Beruflich Dokumente
Kultur Dokumente
Page 1 of 5
Federal Aviation Administration
U.S. Department of Transportation
Docket Management System
1200 New Jersey Avenue, SE
West Building Ground Floor Room W12‐140
Washington, DC 20590
Subject: Petition for Exemption from 14 CFR 91.527(a) at Amendment. 91‐310
Name and Address of the Petitioner:
Tom Galantowicz, Director, Regulatory Administration
The Boeing Company
PO Box 3707
Seattle, Washington, 98124
Reference: 14 CFR 91.527(a) – Operation in Icing Conditions
In accordance with the provisions of Title 14, Code of Federal Regulations (14 CFR) 11.63 and
11.81, The Boeing Company petitions for a limited exemption from 14 CFR 91.527(a).
Specifically, The Boeing Company requests an exemption on the Boeing B777‐9, B777‐8 “777X”
series aircraft, certificated in any category, from the requirement that “No person may take off
an aircraft when frost, ice, or snow is adhering to the wings” where the Original Equipment
Manufacturer (OEM) has determined contamination commensurate with possible anti‐icing
fluid failure from a vertical orientation of the folding wingtips during treatment and taxi would
not adversely affect the performance or controllability of the aircraft, and has placed an
appropriate limitation in the Airplane Flight Manual (AFM), a Federal Aviation Administration
approved document. A summary of this petition as required by § 11.81 is provided in
Attachment 1.
Background
Airframe icing in general has long been known to be a hazard to safe operation of aircraft,
especially on the wing. Wing surface texture changes can disrupt airflow on the wing causing
loss of lift and increased stall speed, plus increased drag adversely affecting aircraft climb
gradient performance. Further, the weight of accumulated ice may present a weight and
balance issue unknown to the crew and that cannot be accurately estimated from visual
observation. Ice on the wing may form in a particular set of conditions that may include near‐
or sub‐freezing temperatures in combination with precipitation.
The B777X features a folding wingtip (FWT) device to facilitate operation at Code E airports.
Procedures for 777X operators allow for de/anti‐ice treatment to occur in either the extended
(horizontal) or folded (vertical) orientation, with extension occurring just prior to taking the
Enclosure to RA-18-03311
Page 2 of 5
active runway for departure. Additionally, it is recognized by industry that use of thickened
anti‐icing fluids on a vertical surface may have different characteristics than a horizontal
surface; when operating in winter precipitation, anti‐icing fluid may locally fail on vertical
surfaces within the determined Holdover Time (HOT). The result of potential fluid failure is the
possibility of contamination on an isolated portion of the FWT.
The B777X FWT is clearly demarcated outboard of the hingeline where, with certain other
limitations, isolated contamination as a result of possibly degraded anti‐icing fluid
characteristics may exist with negligible impairment of performance. Boeing has issued a new
limitation in the AFM that sets forth conditions under which takeoff is not permitted with
regards to FWT de/anti‐icing treatment (Attachment 2). If the limiting conditions are met, i.e.
full deicing and anti‐icing treatment is completed commensurate with other critical surfaces of
the aircraft, operation should be permissible. An example of such permissible operation would
be an airplane that completed anti‐icing treatment with the FWT in the folded (vertical)
position at the time of wing anti‐icing and extended to horizontal prior to taking the active
runway prior to HOT expiration for the main wing. Precipitation may collect on the FWT surface
in the limited exposure time of the main wing HOT in the event the anti‐icing fluid on the FWT
has locally failed, however, the possible contamination that could adhere has been
conservatively accounted for and Boeing’s limitation would not preclude takeoff.
Regulation § 91.527(a) does not allow for any concession, including the OEM’s safety
determination set forth in the AFM, an FAA approved document. By approving the AFM, FAA
provides the basis upon which operation with standard anti‐icing fluid holdover times with the
FWT can be permitted if this petition is granted.
The Applicable Regulations and Relief Sought
Boeing seeks an exemption from § 91.527(a) to permit operation within the holdover times of
the other critical surfaces of the aircraft without specific consideration of the FWT condition.
The exemption would be limited by the AFM – Miscellaneous Limitations notation that defines
conditions under which takeoff without appropriate de/anti‐icing treatment of the FWT is not
permitted.
Reasons for seeking the relief at this time include:
1) FAA has approved Boeing’s conservative determination through aerodynamic analysis that
isolated contamination on the FWT due to possible thickened anti‐icing fluid failure in the
folded position would not adversely affect the performance or controllability of the aircraft.
2) Boeing’s 777X series aircraft additionally features Enhanced Stall Protection (ESP) intended
to enhance airplane safety by preventing the airplane from significantly exceeding useful angles
of attack.
3) The AFM limitation assures that operations are only permitted with consistent de/anti‐icing
fluid treatment between the FWT and the main wing.
Enclosure to RA-18-03311
Page 3 of 5
Granting the Exemption Would Not Adversely Affect Safety
Safety will not be adversely impacted if the FAA grants this petition because FAA will have
concluded, by approving the AFM, that the conditions under which operation with isolated
contamination on the FWT is permitted on B777X by the AFM are sufficiently conservative and
tested by Boeing to be safe for takeoff.
Request to Publish and Expedite Public Comment
Boeing requests that the FAA publish and expedite the public comment period required of this
petition for exemption. Delay to this petition will delay the start of flight testing of the 777‐9
and delay of ATC. Such a delay would adversely affect Boeing and our customers. Boeing
believes this request is justified by the similarity to the previously approved exemption for
737NG dispatch with Cold Soak Fuel Frost adhering to the upper wing (Docket No. FAA‐2015‐
0555). As such, Boeing believes good cause exists for the FAA to consider expediting the public
comment requirements of §§ 11.85, 11.87, and 11.89.
Conclusion
For the foregoing reasons, we respectfully request an Exemption from the requirements of
§ 91.527(a) for the FWT limited by Boeing’s AFM conditions.
Attachments (2)
1. Summary of this petition
2. Excerpt from Draft of Boeing B777X Airplane Flight Manual
Enclosure to RA-18-03311
Page 4 of 5
Attachment 1
SUMMARY OF THE BOEING COMPANY PETITION
Petitioner: The Boeing Company
Regulation Affected: 14 CFR 91.527(a)
Description of Relief Sought:
FAA is requested to provide relief from the cited rule when the OEM, Boeing allows operation
of B777‐9, B777‐8, “777X” series aircraft, certificated in any category, with de/anti‐icing fluids
with relevant holdover times of the other critical surfaces independent of the orientation of the
FWT. The conditions are prescribed in the FAA‐approved Airplane Flight Manual when
operations are not permitted.
Enclosure to RA-18-03311
Page 5 of 5
Attachment 2
Excerpt from Draft of Boeing B777X Airplane Flight Manual
Takeoff with frost, ice, or snow adhering to leading edge devices, all control surfaces, and wing
surfaces is prohibited with the following exceptions:
Takeoff with frozen contaminants on the folding wingtip surfaces outboard of the
hingeline, after being de/anti‐iced in the vertical position and subsequently lowered
into the horizontal position, is allowed.
Takeoff with light coatings of frost, up to 1/8 inch (3mm) in thickness, on lower wing
surfaces due to cold fuel is allowed.