Lockheed Martin Corporation 

Information Systems and Global Solutions 

Allan Middleton, Principal Project Engineer, VCAP 

Mail Zone: DC3742 

12999 Deer Creek Canyon Parkway 

Littleton, CO 80109 

lJ I l JUL ·3 0 P I : 4 I 

Lockheed Martin, through its IS&GS facility located in Littleton, CO, is working with the FAA to obtain 

experimental certification to operate its Vertical Capability Airborne Platform (VCAP) in the Littleton 

area. As part of the experimental certification process Lockheed Martin is requesting exemption from 

the following regulations: 

14 CFR Part 91.9(b): requirement for a flight manual in the aircraft 

14 CFR Part 91.151(b) Fuel Requirements for flight of Rotorcraft in VFR Conditions 

14 CFR Part 91.203 (a) & (b): requirement for display of airworthiness certificate in the aircraft 

14 CFR Part 91.207 Emergency Locator Transmitters 

Ref 91.9 and 91.203. VCAP is a small unmanned aircraft operated remotely via ground control stations. 

As a UAV, VCAP does not have a location for or have a need for a flight manual or for on-board display of 

an airworthiness certificate. Lockheed Martirirequests an exemption from the above listed regulation 

as application to a UAV aircraft is not appropriate to the usage of a UAV. Lockheed Martin believes that 

this exemption is. in the public interest in that the flight manual and experimental certification, and 

registration certificate should reside with the ground control station operator, where the operator has 

access to this information to support operation of the UAV. As such granting this exemption does not 

compromise safety, in any way. 

Ref 91.151. VCAP is a small unmanned rotary wing aircraft equipped to carry a maximum of 60 minutes 

of fuel on board. Lockheed Martin is seeking experimental certification for purposes of research and 

development and crew training. As the proposed operating area for VCAP is limited to a small sparsely 

populated area it would seem practical to establish a smaller minimum fuel for VFR daytime operations 

enabling longer flights. Lockheed Martin would propose 10 minutes of fuel remain after reaching it's 

first point of intended landing. It is calculated that from the farthest extreme point in the operating areo. 

to a home position (Mustan~ Flight Training Area) is under 7 minutes. 10 minutes gives additional 

margin to account for weather conditions. 

· Ref 91.207 As VCAP is a small unmanned rotary wing aircraft and plans to operate under experimental 

certificate within a small approved operating area. The crewis remote from the'aircraft and has the 

aircraft in sight at all times. The additional weight of an approved em'ergency locator transmitteris not ' 'i 

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13 July 2012 

Ref: N88LX 

practical for an aircraft of this size (35 lbs max gross weight). GPS coordinates are relayed back to the 

ground station near real time so should an emergency arise the aircraft can be readily located. 

To summarize, Lockheed Martin request exemption from 14 CFR Parts 91.9(b), 91.151 (b), 

91.203(a)&(b), and 91.207 to support operation of VCAP UAV under FAA Experimental Certification. As a 

UAV there is no need to carry and have available on board manuals or other documentation for display 

as well as an emergency locator transmitter. As a small UAV with a .limited operating area a reduced 

requirement for remaining fuel after reaching its first intended landing point is practical enabling longer 

flight times for research and development and crew training. As such Lockheed Martin request 

exemption from these regulations with the associated information (aircraft flight manual, certificate of 

registration, and airworthiness certificate) being available at the ground stations as appropriate, VCAP 

sufficient fuel for safe operation including alternate landing sites, and emergency locator beacon as 

unnecessary equipment to locate the aircraft within the small operating area. 

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