r{)-BDEIND 

DEC 1 1 2012 

RA-12-05201 

John A. Hamilton 

Lead Administrator 

Regulatory Administration 

Commercial Airplanes 

The Boeing Company 

PO. Box 3707 MC 03-56 

Seattle, WA 98124·2207 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Subject: 

Model: 

RA Project No.: 

Reference(s): 

Special Instruction: 

This letter submits: 

Petition for Amendment to Exemption No. 10235, 

which permits temporary relief from 14 CFR 

25.809(a), Amendment 25-116 

787-8 

N/A 

FAA Exemption No.1 0235, Issued on April 8, 2011 . 

This letter supersedes previously submitted letter, RA-12-

05000, dated November 28, 2012, to remove proprietary 

reference wording. Enclosure remains unchanged. 

(X) Request for Amendment to Existing Exemption No.l0235 

The Boeing Company respectfully submits the enclosed petition to amend existing Exemption 

No.10235, issued on AprilS, 2011. 

The enclosed request for amendment to Exemption No.l0235 is submitted for review and 

acceptance. 

Timely cooperation with this matter is greatly appreciated. 
rti-.BOEIND 

Docket Operations 

RA-12-05201 

Page2 

Please contact this office or the following individuals if you have further questions: 

Project Administrator (PA): Andy Wright at (425) 717-2336 

Prospective Project Administrator (PP A): Nick Smith at ( 425) 266-5484 

BCA Regulatory Administration 787 Program Manager: Tim Dowling at (425) 717- 8574 

The information being forwarded to the FAA by or with this correspondence is for the exclusive 

purpose of support of applications for or amendments to Type Certificates. 

The data provided should be returned to Boeing immediately following use by the FAA, 

includi!J.g any copies thereof which the FAA may be required to make in the course of its review. 

Boeing does not authorize the FAA to retain any portion of the materials being supplied. 

Sincerely, 

uJc wr Douglas M. Lane 

ODA Deputy Lead Administrator 

(425) 237-1383, MC 03-56 

FAX: ( 425) 294-9340 

Enclosure: Petition for Amendment to Exemption No. 10235, which permits 

temporary relief from 14 CFR 25.809(a), Amendment 25-116 

cc: 

Name 

D. Tsuji 

K. Schroer 

Sharepoint 

Yes 

Yes 

Comments 

BASOO Program Manager 6Y -01 

BASOO Program Manager 6Y-01 
 

Petition for Amendment to Exemption No. 10235, which permits temporary 

relief from 14 CFR 25.809(a), Amendment 25-116 

Name and Address of the Petitioner 

Doug Lane, Director, Regulatory Administration Deputy Lead Administrator 

The Boeing Company 

PO Box 3707 

Seattle, Washington, 98124 

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

Exemption No. 10235, The FAA’s Decision section, Limitation 2 

This exemption does not apply to any airplanes delivered after December 31, 2013. 

The Extent of Amendment Sought and Reason(s) 

Regulation Allows / Requires: Amendment is Necessary because: 

Exemption No. 

10235 

Allows partial relief 

from §25.809(a) for a 

limited number of 

787-8 airplanes 

(those delivered on or 

before December 31, 

2013). 

Due to 787 airplane manufacturing difficulties and resulting 

revised airplane delivery schedules, not all 787-8 airplanes 

originally targeted for relief under Exemption No. 10235 can be 

delivered prior to December 31, 2013. However, this requested 

amendment still results in fewer airplanes being covered by 

the exemption than was originally envisioned when the 

exemption was granted.

Design and manufacture of 787-8 airplanes started prior to the 

787-8 certification basis being updated to add §25.809(a) at 

Amendment 25-116. Subsequently, the FAA granted Exemption 

No. 10235, 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-sequence a fully-compliant exterior lighting 

system. This new lighting system is scheduled to be 

implemented as part of a blockpoint change on an airplane that 

will be certified and delivered prior to December 31, 2013. All 

787-8 airplanes manufactured after that point will include the 

fully compliant exterior emergency lighting system. 

Due to unforeseen manufacturing challenges with some early 

787-8 airplanes, the delivery dates of a number of these airplanes 

will extend beyond December 31, 2013. These early production 

airplanes were specifically intended to be covered by the relief 

permitted by Exemption No. 10235. It would create a significant 

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 787-8 airplanes 

manufactured prior to the blockpoint incorporation point and not 

based on the individual airplane delivery dates. 

Enclosure to RA-12-05201 

Page 1 of 4
 

Description of Issue 

As discussed in Exemption No. 10235, §25.809(a) at Amendment 25-116 was a very late 

addition to the certification basis of the Model 787-8. Since that addition occurred well after 

the 787-8 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-compliant exterior lighting system. The exemption grants relief for all 787-8 

airplanes delivered on or before December 31, 2013. 

Boeing is currently in the process of certifying the new exterior lighting system that will be 

incorporated as part of a 787-8 blockpoint change on airplane manufacturing line number 

127. As a result, this new exterior lighting system will be certified and delivered prior 

December 31, 2013. This “and-on” incorporation of a fully compliant exterior lighting 

system meets the intent of Exemption No. 10235 since the blockpoint airplane will be fullycompliant with §25.809(a) at Amendment 25-116, and it will be certified and delivered to the 

airline customer prior to December 31, 2013. Therefore, only those 787-8 airplanes built 

prior to line number 127 need relief from the “all lighting conditions” requirement in 

§25.809(a). As identified in Exemption No. 10235, all 787-9 airplanes will be fully 

compliant with §25.809(a) at Amendment 25-116. 

Due to unforeseen manufacturing challenges with ramping up the 787 production line, and its 

complex build and change incorporation processes, the completion of some of the early 

production 787-8 airplanes have been put on hold. While the majority of these airplanes will 

be completed and delivered prior to December 31, 2013, there are some that will have their 

deliveries delayed until 2014 or later. As discussed in Exemption No. 10235, the 787’s 

complex system architecture and structural materials make it very challenging to incorporate 

a new integrated exterior lighting system into already built airframes. The FAA recognized 

these challenges 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 early production 787-8 airplanes 

would occur after December 31, 2013, the rationale and justification for continued relief for 

these airplanes is the same as that provided in Exemption No. 10235. That is, it would create 

a significant and unwarranted burden, and would lead to further delivery delays if the early 

production airplanes that will be delivered after December 31. 2013 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 

“all lighting conditions” requirement for non-compliant 787-8 airplanes based on the 

blockpoint incorporation point instead of being based on their individual delivery dates. Per 

the current production schedule, amending the original grant as is being requested herein will 

actually result in fewer airplanes entering service without the fully-compliant emergency 

lighting system than was originally envisioned when Exemption No. 10235 was granted. 

Statement of Public Interest 

The Model 787-8 fully complies with §25.809 (a), 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 787-8 airplanes that were designed and built 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 of exemption No. 10235. Conversely, if 

Enclosure to RA-12-05201 

Page 2 of 4
 

this requested relief is not granted, it would certainly lead to further delays in the deliveries 

of these early production 787-8 airplanes due to the need for modifications associated with 

incorporating the new external lighting system. Since the 787-8 provides many industryleading operating economics, environmental improvements and safety improvements relative 

to previously certificated airplanes, it would be in the public’s interest to allow the previously 

built 787-8 airplanes to enter service without further delivery delays. Also, given that the 

many 787 customers are overseas, further delivery delays of the 787-8 are not in the interest 

of the public due to the potential negative impact to export sales and the balance of trade. 

Statement 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 applicability of the grant be revised to correspond to the 

blockpoint change package that includes the new 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. 10235. As part of 

a blockpoint (“and-on”) change, a fully compliant exterior lighting system will be 

implemented, certified and delivered on a 787-8 airplane prior to the end of 2013, thus 

meeting the spirit of Exemption No. 10235. However, due to unforeseen circumstances, the 

delivery of some of the very early production airplanes (without the exterior lighting system) 

will be delayed to 2014 or later. The rationale for relief for these early production airplanes 

remains unchanged from that discussed in Exemption No. 10235. This petition for 

amendment simply requests that relief be allowed for airplanes manufactured prior to the 

blockpoint change incorporation airplane, regardless of their actual delivery dates. 

Privileges of the Exemption Outside the United States 

The privileges of Exemption No. 10235 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 a blockpoint change on airplane manufacturing line number 

127. This airplane will be certified and delivered prior to December 31, 2013. All 787-8 

airplanes manufactured after line number 127 will be equipped with the fully compliant 

exterior lighting system. It is requested that the relief from the “all lighting conditions” 

aspect of §25.809(a) apply to all 787-8 airplanes manufactured prior to the blockpoint 

airplane. Boeing’s request herein is consistent with the original intent to incorporate an “and 

on” production change prior to the end of 2013. However, due to unforeseen circumstances 

with some of the early production airplanes, some airplane delivery dates are being delayed 

far longer than previously planned. Therefore, for the reasons discussed above and in 

Exemption No. 10235, Boeing requests that the FAA amend Exemption No. 10235 to allow 

relief for all 787-8 airplanes manufactured prior to line number 127, regardless of the actual 

airplane delivery date. As described above, granting this petition is in the public’s interest 

and it will not adversely affect safety. 

Enclosure to RA-12-05201 

Page 3 of 4
 

Summary to be published in the Federal Register 

PETITIONER: Boeing Commercial Airplanes 

SECTION OF 14 CFR AFFECTED: 14 CFR 25.809(a) at Amendment 25-116 

DESCRIPTION OF RELIEF SOUGHT: It is requested that exemption No. 10235 be 

amended to clarify that relief from the “all lighting conditions” requirement applies to 787-8 

airplanes built prior to a blockpoint (“and-on”) incorporation of a fully compliant exterior 

lighting system. The blockpoint airplane will be certified and delivered prior to the 

exemption expiration date specified in the existing exemption. 

Enclosure to RA-12-05201 

Page 4 of 4