Boeing has submitted nearly two-thirds of the type- and production-certificate “deliverables” for the 787 Dreamliner to the FAA, program vice president and chief project engineer Mike Delaney told reporters gathered this past Wednesday in Everett, Wash., where eight of the largely composite airframes stand in various stages of completion. The company hopes to fly the first 787 prototype, powered by Rolls-Royce Trent 1000 turbofans, before the start of the Paris Air Show in mid-June, but the flying program accounts for only about 10 percent of all the documentation that must go to the authorities before they deem the airplane ready for revenue service, said Delaney. “We have a number of projects going on, so we’ve tried to work with the FAA as best as we can and they came to lay out a schedule, and that way they can plan their resources and we can plan our resources,” he said. “The FAA has told us that as a template about 30 days is their standard flow to approve something and sometimes they do it faster, sometimes slower, depending on whether they have questions or comments…[it depends on] if it’s a simple submittal or a very complex submittal, but by and large they’re pretty good….They quite honestly do a great job of supporting us if we put together a good plan for them.”

Delaney said Boeing has negotiated with the FAA 3,900 separate items it must present, 60 percent of which it has submitted for compliance. Of those, “a fairly significant number” have already gained FAA approval, he added. He also said Boeing has negotiated two rule exemptions and might need a third to waive an FAA amendment related to emergency lighting around exterior egress. All told, the program has also generated 152 so-called issue papers and 16 special conditions, including one that has drawn special scrutiny from the National Air Traffic Controllers Association (NATCA).

The union, which represents some the FAA engineers assigned to the 787 program, argues that an FAA policy issued in a December 11 memorandum titled “Policy on Issuance of Special Conditions and Exemptions Related to Lightning Protection of Fuel Tank Structure” unduly relaxes SFAR 88, standards set in response to the 1996 crash of TWA Flight 800.

The FAA’s policy memo concedes that that it can’t expect manufacturers to meet the requirements that call for “three, highly reliable and redundant protective features to prevent ignition sources” in certain design areas of the fuel tank structure.

Delaney noted that he served as Boeing’s program manager for SFAR 88 incorporation “eight or nine years ago” and “actually built the first [fuel tank] inerting systems that went on the Boeing airplane.” He, therefore, has expressed a keen personal interest in the subject.

“We have worked our way through with the FAA in very great detail, every detail in that airplane, down to every fastener, every bracket, every system, every spacing, every material, and we’ve probably had more testing on that piece or that regulation than on any other part of the airplane,” he stressed. “I am confident that we have done everything we can to understand, engineer and comply with that rule. Now there were some things in that rule that both the FAA and we had to work around, because it was an area where quite honestly the FAA got prescriptive in terms of design as opposed to writing requirements and we had to work our way through that.

“My personal wish is these test airplanes get struck [by lightning] a lot, because...to go through this at an engineering discussion is literally at the PhD level, and you never win those arguments. But I’ve been through it, and I’m confident, and I know the people at the FAA have worked really hard and they have not compromised a bit.”