Sir,

Lockheed Martin would like to operate a Phantom II quad copter in order to provide an 

aerial target to develop a reliable tracking system for our ADAM/ATHENA system. The Athena 

system is being developed to Track, ID and protect against Class II and Class I UAS’s, small 

rockets, small boats and mortars. Please contact us for further clarification if needed.

1) Regarding the Unmanned aircraft

a. The DJI Phantom II will be the UAS utilized. It is a Quad Copter equipped with four rotors 

that are driven by electric motors powered by a battery, and controlled by a transportable ground 

station provided by the manufacturer DJI. The Phantom II has a max air speed of 30 knots and 

weighs less than 1300 grams. Its size is 20”x20” x 8” .Attached is the manufacturer’s operation 

and maintenance manual, which lists the flight capabilities and operational features of the 

aircraft. The system has several safety features:

1) If the signal from the transmitter/control box is lost, the Phantom automatically goes 

into a “Return to Point of Origin” mode, and returns to its initialization point and lands.

2) It also goes into the auto “Return to Point of Origin” mode if the battery reaches 15% 

level of charge left.

3) Allowable Distance from the “ Point of Origin” can be programmed to limit the 

UAS’s range.

b. The radio frequency complies with the FCC requirements, as per the manufacturer’s 

documentation that accompanies each aircraft, and is noted in the manufacturer’s operation and 

maintenance manual.
2) Regarding the operation of the UAV.

a. All operations will be on the Lockheed Martin Santa Cruz, Ca. Test Facility, a remote site 

in the Santa Cruz mountains that is approx. 4 miles n/s and 2 miles e/w. See attached Google 

map.

b. Before operations, LM Environmental Safety and Health representatives will review and 

confirm that any issued Fire warnings, weather or other safety conditions are met in order for 

flights to occur. This includes fog, high winds and low cloud ceilings. A base wide notification 

will be issued to alert all base personnel that flight operations will be conducted and that the 

flight area is a restricted access area.

c. All flights will have a Pilot in Control (PIC) and at least one Aircraft Observer/Spotter. 

They will remain within normal talking volume distance of each other and each have walkie

talkies that do not interfere with the quad copter control signals for communication with the 

tracking station. There will also be at least one base radio available at their location in the case of 

an emergency. The Aircraft Spotter is to watch for other aircraft and assist in maintaining visual 

contact on the quad copter and to stay in constant verbal contact with the PIC. The PIC will have 

a minimum of 2 hours of time on a RC copter Flight simulator before flying the UA , have 5

hours of documented flight time with the Phantom in sessions specifically for training flight , be 

an AMA member and follow the AMA Flight Safety code ( see attached AMA safety code).

d. A preflight check will be performed and noted in the Flight Log Book (see attached log 

sheet). All discrepancies must be resolved and noted as such in the Flight Log Book before the 

aircraft can be flown. 
e. All flights will be during day light hours only, and the aircraft must remain in visual sight 

at all times.

f. The UAV will not be operated near any buildings, power lines, elevated lights or groups 

of people.

g. The Phantom II has an altitude limit of 400 ft. AGL due to the manufacturer’s 

programming parameters and cannot be exceeded. Flights authorized under the new 333 rules 

state that an altitude ceiling of 200 feet is to be observed at all times. Flights will be restricted to 

this height by changing the software height parameter to 200 feet to ensure compliance.

g. Flight operations will typically be directly over logging access roads and logging 

clearings. Access to these roads is restricted by access gates that are locked at all times and are 

under the direct control of Lockheed Martin.

.h. The typical flight path will originate approx. one mile from the boundary line of LM 

Property and will follow the “Center Ridge Road” ( see google Earth map) for approx. 1000 

yards in one direction, then reverse course, return to launch location and continue on above the 

road for 1000 yards. Requests for alterations in course and altitude will be received from the 

tracking site and performed as long as there no safety or distance issues. A GPS tracking device 

(Garmin Dog Collar) will be attached to the quad copter in the event of the aircraft going down.

1) The co-ordinates for #1 are 37 degrees 06’32.36” N 122 degrees 12’29.99” W elev 1593

2) The co-ordinates for #2 are 37degrees 06’ 16.36” N 122 degrees 12’ 37.67” W Elev 1514

3) The flight area will be a radius of 3000 feet from either of these two launch points.

4) Launch site # 1 has a better angle for a sky background.

5) Launch site #2 has a better launch/landing area.
i. After a maximum 15 minutes of flight, the quad copter will return to launch point so as to 

not drain the battery too low and cause the “Auto Land “function to activate. 

j. The LM Santa Cruz Test Base is not near any airports. It is approx. 23 miles from San 

Jose Airport and 27 miles from Watsonville airport, the two nearest airports.

k. Lockheed has a Certificate of Waiver or Authorization (COA) to launch Class 2 rockets at the 

Santa Cruz Test Base, and calls in to NCT traffic management, as well as requesting a NOTAM 

prior to model rocket operations. We would perform the same notification process prior to UAV 

operations in order to continue having a safe airspace during UAV operations. 

Exemptions requested:

14 CFR part 21, Subpart H (Airworthy Certificates) and 91.203(a) and (b) (Certifications 

required) - due to the size, weight, speed, and limited operating area that the aircraft is be used 

in, an exemption for these items is warranted and meets the requirements for the equivalent level 

of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (section 333).

45.23 Marking of the aircraft – the UAV does not have a cabin, cockpit or pilot station on which 

to mark words or phrases. Two inch letters are difficult to place on an aircraft with dimensions 

smaller than the minimal lettering requirement. However, we will mark with the largest possible 

lettering the word “LOCKHEED” on the fuselage as required by 45.29(f) so that the PIC and the 

Spotter will see the markings.
91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) Maintenance inspections as they

apply only to aircraft with an airworthiness certificate. As a safety precaution, a preflight 

inspection of the UA will be performed before each flight as outlined in the operating document.

61.113(a) and (b) - private pilots are limited to non-commercial operations, however an 

equivalent level of safety can be achieved by current regulations as the UAV does not carry any 

pilots or passengers. In addition, while a pilot license is helpful, it does not ensure remote 

piloting skills. The risk of operating a UAV are much less than the risk levels of operating a 

manned aircraft engaged in commercial activities as outlined in 14 CFR part 61. As such an 

exemption from 61.113 Private Pilot Privileges and Limitations: Pilot in Command is requested.

91.7(b) (a) prohibits the operation of an aircraft without an airworthiness certificate. Since there 

is no certificate applicable to this aircraft, it is requested that this regulation be exempted.

91.9(b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers 

on board this aircraft, and due to the Phantom’s size, an exemption is requested. Having the 

safety/flight manual on the ground with the UAS ground Station where the PIC is located is a 

more effective location.

91.121 altimeter settings are not applicable as the Phantom uses electronic GPS with a 

barometric sensor.

91.151(a) Fuel requirements for flight in VFR conditions – the Phantom does not have any liquid 

fuel. It is powered by a battery, so this requirement is not applicable.