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Attachment 1.Pdf Enclosure to RA-16-01068 Petition for Exemption from 14 CFR 25.810(c) Amendments 25-72, 88 and 114, as Applicable of Title 14, Code of Federal Regulations Petition for Exemption from 14 CFR 25.810(c) Amendments 25-72, 88 and 114, as Applicable, for Certain Model 737 Series Airplanes Name and Address of the Petitioner Douglas M. Lane, Director, Commercial Airplanes The Boeing Company PO Box 3707, M/S 03-52 Seattle, Washington 98124-2207 Section(s) of the Regulations from which Relief is Sought: 14 CFR 25.810(c) Amendment 25-72, 88 and 114, as applicable §25.810 Emergency egress assist means and escape routes. (c) An escape route must be established from each overwing emergency exit, and (except for flap surfaces suitable as slides) covered with a slip resistant surface. Except where a means for channeling the flow of evacuees is provided— (1) The escape route from each Type A or Type B passenger emergency exit, or any common escape route from two Type III passenger emergency exits, must be at least 42 inches wide; that from any other passenger emergency exit must be at least 24 inches wide; and (2) The escape route surface must have a reflectance of at least 80 percent, and must be defined by markings with a surface-to-marking contrast ratio of at least 5:1. The Extent of Relief Sought and Reason(s): Regulation Requires: Relief is Necessary because: §25.810(c) An escape route must Certain Boeing Model 737 series airplanes Amendment 25- be established from are delivered without an interior installed and 72, 88 and 114, each overwing certified for zero (0) occupancy in the main as applicable emergency exit, and cabin. These airplanes later undergo interior … covered with a slip modification and exterior painting at resistant surface. completion centers. Direct compliance to §25.810(c) would require that these airplanes have the slip resistant escape path markings on the wing associated with the Type III Overwing Emergency Exits (OWE)s. Often times, the slip resistant coating, which requires the airplane spend a full day in a paint hangar, is 1 of 4 Enclosure to RA-16-01068 Petition for Exemption from 14 CFR 25.810(c) Amendments 25-72, 88 and 114, as Applicable of Title 14, Code of Federal Regulations subsequently removed when the post- delivery interior modification eliminates the OWEs. The 737 sized paint hangars are a limited resource. Exempting certain airplanes from the requirements of §25.810(c) would free up time in the paint hangars that could otherwise be used to expedite completion of 737 series airplanes certified for passenger carriage and intended for delivery to commercial airlines. Description of Issue The Boeing Company seeks exemption from 14 CFR 25.810(c), which requires the application of a slip resistant escape route marking leading from overwing emergency exits for certain Model 737 series airplanes that are certified for zero (0) occupancy in the main cabin and delivered to completion centers for interior modification and exterior painting. These “green” airplanes are delivered from the factory without the normal main cabin features (e.g., no seats, carpeting, floor proximity markings/lighting, stowage bins, galleys, and very limited linings (sidewall and ceiling) and only 1 lavatory. As a result, the flight deck is the only location on the airplane certified for occupancy during taxi, takeoff and landing. The 737 flight deck compartment is certified to accommodate a maximum of four (4) occupants. Therefore, the airplanes covered by this proposed exemption, will never have more than four (4) occupants. For properly configured airplanes, SFAR 109 provides relief from the 60 feet exit spacing requirements in §25.807(d)(7) at Amdt 25-72, provided the airplane is not operated for hire or common carriage and does not carry more than 60 passengers. This relief allows the overwing exits to be deactivated and concealed. Additionally, the FAA has issued the exemptions 6820A and 7609 to the 737-700 and 737-800, respectively, granting this relief as well. If the completion center STC modification does not include the overwing exits, there is no need for the application of a slip resistant escape route markings on the wing of the airplane, as required by §25.810(c). If the completion center modification does include overwing exit(s), the appropriate slip resistant markings will be applied and certified as part of the STC. It is proposed that this exemption be applied to Model 737 series airplanes. Statement of Public Interest Granting relief to forego painting the slip-resistant overwing escape route markings on the unfinished 737 airplanes that are delivered to a completion center for the interior modification and exterior painting prior to the subsequent delivery to the customer is in the public’s interest. The relief would lessen the environmental impact associated with painting the slip resistant markings to support the initial delivery of the airplane from Boeing, only to 2 of 4 Enclosure to RA-16-01068 Petition for Exemption from 14 CFR 25.810(c) Amendments 25-72, 88 and 114, as Applicable of Title 14, Code of Federal Regulations have the slip resistant markings chemically stripped and the wing repainted by the completion center when the overwing exits are deactivated by the completion center modification. Granting the relief is also in the public’s interest because it will lessen the environmental impacts associated with jet engine emissions on flights that can be otherwise avoided. Paint hangers large enough to accommodate airplanes like a 737 are very limited in their quantity and locations. At current airplane production rates, the paint hangers in the Puget Sound area are being utilized at their maximum capacity. Granting relief to forego painting the overwing markings will help free up local paint hanger resources. As a result, it will reduce the number of airplanes that are required to fly to remote paint hanger locations like Portland, OR, and Spokane, WA, which will reduce the associated jet engine emissions into the environment. Statement of No Adverse Effect on Safety: No adverse effect on safety would result from the granting of this exemption because the airplane’s main cabin will be certified for zero (0) occupancy when they are delivered from Boeing to the completion centers. As a result, only the flight deck compartment, which is certified for a maximum of four (4) occupants, will be occupied. In the unlikely event that an emergency evacuation is needed during a delivery flight, the 737 models are equipped with four (4) emergency exits in or near the flight deck compartment that provide the means to safely and rapidly evacuate the airplane. These include the left and right Number 2 window exits and the Forward left and right door exits that are positioned just aft of the flight deck. The overwing exits are not required for an airplane certified for zero (0) passenger occupancy and they are not needed for rapid evacuation from the flight deck compartment. Until the interior modifications are completed and certified, airplanes covered by this proposed exemption would need to be operated in accordance with a Special Flight Permit (SFP) issued by the FAA. To ensure an acceptable level of safety, the SFP application will include the following limitations: - There will be a maximum of four (4) crew members on board - All persons onboard will be necessary for the flight - All crew members will be seated in the flight deck - No additional persons will be carried - No persons will occupy the Flight Attendant seats during Taxi, Takeoff and Landing - The crew members will be trained in airplane evacuation and briefed on the status and location of all available emergency exits, including the lack of escape path markings on the wing SFAR 109 and Exemptions 6820A and 7609 allow overwing exits to be deactivated on airplanes with a low passenger count and when not used in common carriage. The airplanes for which the proposed exemption would apply will never be flown in common carriage or with any passengers occupying the main cabin. 3 of 4 Enclosure to RA-16-01068 Petition for Exemption from 14 CFR 25.810(c) Amendments 25-72, 88 and 114, as Applicable of Title 14, Code of Federal Regulations As noted above, the airplanes for which this exemption is sought do not have any floor path lighting leading to the overwing exits. This further decreases the likelihood of the overwing exits being used during an evacuation. Request to ‘Waive Publication and Comment’: Not requested. Privileges of the 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 extension of privileges is necessary to conduct flight operations to completion centers outside of the United States. Conclusion: The Boeing Company requests an exemption from 14 CFR 25.810(c), Amendment 25-72, 88 and 114, as applicable, to provide relief from having to paint slip resistant escape route markings on the wings adjacent to the Type III overwing emergency exits for certain new production Boeing Model 737 series airplanes that will be delivered to completion centers for interior modification and exterior painting. This request is justified based on the rationale provided in this petition. Namely, that the maximum number of occupants on a delivery flight will be restricted to a maximum of four (4) crew members seated in the flight deck. These crew members will have access to a sufficient number of prominent and accessible emergency exits so as to significantly decrease the likelihood of an overwing exit being used for evacuation. Summary to be Published in the Federal Register: PETITIONER: Boeing Commercial Airplanes SECTION OF 14 CFR AFFECTED: 14 CFR 25.810(c) Amendment 25-72, 88 and 114, as applicable DESCRIPTION OF RELIEF SOUGHT: The Boeing Company has requested an exemption from 14 CFR 25.810(c), Amendment 25-72, 88 and 114, as applicable, for certain new production Model 737 series airplanes that will be delivered to completion centers for interior modification and exterior painting.
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