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August 11, 2015

Northrop Grumman Systems Corporation

One Hornet Way XE6K40/D2

El Segundo, CA 90245

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Northrop Grumman Systems Corporation (NGSC) hereby applies for an exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAS, so long as 

such operations are conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively sUAS under controlled conditions in airspace that is

1) limited

2) predetermined and

3) controlled.

Northrop Grumman Systems Corporation develops many different products for aviation and aerospace 

applications using a variety of equipment and devices to demonstrate the end product to our customers.

In this particular case, sensing and tracking devices are employed for aerial applications.

The Petitioner Requests Relief from the following regulations under this exemption:

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.205 (b)2

14 C.F.R. 91.215 

14 C.F.R. (91.401-91.417)

Unmanned Aircraft System 

sUAS are seen as superior to helicopters due to the smaller devices cheaper equipment and personnel 

cost, reduced noise and as such, a much smaller environmental impact which promotes public safety. 
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We are petitioning for exemption to enable Northrop Grumman Systems Corporation to operate a DJI 

S900/A2 and a DJI Phantom 3.

Northrop Grumman Systems Corporation will only operate its SUAS in line of sight of a pilot and/or 

observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile 

area described in the FOPM. Such operations will insure that the sUAS will not create a hazard to users 

of the national airspace system or the public.

Northrop Grumman Systems Corporation will not operate its sUAS within 5 miles of an airport, unless a 

separate Certificate of Authorization (COA) with the airport controlling agency is established with 

additional limiting parameters.

Maximum flight time for each operational flight will provide a 20% power reserve.

The sUAS will be programmed to limit the operated at an altitude of no more than 400 feet AGL

Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer.

The sUAS operated by NGSC weighs less than 55 pounds, including any payload.

The SUAS will not operate at speeds in excess of 50 knots.

We respectfully request exemption under Section 333 to enable Northrop Grumman Systems 

Corporation to operate sUAS operations for the activities stated

Sincerely,

James Wayne

Northrop Grumman Systems Corporation
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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Northrop Grumman Systems Corporation requests exemption from the listed regulations for the reasons 

stated.

14 CFR 

Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the DJI S900 and DJHI Phantom 3 under the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: 

a. Research and Development.

Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft 

operating techniques, or new uses for aircraft.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon 

fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally 

certificated aircraft performing the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in 

the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters 

at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The SUAS does not have an 

entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number 

assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual 

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation, the documentation would 

not be available to the crew during flight operations. To obtain an equivalent level of safety and meet 

the intent of 91.9, we propose that a current, approved SUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests. 

The regulation states, "No person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." The SUAS System ground-based control station 
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consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", 

both the student and instructor can, and will, operate the single set of controls simultaneously. With 

both student and instructor having "hands-on" the controls during flight, we feel that this technique 

meets the intent 91.109 and provides an equivalent level of safety. 

91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. No unit will be operated closer than 500 feet to any 

non-participating person and then only under controlled conditions on private property. 

CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to 

maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the launch and recovery point is transmitted via radio from the sUAS onboard computer to the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The SUAV is battery operated and the maximum duration of flight from a single 

battery charge is 8 minutes with a 20% reserve. Since the aircraft will never fly more than 

3/4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the 

reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for 

an equivalent interpretation with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) 

provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew." At a maximum gross weight of 8.3 pounds, the sUAS is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents 

deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground control 

station and available for inspection upon request. In order to identify the aircraft, we propose that the 

information found on airworthiness and registration certificates be permanently affixed to the aircraft 

via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the 

requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401-91.417)-Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the 

aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight