Aviation Safety Seattle ACO Branch

Aircraft Certification Service 2200 S. 216th Street

Compliance & Airworthiness Division Des Moines, WA 98198

August 13, 2021

In Reply
Refer To: 785-21-11462

Mr. Amin A. Safee

Manager, Regulatory Administration & Certification
Boeing Commercial Airplanes
SoCal Design Center
4000 N Lakewood Blvd., MC D800-0075
Long Beach, CA 90808

Dear Mr. Safee:

Subject: Federal Aviation Administration (FAA) Approval of an Alternative Method

of Compliance (AMOC) to Airworthiness Directive (AD) 2021-16-15

Reference: (1) Boeing global AMOC request letter, dated August 9, 2021
(2) Boeing 737 MAX Master Minimum Equipment List (MMEL)
(B-737-8/-8200/-9), Revision 3, April 12, 2021: Sequence No.
21-51-01-01A (One Pack Inoperative)
(3) 737 MAX Dispatch Deviation Guide (DDG) for FAA B-737-8/-8200/-9
MMEL, Revision 3, April 30, 2021: Sequence No. 21-51-01-01A (One
Pack Inoperative)
(4) Boeing 737 NG MMEL Boeing 737 MMEL (B-737-100/200/300/400/500
/600/700/800/900/900ER), Revision 61, July 8, 2020: Sequence No. 21-
01-01-01 or 21-01-01-03 (One Pack Inoperative)
(5) 737 Classic and NG DDG for FAA B-737-100/200/300/400/500/600/700
/800/900/900ER MMEL, Revision 57, July 15, 2020: Sequence No. 21-
01-01-01 or 21-01-01-03 (One Pack Inoperative)
(6) 737 MAX Cargo Compartment Fire Protection System Certification
Document, Revision AA, July 15, 2021
(7) Cargo Compartment Fire Protection System Certification Data for 727
and 737 Aircraft, Revision AC, October 12, 2017

The FAA received the referenced letter requesting approval for an AMOC to paragraph (g)
of AD 2021-16-15. AD 2021-16-15 requires that no person may dispatch or release an
airplane with cargo in the aft cargo compartment with failed electronic flow control of air
conditioning packs, unless the aft cargo compartment remains empty, or is verified by the
operator to contain only non-combustible and/or non-flammable empty cargo handling
equipment, ballast, and/or fly-away kits. The FAA issued AD 2021-16-15 to address failed
electronic flow control of air conditioning packs, which can result in an uncontained aft
785-21-11462 2

cargo compartment fire due to insufficient cargo fire suppression capability. Failed
electronic flow control of air conditioning packs would significantly increase the air
conditioning pack airflow, which results in increased cargo compartment air leakage that
degrades the fire suppression performance.

Your letter requests dispatch or release of an airplane with an inoperative air conditioning
pack that has failed electronic flow control and the other air conditioning pack operating in
electronic flow control using reference (2), (3), (4), and (5) dispatch items as an AMOC to
paragraph (g) of AD 2021-16-15 for prohibiting dispatch or release of an airplane with cargo
in the aft cargo compartment with failed electronic flow control of air conditioning packs.
Your proposed AMOC would allow dispatch or release of an airplane with cargo in the aft
cargo compartment.

Your proposal provides an acceptable level of safety since an inoperative air conditioning
pack with failed electronic flow control will result in no airflow through the respective air
conditioning pack, which addresses the concern of degraded aft cargo compartment fire
suppression performance due to increased cargo compartment air leakage. Your proposal
also provides compliance data in reference (6) and (7) for dispatching or releasing an
airplane with a single air conditioning pack operating in electronic flow control will:

a) meet the required Halon fire suppressant concentration, and

b) hazardous quantities of smoke or Halon fire suppressant will not migrate to occupied
areas.

The manager of the Seattle ACO Branch reviewed and approves the dispatch or release of an
airplane with an inoperative air conditioning pack that has failed electronic flow control and
the other air conditioning pack operating in electronic flow control using reference (2), (3),
(4), and (5) dispatch items as an AMOC to no dispatch or release of an airplane with cargo
in the aft cargo compartment with failed electronic flow control of air conditioning packs
required by paragraph (g) of AD 2021-16-15.

In accordance with FAA Order 8110.103B, the following conditions apply:

1. All provisions of AD 2021-16-15 that are not specifically referenced above remain
fully applicable and must be complied with accordingly.

2. This FAA AMOC is transferable with the aircraft to another owner/operator.

3. Before using this AMOC, notify your appropriate principal inspector, or lacking a
principal inspector, the manager of the local Flight Standards District
Office/Certificate Holding District Office.

4. The preceding paragraph also applies to any applicable foreign-registered aircraft

upon transfer of the aircraft to the U.S. registry if compliance with the AMOC has
not been accomplished.
785-21-11462 3

5. This AMOC only applies to the FAA AD listed above. The FAA does not have the
authority to approve this as an AMOC to any AD issued by another civil aviation
authority (CAA). Approval of an AMOC to another CAA’s AD must come from that
CAA.

If you have any questions regarding this correspondence, please contact Mr. Sam
Nalbandian, Aerospace Engineer, by telephone at (206) 231-3993, or by email at
samuel.k.nalbandian@faa.gov.

Sincerely,
Digitally signed by
ROBERT E ROBERT E KAUFMAN
Original Signed by
KAUFMAN Date: 2021.08.13
10:57:30 -07'00'
for
Paul Bernado
Acting Manager, Seattle ACO Branch, AIR-780
Compliance & Airworthiness Division
Aircraft Certification Service