May 11,2012

To: U.S. Department ofTransportation Docket Management System 400 7th Street, SW. RoomPL401 Washington, DC 20591-0001

From: Raytheon Missile Systems Gregg George ChiefPilot and Senior Principal Systems Engineer P.O. Box 11337 Bldg 845, MS 5 Tucson, AZ 85734-1337 520-794-2777 gregg george@ratheon.com Missile Systems PO Box 11337 Tucson, Arizona 85734-1337 USA 520 794.3000

Subj: Request for exemption from §45.23 (b), §91.9 (b) (2), and §91.203 (a) and (b), ofTitle 14, ofthe Code ofP ederal Regulations. Ref: 14 CPR§ 11, 14 CPR§ 45, 14 CPR§ 91
Raytheon currentlyhas an exemption for general display ofmarkings which expires on November 30, 2012. Raytheon is requesting an exemption extension to November 30, 2014 from the following regulations: 

### § 45.23 (b) Display ofmarks; general In part; (b) Whenmarks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport categoryaircraft or experimental orprovisionally certificated aircraft, the operator must also display onthat aircraft near each entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Raytheon requests exemption from the requirement to display the word "Experimental". Display ofthe word "Experimental"with 2 inch letters will be impractical due to the small size ofthe aircraft. In figure 1below you will see that the word "Experimental", ifrequired, would fit best with 1inch lettering. However, since there is no pilot aboard the aircraft, there is no cabin door, nor a purpose for the display ofthe word. An equivalent level ofsafety will bemaintained byoperating the aircraft in a limited and specific mannerby a qualified crew.
16138RMS (12102)Figure 1 

### § 91.9 (b) (2) Civil aircraft flight manual, marking, and placard requirements Inpart; (b) No person mayoperate a U.S.-registered civil aircraft- (1)

0 0 0 Missile Systems PO Box 11337 Tucson, Arizona 85734-1337 USA 520.794.3000

(2) Forwhich an Airplane orRotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved Airplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Raytheon requests an exemption from the requirement to carry the aircraft flight manual onboard theunmanned aircraft (UA). Carrying the aircraft flight manual in the aircraft is notpractical since there is no pilot onboard the aircraft. An equivalent level ofsafety will be maintained bykeepingthe manual in the Ground Control Station where it will be available to thepilot. 

### § 91.203 (a) and (b) Civil aircraft: Certifications required Inpart; (a) Except as provided in §91.715, no person mayoperate a civil aircraft unless ithas within it the following: (I) An appropriate and current airworthiness certificate. (2) An effective U.S. registration certificate issued to its owner.

16138RMS (12102)Missile Systems PO Box 11337 Tucson, Arizona 85734-1337 USA 520794.3000 (b) No person mayoperate a civil aircraft unless the airworthiness certificaterequired byparagraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Raytheon requests an exemption from the requirement to carry certification and registration documents and to display them onboard the UA. Carrying the airworthiness certificate and aircraft registration in the aircraft is not practical since there is no pilot onboard the aircraft. An equivalent level ofsafetywill bemaintained by keeping these documents in the Ground Control Station where it will be available to the pilot. Summary Raytheon operates various Unmanned Aircraft Systems in the United States for missions related to research and development, crew training and market surveys. The new technologies developed to be used bythe Department ofDefense, and otherpublic agencies will contribute to overall public safety. The operations are in the public interestbecause they will support military and public agencies in the war on terror, homeland defense, borderprotection, law enforcement and disaster relief. Raytheon UAS operations will meet an equivalent level ofsafetybecause oftheuse ofcertified engineering processes and quality control in the design and manufacturing ofthe aircraft, and the use ofcertified pilots and engineers in the operations and maintenance ofthe UA systems.

cc: John E. Calloway Manager, Flight Test Operations Raytheon Missile Systems
16138RMS (12102)

# /~~cf.~ Gregg L. George Senior Principal Systems Engineer ChiefPilot Systems Test Directorate Flight Test Operations Raytheon Missile Systems

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