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A ugust 1 1, 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 comme rcial 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 o peration of small, unma n ned 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 us ing 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.2

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 n ot 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 2 0% 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 Corporation3

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY
Nort h rop Grumman Systems Corporation requests exemption from the listed regulations for the reasons stated.
14 CFR Part 21, Airworthiness Certificates This part establishes the p rocedures 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 D evelopment

. 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 re quirements. 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 experimen tal 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 previou s 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 t he 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 informatio n 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 obtai n 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 station4

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 "hand s-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 on b oard 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 t hat 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 registrati on 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 affi xed 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 t he 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