May 11,2012 

To: U.S. Department of Transportation 

Docket Management System 

400 7th Street, SW. 

RoomPL401 

Washington, DC 20591-0001 

From: Raytheon Missile Systems 

Gregg George 

Chief Pilot 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 

of P ederal Regulations. 

Ref: 14 CPR§ 11, 14 CPR§ 45, 14 CPR§ 91 

Raytheon currently has an exemption for general display of markings which expires on November 30, 2012. 

Raytheon is requesting an exemption extension to November 30, 2014 from the following regulations: 

§ 45.23 (b) Display of marks; general 

In part; 

(b) When marks include only the Roman capital letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator 

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot 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 of the word 

"Experimental" with 2 inch letters will be impractical due to the small size of the aircraft. In figure 1 below you 

will see that the word "Experimental", if required, would fit best with 1 inch lettering. However, since there is 

no pilot aboard the aircraft, there is no cabin door, nor a purpose for the display of the word. 

An equivalent level of safety will be maintained by operating the aircraft in a limited and specific manner by a 

qualified crew. 

16138RMS (12102) 
Figure 1 

§ 91.9 (b) (2) Civil aircraft flight manual, marking, and placard requirements 

In part; 

(b) No person may operate a U.S.-registered civil aircraft-

(1) 0 0 0 

Missile Systems 

PO Box 11337 

Tucson, Arizona 

85734-1337 USA 

520.794.3000 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there 

is available in the aircraft a current approved Airplane or Rotorcraft 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 the unmanned 

aircraft (UA). Carrying the aircraft flight manual in the aircraft is not practical since there is no pilot onboard 

the aircraft. An equivalent level of safety will be maintained by keeping the manual in the Ground Control 

Station where it will be available to the pilot. 

§ 91.203 (a) and (b) Civil aircraft: Certifications required 

In part; 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has 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 may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

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 of safety will be maintained 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 by the Department 

of Defense, and other public agencies will contribute to overall public safety. 

The operations are in the public interest because they will support military and public agencies in the war on 

terror, homeland defense, border protection, law enforcement and disaster relief. 

Raytheon UAS operations will meet an equivalent level of safety because of the use of certified engineering 

processes and quality control in the design and manufacturing of the aircraft, and the use of certified pilots and 

engineers in the operations and maintenance of the UA systems. 

cc: John E. Calloway 

Manager, Flight Test Operations 

Raytheon Missile Systems 

16138RMS (12102) 

/~~cf.~ Gregg L. George 

Senior Principal Systems Engineer 

Chief Pilot 

Systems Test Directorate 

Flight Test Operations 

Raytheon Missile Systems 

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