exit. It will be out of sight and no exit signs will lead personnel to Door 1 LH once the supernumeraries have taken their seats in the upper deck thus it is unnecessary to make it a useable emergency exit with evacuation means as ot her exits will be available, appropriately marked, and equipped with the evacuation means (same as previous 747 Freighter models).Enclosure to BDCO-10-03041

Page 6 of 10 Granting the Exemption to 25.807(a)(1 ) Amendment 67 and 14 CFR 25.813(a)

Amendment 46 for the non-floor level ex it and less than 20 inch passageway, respectively, at the upper deck crew door will not have an appreciable affect on safety based upon the following factors which are summarized here and discussed as necessary in more detail below:

o Limited number of trained super numeraries (see discussion, above)

o Consideration of the crew door rating si milar to a Type III exit with a 19 inch passageway being maintained

o a small step-up of approximately 8 inches

Per 14 CFR 25.807(c)(1) Amendment 67, a pai r of Type I exits would allow 40-79 passengers, while a pair of Type III exits would be sufficient for between 20 and 39 occupants. In combination with the f light deck overhead exit, having the 747-8F airplane configured with a Type I size cut out and nearly meeting the Type I passageway requirements, while only needing to provide evacuation capability for 8 occupants, the overall design is considered sufficiently safe.

While a 20 inch passageway is required for a Type I sized exit, the crew door can be considered, based on the number of pass engers being evacuated, similar to a Type III exit. The applicable regulations, 14 CF R 25.813(c)(1)(2) Amendment 46, do not specify a passageway requirement for Type III exits rather only that the projected opening may not be obstructed and there may be no interference in opening the exit. Considering the 747-8F crew door as sim ilar to a Type III exit, with a method of compliance associated with the projec ted opening by providing a 19 inch passageway at the crew door and no obstruction in opening the exit, is sufficiently safe for the 8 occupants. A step-up of 20 inches is allowed for a Type III exit. The 747-8F step-up when the escape slide is not installed is approximately 8 inches and there is no step up when both the inertial reels and slide are installed. The FAA recognized a similar condition in Exemption No. 9735 for the 747-400F “...have a crew service door the size of a Type I exit, but because the door has a step-up inside the airplane it is rated as a Type III exit and is available for evacuation”.

.

Granting the exemption to 14 CFR 25. 809(a) Amendment 25-116 will not adversely affect safety based upon the following factors which are summarized here and

discussed in more detail below:

• Flight deck and supernumerary windows

• Crew awareness

• Manually-deployed escape slide and inertia reels

• Exit height

• Exterior body-mounted lights

It is understood 14 CFR 25.809(a) at Amendm ent 25-116 was codified to address the potential for a crew member or s upernumerary to mistakenly open or use an emergency exit when there is an external hazard (such as a fire, water or terrain/obstacles) that is not visible (due to lack of means to view outside and/or from inadequate lighting) that could pose an imm ediate threat to the occupants of theEnclosure to BDCO-10-03041

Page 7 of 10 airplane, damage the evacuation means, pos e a threat to personnel using the evacuation means, and/or delay the evacuation.

Previous industry design practice has provided outside viewing means (windows) installed on or adjacent to the passenger emer gency exits in the majority of cases. Additionally, the large flight deck windows provide a means to view the surrounding area by the flight crew as the airpl ane is on approach. These windows have proven an effective means for quickly assessing condi tions outside the emergency exit prior to the emergency exit being opened in order to avoid delay in opening the emergency exits and initia ting the evacuation.

In addition to the flight deck windows, a window is installed in the crew door of the 747-8F. Additionally, the 747-8F includes three standard passenger sized windows (for the supernumeraries) on the right and left hand side of the airplane aft of the crew door and located in the supernumerar y compartment. One window (each side)

is located in the crew bunk area of the supernumerary compartment.

All windows provide a view of the surr ounding area with the airplane resting on all landing gear. Once the airplane has slowed to a stop, viewing of all of the likely areas of evacuee ground contact prior to the exit being opened will not be fully possible since they are directly beneath t he aircraft when inertia reels are used. However, a view of the surrounding area as the airplane comes to a stop as well as the surrounding view from the flight deck and supernumerary windows once stopped provides the ability to make assessment s and appropriate evacuation decisions as

follows:

o In most cases, the presence of a fire in the vicinity of the flight deck windows and crew door large enough to be a hazard if the exit is opened would be readily and easily recognizable by the flight crew as the airplane slows to a stop. In these cases, the flight crew would command evacuation from the appropriate exit.

o Recalling, the supernumerar ies are required to be briefed in the use of the exits, the presence of a fire or wate r in the surrounding area of the crew door large enough to be a hazard would likely be recognized by the supernumeraries from windows in the supernumerary area, in conjunction with the body-mounted lights as necessary, and could be communicated to the flight crew when determini ng which exit to utilize.

It is understood 14 CFR 25.809(a) at Amendm ent 25-116 is also to prevent the deployment of an escape slide into a hazard, since this deployment is irreversible, and door re-closure is necessarily impeded by the deployed slide due to its interface with floor structure immediately inboard of t he door sill. In the case of the 747-8F, the evacuation means is manually-deployed a fter the emergency exit is opened. If a hazard such as fire, water, or terrain is detected near the crew door, after the door is opened, the door may be easily closed again because the manually deploy passenger escape slide or inertia reels would not be in the way of the door

mechanism.Enclosure to BDCO-10-03041

Page 8 of 10 The location of the emergency exit is approx imately 13.5 feet above the water line in the unplanned ditching scenario which is worst case. The crew door is far enough above the water level after a ditching event su ch that if this emergency exit were tobe opened without first assessing outside conditions it could easily and quickly be reclosed without consequence.

Additionally the 747-8F airplane is conf igured with body-mounted lights (reference Figure 5) providing the illumination in dark of night conditions to assess the surrounding area prior to emergency exit opening. After emergency exit opening and before evacuating through the exit, maki ng an assessment of safety to evacuate can be done by viewing out the open exit utilizing the body-mounted exterior lights which will fully illuminate the ground contact area of both evacuation means before those means are deployed.

While a means that provides viewing of the evacuee ground contact area for all combinations of gear collapse does not ex ist for the crew door when equipped with inertia reels or manually-deployed escape slides, the airplane design provides an acceptable level of safety as noted above.

Similar conditions were recognized and accepted by the FAA in Exemption No. 9696

for the 767-300BCF. “We agree in this specific case with the petitioner’s rationale that in most cases the presence of a fire in the vicinity of the lefthand flight deck window and Door 1 L would be recognizable by the flight deck crew...”

. “Because the assist means is an inertia reel, the evacuee has a bit more control over the landing zone...” . Similar to the inertial reels, there is also control over the deployment of the optional escape slide for the 747-8 and rationale for no adverse affect on safety for the optional slide in relation to 14 CFR 25.809(a) is contained

herein.

Limitation 16 It is proposed that the FAA accept an adequate opening to allow access from outside the airplane at the crew door by pr oviding relief from Limitation 16 of Exemption No. 9793A which requires in part, “For airplanes with the optional escape slide installed at the crew door Boeing mu st develop instructions for moving the escape slide aft to clear the projected opening of the ex it from outside the airplane.”

Exemption 9793A noted a concern that “the escape slide is partially blocking the access to the airplane when the crew service door is opened from the outside, which may prevent rescue personnel from rapidly entering the airplane in an emergency.” An acceptable level of safety can be main tained without the specific requirement to fully clear the projected opening of the exit based on:

o providing adequate access for rescue personnel from outside the airplane

o rescue personnel procedures

o maintaining all of the other aspects of Limitation 16.

The exit maintains the physical structural cutout of a Type I exit as well as the function of being openable from the outside allo wing entry into the airplane. If the slide has not been deployed, then the rescue personnel can move the slide pack aftEnclosure to BDCO-10-03041

Page 9 of 10 by following the instructional placards added to the outboard of the slide pack, thus providing an entry way.

In the nose down adverse attitudes, the 747- 8F slide does not have a detent on the track for it to lock in the full open position. The force to move the slide is less than 30 pounds which is within the capability of rescue personnel.

Safety is maintained because the requirem ents of Limitation 16 provide an increase in safety as compared to the 747-400F by including instructions for rescue personnel in the type design (via placarding) in addition to including instructions in the rescue and fire fighting procedures.

F. Proposed Revision to Limitation 16

Request to Revise Limitation 16: Boeing hereby requests the FAA revise Limitation 16 to remove the “clear opening” requirement. Boeing proposed wording - “For airplanes with the optional escape slide installed at the crew door Boeing must develop instructions for moving the escape slide aft to provide an entryway sufficient to allow access into the airplane for the purposes of rescuing occupants from the

outside. These instructions must be added to the outboard side of the escape slide assembly so that rescue personnel can read the instructions and move the escape slide out of the way. These instructions must be demonstrated to be effective for rescue personnel.”

G. Statement of Public Interest

The public interest will be advanced by the grant of Exemption as it is in the best

economic interest of the United States. In creased sales of airplanes contribute to the balance-of-trade, the gr oss domestic product and economic health of the United States. Marketability of the 747-8F is improved, leading to increased sales, by keeping the sales price and operating cost of the 747-8F down while providing flexibility to the airlines in a choice of evacuation means.

Purchase prices could increase due to extensive design changes associated with providing fully compliant designs for both evacuation means which would be necessary to allow the operational flexibility in evacuation means. Design changes likely to be necessary include:

o New escape slide

o Revisions to provide for a floor leve l exit for operators who select only the

inertia reels

o Means to view the evacuee ground contac t area for both the inertia reel and escape slide

o Changes to the door structure and/or door mechanisms

o Interior configuration changes to allow the escape slide to be moved further aft to fully clear the projected opening of the exit

Operating costs are kept down by:Enclosure to BDCO-10-03041

Page 10 of 10 o Having common training and operating procedures with the 747 Freighter Fleet when the escape slide is installed while avoiding the cost of maintaining different material in the training, maintenance, dispatch and operations

manuals for the 747-8F and 747-400F. Every 747-400F delivered from Boeing was equipped with an escape slide installed in a similar interior configuration, a window in the crew door, and an exterior body-mounted light to illuminate the evacuee ground contact area of the escape slide. The majority (4 of 6) of the airline cust omers that have purchased the 747-8F also operate fleets of earlier model 747 Frei ghters and will have the escape slides installed on their 747-8F, same as the 747-400F.

o Common training and operating procedures to other freighter models for those airlines selecting only the i nertia reels as the evacuation means.

o Having common escape slide spares with existing 747 Freighter fleets.

o Avoiding the weight and fuel penalty and system maintenance costs including any economic penalties associated with f light delays that would otherwise be realized by the required design changes as noted above in the purchase price impacts.

o Weight and fuel benefits for operators choosing the inertia reels as the

evacuation means

Lower purchase and operating cost will help maintain cargo shipping rates aboard Freighter airplanes at their current levels , which benefit the US economy as a whole.

Grant of Exemption as requested in this petition is in the best interest of the travelling public through introduction of this new product into the marketplace that

has advanced the certification basis in m any areas as compared to the 747-400F. Enabling common operating procedures for ev acuation not only maintains purchase price and operating cost as noted above, but avoids the potential for human error which may be introduced when procedures vary for similar products. For the reasons noted above, it is the petitioner’s opi nion that the overall level of safety is improved by comparison to the previous 747 Freighter models that are certified with similar configurations and evacuation systems and safety is maintained which is in the public’s best interest.

H. Request for Waiver of Publication

The petitioner requests that this petition for exemption not be delayed by the public process, which includes publication of the s ubject petition, due to the fact that this exemption will not set a precedent. Boeing believes good cause exists to waive the publication and comment requirement s of 11.85, 11.87, and 11.89.

Relief from 14 CFR 25.783(g) has been provi ded on other freighter aircraft including 757 Exemption No. 4808. Relief from 14 CFR 25.807(a)(1) Amendment 67 and 14 CFR 25.813(a) Amendment 46 while not previously explicitly granted in previous exemptions has been implied and is related to the relief sought for 14 CFR 25.783(g). Relief from 14 CFR 25.809(a) Amendment 116 has been provided on other freighter aircraft including 767-300 BCF Exemption No. 9696. Additionally, this change is less prescriptive in its method of achieving the intended goal ofEnclosure to BDCO-10-03041

Page 11 of 10 Limitation 16 yet the full capability intended by Limitation 16 is still provided. This request to revise Limitation 16 is not unprecedented. The FAA has granted a revision to Exemption No. 9793 to allow for installation of the crew slide because a corresponding level of safety is provided. Similarly, the same level of safety is provided by the revised Limitation, in that the design allows access to the occupiable areas from outside the airplane.

The 747-8F petition is being provided in a timely manner; however, due to the scheduled delivery of the first 747-8F being near the end of the year 2010, for the first customer with the escape slide chos en option, a delay in processing of the Exemption could delay the entry into service.

I. Privileges of this Exemption Outside the United States

Per 14 CFR 11.81(h), Boeing requests that the privileges of this Exemption be

extended outside the United States. This ext ension of privileges is necessary for operations based within foreign countries having bilateral agreements with the United States accepting FAA 14 CFR Part 25 as their airworthiness standards for transport category aircraft. The 747-8F is intended for the global market place.

J. Conclusion

The 747-8F maintains the level of safety previously afforded on the 747 Freighter series from an exit rating and evacuati on systems standpoint. The 35 year service history of the 747F series has proven it s safety. Granting relief from 14 CFR 25.783(g) Amendment 23, 14 CFR 25.807( a)(1) Amendment 67 and 14 CFR 25.809(a) Amendment 116 for the 747-8F model is justified based on this exit meeting the pertinent aspects of the Type I exit and considering that it will only be used by a limited number of trained and capabl e occupants. Granting relief from 14 CFR 25.809(a) Amendment 116 for the 747-8F model is justified based on the capability of the airplane to provide safe evacuation means including illumination.

Granting the revision to Limitation 16 is justified based on providing adequate access by rescue personnel from outside the airplane and maintaining all of the other aspects of Limitation 16. If Limitati on 16 is revised the crew door will maintain an effective opening adequate for rescue personnel to enter from outside the airplane if necessary.