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 

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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 ofthe experimental certification process Lockheed Martin is requesting exemption from the following regulations: 14 CFR Part 91.9(b): requirementfor aflight manual in the aircraft 14 CFR Part 91.151(b) Fuel Requirements forflight of Rotorcraft in VFR Conditions 14 CFR Part 91.203 (a) & (b): requirement for display ofairworthiness certificate in the aircraft 14 CFR Part 91.207 Emergency LocatorTransmitters Ref 91.9 and 91.203. VCAP is asmall unmanned aircraft operated remotelyvia ground control stations. As a UAV, VCAP does not have a location foror have a need for aflight manual orfor on-board display of an airworthiness certificate. Lockheed Martirirequests an exemption from the above listed regulation as application to a UAV aircraft is notappropriate tothe usage ofa UAV. Lockheed Martin believes that this exemption is. in the public interest in thatthe flight manual and experimental certification, and registration certificate should reside with the ground control station operator, where the operator has access tothis informationto support operation ofthe UAV. As such granting this exemption does not compromise safety, in any way. Ref 91.151. VCAP is asmall unmanned rotary wing aircraft equipped to carry a maximum of60 minutes offuel onboard. Lockheed Martin is seeking experimental certification for purposes of research and development and crew training. As the proposed operating area forVCAP is limited to asmall sparsely populated area itwould seem practical to establish asmaller minimum fuel forVFR daytime operations enabling longerflights. Lockheed Martinwould propose 10 minutes offuel remain after reaching it's first point of intended landing. It is calculated thatfrom the farthest extreme point in the operating areo. to a home position**(Mustan~** Flight Training Area) is under7 minutes. 10 minutes gives additional margin to accountforweather conditions.

· Ref 91.207 As VCAP is asmall unmanned rotary wing aircraft and plans to operate underexperimental

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 ofan approved em'ergency locatortransmitteris not
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Ref: N88LX practical for an aircraft ofthis size (35 lbs max gross weight). GPS coordinates are relayed back tothe 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 ofVCAP UAV under FAA Experimental Certification. As a UAV there is no need to carry and have available on board manuals orother documentation for display as well as an emergency locatortransmitter. 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 flighttimes for research and development and crewtraining. As such Lockheed Martin request exemption from these regulations with the associated information (aircraft flight manual, certificate of registration, and airworthiness certificate) being available atthe ground stations as appropriate, VCAP sufficientfuel for safe operation including alternate landing sites, and emergency locator beacon as unnecessary equipmentto locate the aircraftwithin the small operating area.



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