August 10, 2015

Exemption No. 12403

Regulatory Docket No. FAA–2015–1898

Ms. Karen Dyberg

Spectrum Manager

Raytheon Integrated Defense Systems

1001 Boston Post Road 

Marlborough, MA 01752

Dear Ms. Dyberg:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letters dated May 7 and May 18, 2015, you petitioned the Federal Aviation Administration 

(FAA) on behalf of Raytheon Integrated Defense Systems (hereinafter petitioner or operator) 

for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct testing of the Raytheon radar system and other advanced defense technologies.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

The UAS proposed by the petitioner are the DJI Phantom 2 and DJI S900.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Raytheon Integrated Defense Systems is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Raytheon Integrated Defense Systems is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 and 

DJI S900 when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Raytheon Integrated Defense Systems 

1001 Boston Post Road 

Marlborough, MA 01752 

May 7, 2015 

 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Re: Raytheon IDS Petition for Exemption under 14 CFR 11.81 for use of DJI S900 Hexacopter 

Dear Sir or Madam: 

On behalf of Raytheon Integrated Defense Systems (Raytheon IDS) I am filing this Petition for Exemption, as 

allowed by 14 C.F.R. § 11.81, to request exemption for use of a model aircraft by a company for its research and 

development purposes. 

Below, Raytheon IDS sets forth the required information for consideration of this exemption request. If further 

explanation is required for any of these criteria to be met, please contact me at: 508-450-9236 or 

Karen.Dyberg@Raytheon.com. 

1. Name, Address and Contact Information for Petitioner 

Name: Raytheon Integrated Defense Systems 

 Contact: Karen Dyberg, Spectrum Manager 

Address: 1001 Boston Post Road, Marlborough, MA 01752 

Phone: 508-450-9236 

e-mail: Karen.Dyberg@Raytheon.com

2. Regulatory Exemption Sought: 

Raytheon IDS is seeking an exemption from the FAA’s Regulations requiring a Certificate of Airworthiness. In 

this case, the exemption sought is a specific exemption for the proposed operations described below from 14 

C.F.R. Sections 21.11, 21.15, 21.20, and 21.21 all related to the requirement to have an airworthiness certificate in 

place prior to use of an aircraft. 

3. Extent of Relief Sought: 

Raytheon IDS is seeking relief to allow it to operate the DJI S900 hexacopter, a model aircraft, as the platform 

used for testing of a radar simulator device in Raytheon IDS’s development of a rapid prototype radar system. 

The use of this mobile platform will greatly reduce the cost and speed the time to develop the proposed radar 

system by allowing remote mobile testing and advancement of the prototype radar system. The relief sought is 

from the prohibition on companies using model aircraft in their business operations. This relief is very limited, 

since the model aircraft is used in development of a radar, not for any other purpose. 

Regulations from which relief is sought: 

Raytheon is seeking relief from a number of sections under Title 14 of the Code of Federal Regulations, 

including: 

14 CFR Part 21 – Airworthiness Certification, subpart H 

14 CFR Part 61 – Certification: Pilots, Light Instructors, and Ground Instructors
Page 2 of 12 

14 CFR Part 91 – General Operating and Flight Rule 

 91.103(b)(2) – Preflight action 

 91.105 – Flight crewmembers at stations 

 91.109 – Flight instruction 

 91.119 – Minimum safe altitudes 

 91.121 – Altimeter settings 

 91.151 – Fuel requirements for flights in VFR conditions 

 91.405 – Maintenance required 

 91.407 – Operation after maintenance 

 91.409 – Inspections 

 91.417 – Maintenance records 

Without such relief, Raytheon would not be allowed to use the aircraft for its independent research and 

development work. 

4. Reason for Relief – Proposed Operations: 

The proposed testing requires use of an airborne mobile transmitter that will simulate the movement of an 

object that Raytheon’s developmental radar needs to track. The radar tracking is part of a rapid prototype 

technology development effort. Using commercial-off-the-shelf technology is key to keeping costs low and 

delivering results quickly. 

The model aircraft will be equipped with a radar simulator and flown on secure Raytheon property or in

specially designated areas with personnel ensuring secure and safe operations. The purpose is for testing of a 

Raytheon radar system under development at Raytheon’s Pelham, New Hampshire facility. Most of the test 

sites selected are parking lots or open areas that are on Raytheon facilities, which are fenced in and have 

restricted access. Since the proposed operations will comply with the amateur UAV user parameters – line of 

sight operations and no operation above 400 feet – the restricted access to the flight areas should ensure that 

there is no burden on the national airspace and no impact on other aircraft. 

Details of the proposed operations are set out below. 

A. UAS System 

a. Aircraft Performance and Performance Limitations 

b. Operating Procedures 

c. Aircraft loading information 

Make: DJI 

Model: S900, 

SN: 0370062767 

Technical Specifications: 

 Diagonal Wheelbase: 90cm 

 S900 Takeoff Weight (w/ payload): 5.4Kg 

 Payload Weight: 2.1Kg 

 Battery Power: LiPo 22.2V 15000mAh 

 Estimated Hover Time: 18min (@15000mAh & 5.4Kg Takeoff Weight ) 

 

B. Pre-flight inspections, maintenance, repair 

In accordance with manufacturer instructions we will follow the following instructions to the 

letter: 
Page 3 of 12 

Figure 1. Spreading Wings S900 User Manual ver. 1.2, December 2014, at p. 4 

 

Further, to ensure safe operations, the program will also follow the AMA Radio Control Large 

Model Airplane Program pre-flight inspection checklist, as shown in Attachment A. 

 

C. RF spectrum to be used for control of UAS 

The program will use the Futaba 8J controller for remote control operations. It uses the 2.4 GHz 

unlicensed band configured for RC controllers. The controller is FCC certified. This controller 

has a special feature. The UAV has an autonomous operation capability. If communication 

between the UAV and the controller is lost, or if the battery is running low, the UAV has a 

“return to home” function. The UAV will activate the function autonomously if communication 

with the controller gets too weak or if the UAV determines its battery life requires return to the 

home station to ensure safe arrival at the home station before battery exhaustion. Furthermore, if 

the controller is somehow dropped or broken, the UAV will also return to the home station. If the 

person in control of the UAV wishes to manually activate the home function, that capability is 

also available. This would be done if the UAV is operating out of the ordinary or if there is any 

issue with UAV control. The operator just pushes the home button and the UAV will return 

home. 

D. Associated equipment that will be part of UAS – sensors, cameras, etc. 

To undertake further development of one of Raytheon’s advanced radar systems, an airborne 

Synthetic Target Generator (STG) is required to exercise the radar. This payload is a radio that is 

sending out signals at 5 Watts with an ERP of 50 Watts (peak power). This radio signal is used to 

simulate a remote system that is part of an advanced radar development initiative. Raytheon IDS 

will obtain an FCC experimental license for the appropriate radio operations. 

Installation: The STG with an omni-directional antenna will be added to a small Unmanned 

Aerial Vehicle (UAV) host platform, the S900, to emulate real target motion through space. The 

UAV-mounted STG will transmit the FCC-authorized waveforms at low power levels, from 

several locations, described in detail below. This will allow Raytheon to test the performance of 

the radar when it is working with an actual moving target that is trackable by the radar system. 
Page 4 of 12 

No ground-based moving target offers the opportunity to track at the distances required, only a 

target in motion in the air allows the radar to perform as necessary for its advanced development. 

E. Pilot In Command 

a. Qualifications of person who will be directly responsible for operation of UAS 

 Private Pilot since 1973: Single Engine Land: Various Single Engine Aircraft 

 P ilot has flown his own Personal, UAS Quadcopter for more than 1 year 

b. Level of airman certificate held 

 Private Pilot, Single Engine Land 

c. Applicable training related to the operation 

 The pilot has trained and been licensed and certificated as a pilot. He has personal 

 experience operating UAS systems. 

d. Minimum hours of flight experience 

 Over 200 hours of flight experience 

e. If operation will use visual observers, describe their roles and qualifications 

 The remote control operator will be the observer for all flight operations. 

f. Medical standards and certification of the person(s) directly responsible for operation of 

the UAS. 

 Yearly Physical

 

F. Safety: 

a. How operations will not adversely affect safety: The proposed operations are limited in 

time and scope. Testing will take place only on limited work days, when the radar testing 

is underway. The testing will be limited to 15 minute increments, which is the power 

limitation of the UAV. The areas selected, described in more detail in this Petition, are 

protected from public access, and are isolated areas, even on the Raytheon properties. No 

operations are proposed that would cause any sort of hazard. 

b. How operations will provide a level of safety at least equivalent to that provided by the 

rule from which exemption is sought: The rules from which exemptions are sought are 

the rules that precludes this UAV operation by this operator – Raytheon. The current 

rules preclude a business from operating the UAV, although the rules would allow an 

amateur to operate the same UAV, under less restricted circumstances. So, to ensure the 

proper level of safety, the proposed operation will be strictly in accordance with the 

already-permitted amateur operating guidelines, only by a company that needs to use the 

platform to expedite development of a radar system. Because Raytheon has a regulatory 

compliance program, the level of safety of operations will be followed strictly, leading to 

a level of safety at least equivalent to that which results from amateur operations of the 

same UAV platform. Pre- and post-flight safety checks and operation by a licensed pilot 

will also ensure that the level of safety for these operations will be at least equivalent to 

the rule that allows amateur operations of this UAV. 

c. Plans to implement clearly defined operational borders and procedures to ensure public 

safety, which includes persons and property both in the air and on the ground: The 

operational borders are in place because of the areas of operation selected. Three areas 

are contained on secure Raytheon facilities; the others are MDC which is adjacent to a 
Page 5 of 12 

Raytheon property and Area 4, which is a designated UAS test-site. The Raytheon 

facilities, which are the top priority sites to use, are fenced off from the general public, 

with secure access required, and all entrances to the property are gated with security at 

the gates. At those sites, the area of operation is wholly contained within the Raytheon 

facilities, and the areas chosen on the Raytheon property are remote and unused. The 

areas were selected because of their remote and unused condition. Further, Raytheon will 

post signs around the operational area prior to test operations to ensure that no people 

will be exposed to any potential harm. In addition, because the area of operations is 

small and the operator will be within sight of the UAS at all times, the operator will be 

able to also watch out to protect any Raytheon employee who might be in the test area 

unexpectedly. 

The low mass and low speed of operation for this UAV will also ensure that there is no 

harm to any individual in the area of operation. 

G. Flight Characteristics 

a. Maximum operating speed – The maximum speed of the UAV is 16 m/second (about 30 

miles per hour). The UAV will NOT operate above 20 miles per hour. The UAV 

device will take off and be used primarily to hover with its radio payload in operation. 

The goal is to ensure that the remote radar is able to detect the simulated radar target and 

to work on processing the signals. For that testing, the UAV does not need to move very 

much, in fact it would impede the operation of the radar testing if it did. The hover 

capability of this UAV is the reason that the program chose a hexacopter rather than a 

fixed wing aircraft. There will be some side-to-side movement 30-40 meters either 

direction, but the testing design calls for the UAV to remain primarily in one general area 

at the test facility. The flight pattern will be either an oval or a figure 8 pattern over the 

test area. The maximum speed used in testing could go as high as 20 miles per hour. 

 

b. Altitude – below 400 feet. 

c. Describe minimum flight visibility – No flights will be conducted if the weather visibility 

is less than 3 miles from the control station. If the visibility is 3 miles or greater, and 

wind conditions allow for safe flight, flights may be conducted as necessary. 

d. Distance from clouds for intended operations - The normal cloud ceiling in this area is 

above 3000 feet, and the maximum altitude of flight will be below 400 feet. If it is a 

cloudy day, they will not fly anyway. Further, there will always be visual line of sight 

between the operator and the UAV. 

 

e. Potential hazards and safety mitigations - The mass of the UAV is low enough that the 

device does not pose much of a safety hazard. The testing area will be cleared of any 

people who are not part of the test prior to any operations. The operator will ensure that 

the UAV operates clear of trees, power lines, buildings, street lights, and other 

obstructions. The failsafe in the UAV will help to ensure that the UAV does not land 

away from the operator, because it will return to home rather than lose signal or power. 

H. Characteristics of Area of Intended Operation 

a. General Description – The areas selected for operation are four open areas on, and in one 

case next to, Raytheon property, where there are no people and the actual area of 

operation would be away from buildings. The fifth site selected is a UAV test range that 

would only be used if none of the other sites was available. 
Page 6 of 12 

The Raytheon sites: Pelham, Raytheon HQ, and Sudbury are all on property that is 

securely fenced off from public access. To gain access to the property, any visitor would 

have to go through security at the main gate. The security of the facility is high because 

of the nature of work that Raytheon conducts. There will be no passers by entering the 

test area. Further, no general public vehicle traffic will be in the area. 

MDC is at a Raytheon property in Woburn, Massachusetts. The test area is public land 

behind the Raytheon property, and the area is generally not accessed by the public. This 

site is not expected to be in use very much for the testing, but it was added in case its 

location is necessary for the geometry testing of the radar. 

The UAV test range is not on Raytheon property, but it is a known UAV test range, and 

as such it is known to the public as a place where UAVs are flown. Raytheon, if it uses 

this site at all, will used enhanced precautions to ensure that there are no hazards present 

during any flights conducted there. 

b. Google Earth images of each of the five test areas are below: 

Site Locations (Lat, Long, & Alt -ft)

Site0: 42.737013°, -71.354670°, 412 

Site1: 42.637037°, -71.249763°, 197 

Site2: 42.521533°, -71.141729°, 107 

Site3: 42.364951°, -71.430758°, 159 

Site4: 42.616659°, -71.510590°, 204 

The Figures 2-6 are taken from Google Earth, depicting the site locations with a 100 

meter radius from the site coordinates. The radius is for informational purposes only, 

since the hexacopter will not fly throughout the whole radius. At the MDC and Sudbury 

sites, operations will be limited to the sectors shown, to ensure additional safety. When 

the hexacopter is in use, it will fly/hover in a very limited portion of the area shown. 

These images are presented to allow the reviewer to see that the areas selected are away 

from people and mostly away from buildings. In those areas, the hexacopter will fly in 

an oval or figure eight pattern, if it is not simply hovering. 
Page 7 of 12 

Figure 2. Pelham Site 

Figure 3. Raytheon Headquarters – back parking lot, showing potential flight pattern 
Page 8 of 12 

Figure 4. MDC, showing potential flight pattern 

Figure 5. Sudbury location, showing a potential flight pattern

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Page 9 of 12 

Figure 6. UAV test range

c. Associated potential hazards 

Pelham: None. 

Raytheon HQ: None 

MDC: None 

Sudbury: None 

UAV test range: None 

d. Proximity to populated areas - The area of operations will be limited to the open spaces in 

the sites selected. Operations will be controlled by a licensed pilot, and the operations 

will avoid any buildings. This is essential not only for the safety of flight and the people 

in the buildings, but any flight near a building could interfere with the radio 

experimentation that is the purpose of the flight. 

I. Proximity of any Airports 

Site-by-site assessment of airport proximity: 

Pelham Site – the Pelham site is near the Steck Farm Airport, which does not appear to have a 

runway, although there do appear to be some bi-planes parked at the farm, and they may use the 

field as their runway. 

Raytheon HQ – about 4.5 miles from the headquarters location, to the northeast and in the 

Merrimack River is the Merrimack Valley Seaplane Base. There are no other airports or heliports 

nearby. 

MDC – no nearby airports. There is a “digital heliport” within about 2 miles, but on closer 

inspection, it does not appear to be a heliport at all, since there are no markings for use by aircraft 

in the parking lot. 
Page 10 of 12 

Sudbury – Nearby airports: there is an old airstrip is nestled in the woods about 1.5 miles from 

the Sudbury location, but it appears to be in disrepair and not used. Also, the Marlboro Airport is 

approximately 5 miles from this test site. It is a public airport with one runway that averages 

about 37 flights per day. 

UAV Test Range – the only aircraft facility within five miles of the UAV test range is the 

Nashoba Community Hospital Heliport. The next nearest airport is Pepperell Airport which is 

between 7 and 8 miles away from the UAV test range. Pepperell is a private airport, used largely 

for sky diving activities. While the airport is open to general aviation, not commercial, and pilots 

must call first to use the airport. 

Summary Analysis: After review of the nearby airports, and given the height limitation of the 

UAV flights (400 feet or less) there is no anticipated concern that any UAV operations will pose 

a hazard to any airport or flight operations. 

J. Operation in Visual line-of-sight in accordance with Section 333(b)(1) 

The operations will operate with visual line of sight. The UAV will never be out of sight of the 

operator. Because the area of operations will have a radius of 100 meters, with the expectation 

that the UAV will hover more than it will fly, the UAV is expected to be much closer to the 

operator than 100 meters. The areas selected for operation, as shown in figures 2-6, are open 

areas with no obstacles or obstructions to view. These areas were selected both for the safety of 

flight characteristics, but also because open areas are required for the testing to be effective. 

Figures 3, 4, and 5 also include overlays which show the possible flight paths of the UAV at those 

test sites. The UAV operations will be limited to oval (race track) paths or figure eight paths, to 

keep the UAV in a discrete area away from any obstacles, buildings, or people. Further, these 

flight paths are ideally designed for the radar development operations that are the purpose of the 

UAV flights. 

The pilot in command of the UAV will maintain visual contact with the UAV as well as having 

control of the RC controller to direct flight. Finally, the pilot in command will have the ability to

trigger the “home” command if at any point safety requires it. 

K. Procedures for pre-flight safety risk assessment to comply with 14 CFR Section 91.7(b) 

The pilot, along with the UAV team, will conduct a pre-flight safety risk assessment prior to any 

operations. The procedures will include: 

Checking and monitoring weather conditions every 15 minutes the day of flight to ensure that 

wind conditions will not allow loss of control to the UAV. 

Checking visibility to ensure that the minimum visibility will be maintained throughout each 15 

minute scheduled flight. 

Inspecting the chosen flight area for obstacles, people, or valuable property. Adjusting the flight 

area to avoid any obstacles or people to ensure the safety of all. 

Prior to each flight, the flight area will be cordoned off with signs posted that a flight is in 

progress and that people should avoid the area. This will protect any Raytheon staff from 

inadvertently entering the area during a flight, thereby minimizing any chance of risk to humans. 
Page 11 of 12 

Further, to ensure the airworthiness of the aircraft, the pilot will conduct all of the pre-flight 

safety checks and inspections listed in the AMA manual – see Attachment A – and in the aircraft 

user manual – See Figure 1, above – before every flight. 

Raytheon’s proposed testing would equip the hexacopter with a simulated radar transmitter and 

fly the hexacopter in specifically designated areas, below 400 feet, to allow work on advancement 

of the radar system. 

The central radar, where system development is taking place is located at: Pelham, New 

Hampshire - Site0: 42.737013°, -71.354670°, 412 ft AMSL 

The operations would be conducted by a specialized team of operators who are expert in use of 

the hexacopter as well as very familiar with the FAA’s requirements for see and avoid procedures 

with regard to any and all other aircraft operating in the nearby National Air Space. 

5. How would this request benefit the public as a whole: 

The proposed operations will deliver a high quality technology to potential US government customers at a 

rapid rate and economical cost. This benefits the public by delivering advanced technology rapidly that will 

enhance national security. Further, the use of commercial off the shelf components as a platform for 

developing the radar system will save tax payer dollars over development of a customized UAV as the 

platform for the radar simulator. Further, there is no harm to the public from the proposed operation. The 

goal is to use this UAV as part of a research experiment, not as a device for hire. 

The whole purpose of the operation is to use the UAV as a platform that will advance the development of a 

radar system. Testing of this UAV is not the reason for this request. The experimentation is devoted to radar 

system development. Advances in the radio system will prove fruitful for Raytheon’s DOD customers. 

 

6. Reasons why this exemption will not adversely affect safety or how this exemption will provide 

safety at least equivalent to the existing rule: 

The proposed operations will be conducted by a licensed pilot who is very familiar with the FAA’s rules on 

UAS operations. 

Use will be limited to the greatest extent possible, and the burden on the national air space will be as low as 

possible, since flight operations will only take place to advance the science of the radar. The primary 

locations for this testing are on Raytheon plant sites, and not at publicly available spaces. The areas selected, 

as described above, are fenced off from the public and only personnel with proper authority are allowed on 

site. With the low altitude of flight, there is no chance of any interference with any aircraft or other UAVs. 

Further, testing will only be conducted sporadically, in good weather conditions, and by personnel who are 

experienced with the need to protect the national air space using see and avoid techniques. 

The operations will be conducted by a certificated airman with many years of experience as a pilot. His 

experience in conducting pre-flight and post-flight inspections will prove invaluable to ensuring that the flight 

operations are conducted in compliance with all procedures. Further, his experience will also prove 

invaluable in ensuring that the flight operations will be conducted in accordance with the proper diligence and 

care. 

This level of experience and attention to proper procedure is essential to ensuring Raytheon’s compliance 

with the FAA’s regulations. Since these aircraft are otherwise flown by amateurs for recreational purposes, in 
Page 12 of 12 

areas which may not be controlled, the proposed exemption will provide safety at least equivalent to the 

existing rule. 

7. Summary:

Raytheon is seeking an exemption from the FAA for the use of a commercial-off-the-shelf UAV to speed the 

development of advanced defense technologies. The use of the UAV will allow for rapid prototyping of a 

radar system and speed the troubleshooting of various technical issues by using a remote synthetic target 

generation that will test the radar performance. 

The exemption request seeks authorization for use of the DJI S900 Hexacopter to carry the target generator. 

The FAA’s current regulations preclude a business from using an amateur UAV in their business operations. 

Because the aircraft does not yet have an airworthiness certificate, this petition seeks to waive various FAA 

regulations regarding the use of certificated aircraft. However, the key to the testing is that Raytheon will be 

using a UAV that is widely available to amateur users, and Raytheon will be using the UAV in highly 

controlled environments and with stringent safety protocols. 

Raytheon will utilize the experience of a licensed pilot to command the operations of the aircraft. The aircraft 

will operate below 400 feet in altitude. The aircraft in question has a homing feature which will ensure that it 

never loses power far from its starting point and which ensures that it will not fly out of range of the 

controller. 

Operations will be limited to visual line of sight, with an emphasis on see-and-avoid procedures being

followed. 

Flights will be sporadic and limited to 15 minutes at a time, not constant, and certainly not daily. 

Furthermore, the UAV will only be in use during the workday, not at night nor on the weekends. 

Grant of this Petition for Exemption is in the public interest because it will advance the radar science through 

the use of innovative technology, at a lower cost to the public and at a quicker pace that is important for our 

nation’s security. Further, the proposed operations, which include command by a trained pilot, do not pose a 

greater risk to the public than operations already taking place by amateurs. 

This Petition does not seek an exemption for use of the UAV for hire. It is simply a highly efficient tool for 

advanced development of a radar technology which is important to the US Department of Defense. 

 

Conclusion:

For the foregoing reasons, Raytheon IDS respectfully requests that the FAA grant this Petition for Exemption 

to allow it to operate a UAV platform for the rapid and cost-effective development of its radar system. 

Raytheon IDS will take all precautions to protect the national airspace, as described above. Should you have 

any questions or need further information, please contact me. 

This request is vital to our national security. Thank you very much for your consideration. 

Sincerely, 

Karen Dyberg 

Spectrum Manager 

Raytheon Integrated Defense Systems 
Large Model Airplane Program—Preflight Checklist

Page 13 of 29

GUIDELINES FOR LARGE MODEL AIRPLANE INSPECTIONS

No one can predict equipment failure or pilot error in the flying of radio controlled airplane. 

However, if the following preliminary precautions are met, equipment and structural failures can 

be minimized.

Whether you are the owner of a LMA or an appointed LMA Inspector, you will evaluate every

aspect of the airplane awaiting certification.

The following is considered the criteria for certification of Large Model Airplane:

Check List for Preflight Inspection

1. UN-ASSEMBLED INSPECTION

1.1 WING GROUP

( ) Fuselage attachment points

( ) Strut attachment points

( ) Rigging wire attachment points

( ) Servo mounting

( ) Pushrods/cables and actuating links

( ) Control horns

( ) Control surface hinges and area around hinges

( ) Undercarriage integrity and attachment points

( ) Structural integrity overall

( ) Covering integrity

1.2 FUSELAGE GROUP

( ) Wing attachment points

( ) Undercarriage integrity and attachment points

( ) Servo mounting

( ) Pushrods/cables and actuating links

( ) Control horns

( ) Control surface hinges and area around hinges

( ) Fin and rudder assembly

( ) Horizontal stabilizer assembly

( ) Bracing/strut attachment points

( ) Structural integrity overall

( ) Covering integrity
Large Model Airplane Program—Preflight Checklist

Page 14 of 29

1.3 ENGINE(S)

*( )Propeller secure and undamaged

*( )Spinner secure and clear of propeller blades

*( )Engine mounting and accessories secure

*( )Cowling attachment

*( )Magneto switch functioning and OFF

*( )External servicing points (fuel, plus, etc.)

1.4 RADIO EQUIPMENT

( ) Receiver installation

( ) Battery installation

( ) Antenna installation

( ) Switch installation

( ) Wiring and plugs clean, undamaged and secure

2. ASSEMBLED INSPECTION

2.1 GENERAL

( ) First ensure that all components fit together correctly, and that no undue strain is

needed to achieve proper alignment.

2.2 RIGHT WING

( ) No non-design twists or warps

( ) Wing tips true

( ) Wing leading edge

( ) Struts and rigging secure

( ) Attachment to fuselage

( ) Undercarriage attachment

( ) Alignment of control surfaces

2.3 FUSELAGE AND TAIL GROUP

( ) Horizontal stabilizer attachment

( ) Fin and rudder attachment

( ) Struts and bracing secure

( ) Alignment of tail group with respect to wing

( ) Alignment of control surfaces

( ) Tail wheel assembly

( ) Canopy
Large Model Airplane Program—Preflight Checklist

Page 15 of 29

2.4 LEFT WING

( ) No non-design twists or warps

( ) Wing tips true

( ) Wing leading edge

( ) Struts and rigging secure

( ) Attachment to fuselage

( ) Undercarriage attachment

( ) Alignment of control surfaces

2.5 MISCELLANEOUS

 ( )Center of gravity

*( )Correct movement and centering of all control surfaces

*( )Battery charge, fuel, air pressure all sufficient

2.6 CHECKS WITH ENGINE(S) RUNNING

*( )Airplane secure before start (tied down preferred)

*( )Engine performance and reliability

*( )Propeller and spinner balance

*( )Minimal airplane vibration

*( )Radio reliability

*( )Radio range check

The above check list is to be completed by the owner of a LMA or an appointed inspector prior 

to test flights. All items are to be marked “N/A” if not applicable, checked if passed, or left blank 

pending re-inspection if failed.

The Check List is subsequently used by the operator of the airplane:

(a) Once at the beginning of a flying session (all items)

(b) Before every flight (items marked with an * only)
Large Model Airplane Program—Preflight Checklist

Page 16 of 29

PREFLIGHT CHECKOUT TEST

(Should be completed prior to each flight)

CONTROL SYSTEM:

( ) Perform a range check with your radio. Use the recommended range check distances as 

described by the radio manufacturer as a minimum test range requirement. Perform the range 

check, without the engine operating, to the maximum range achievable without control 

degradation. 

( ) Run a similar check with the engine operating at power levels from idle to maximum power. 

If there is range degradation with an operating engine there is an issue with ignition noise and/or 

a vibration induced problem. Do not fly until this is resolved. ANY reduction in range means a 

loss in signal/noise ratio and a chance of control loss in flight.

The engine off/engine on test should be conducted prior to each flying session since degradation 

of shielding and spark plugs with usage is a historical fact.

( ) Check servo operating for erratic performance, especially with the engine(s) operating. Be 

sure they operate smoothly throughout the entire control range. Apply hand load to surfaces 

while being moved by transmitter action to check for non-flexing of control cables/rods.

( ) Transmitter battery life MUST have been previously established by a discharge test, prior to 

first flight.

( ) Keep a daily record of transmitted "ON" time.

( ) Check the state of charge of the flight battery packs, UNDER LOAD, just prior to each 

flight. Flight battery packs MUST have been previously checked for design capacity prior to first 

flight.

( ) Check the function of the fail-safe system by turning off the transmitter and observing the 

results.

VEHICLE:

Thoroughly inspect the airplane and components for assembly and for structural integrity.

( ) Inspect the wing and tail assembly for signs of structural failure.

( ) Examine all control surface hinging for design integrity.

( ) Examine servo mounting and retention screws or bolts.

( ) Examine all push rods and keepers.
Large Model Airplane Program—Preflight Checklist

Page 17 of 29

( ) Be SURE there is no looseness or slop in the control components.

( ) Check the mounting provision for tightness and security of all components that are 

removable for transporting to and from the flying site.

( ) Inspect fuselage for signs of potential failure or damage during previous flights or 

transporting.

( ) Check servo installation and be sure the servo arm retention screws are tight.

( ) Inspect receiver/servo wiring for integrity and see that all plugs connecting the components 

are taped or in some way protected from vibrating apart. Include battery pack plugs.

( ) Check to see that receiver antenna(s) are routed away from servos. Vertical orientation of 

antenna is preferred.

( ) Check for NO STRAIN on antenna/receiver connection.

( ) Examine landing gear mounting and function. (retract/steering)

( ) Examine fuel tank(s) installation for adequate support, isolation from vibration and ZERO 

leakage. Special care must be given to gasoline systems in view of the increased fire hazards 

involved.

ENGINES:

( ) Inspect mounting for looseness, cracks or evidence of degradation.

( ) Check for loose bolts, muffler looseness, routing and integrity of ignition wiring, etc.

( ) Check propeller(s) and installation for tightness. Propellers must have the edges rounded to 

prevent hand cuts on starting. Always use a glove or engine starter.

( ) Check spinner(s) for tightness or cracks. (Loss of a spinner and/or propeller in flight can 

quickly generate a panic situation).

( ) Inspect cowl area for loose nuts and bolts.
Large Model Airplane Program—Preflight Checklist

Page 18 of 29

ENGINE RUN-UPS:

( ) Exercise extreme caution when starting and operating engines. A starter is preferred to avoid 

hazards to the hands or body.

 Securely restrain the vehicle. Do not allow ANYONE to be positioned in the plane of

rotation of the propeller(s).

 The use of safety glasses is encouraged. Avoid loose clothing, transmitter straps, etc. that 

might engage the propeller.

( ) Always have a FIRE EXTINGUISHER available when operating gasoline engines.

( ) Start the engine(s) and check for proper idle.

 

( ) Be sure that the engine(s) operates at desired top end R.P.M. and does not sag with prolonged 

running, from inadequate cooling.

PILOT STANDARDS:

The inspector will review the pilot’s skill level at the same time as the model’s qualification 

flight.

Safe operation is a mixture of several ingredients: design, construction, pre-flight check-out and 

the pilot. A proficient pilot can often avoid a disaster when power failure, partial loss of control 

or many other incidents occur. The larger the airplane is, the more it will fly like a full-scale 

airplane than smaller models. Control and engine(s) response are quite different from smaller 

airplane.

The following constitutes the standards for pilots of airplanes in the LMA-2 classification:

( ) At least five years background in model design, construction, and/or piloting of radio 

controlled model airplane.

( ) Has demonstrated successful flying experience of LARGE heavy models in excess of 40 

pounds. 

( ) A demonstrated ability to recognize stall and loss of aerodynamic control.
Raytheon Integrated Defense Systems

1001 Boston Post Road

Marlborough, MA 01752

May 18, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE., 

Washington, DC 20590

Re: Raytheon IDS Petition for Exemption under 14 CFR 11.81for use of DJI Phantom 2 Quadcopter 

Dear Sir or Madam:

On behalf of Raytheon Integrated Defense Systems (Raytheon IDS) I am filing this Petition for Exemption, as 

allowed by 14 C.F.R. § 11.81, to request exemption for use of a model aircraft by a company for its research and 

development purposes. 

Below, Raytheon IDS sets forth the required information for consideration of this exemption request. If further 

explanation is required for any of these criteria to be met, please contact me at: 508-450-9236 or 

Karen.Dyberg@Raytheon.com. 

1. Name, Address and Contact Information for Petitioner

Name: Raytheon Integrated Defense Systems

Contact: Karen Dyberg, Spectrum Manager

Address: 1001 Boston Post Road, Marlborough, MA 01752

Phone: 508-450-9236

Email: Karen.Dyberg@Raytheon.com

2. Regulatory Exemption Sought:

Raytheon IDS is seeking an exemption from the FAA’s Regulations requiring a Certificate of Airworthiness. In 

this case, the exemption sought is a specific exemption for the proposed operations described below from 14 

C.F.R. Sections 21.11, 21.15, 21.20, and 21.21 all related to the requirement to have an airworthiness certificate 

in place prior to use of an aircraft.

3. Extent of Relief Sought:

Raytheon IDS is seeking relief to allow it to operate the DJI Phantom 2 Quadcopter, a model aircraft, as the 

platform used for testing of a radar simulator device in Raytheon IDS’s development of a rapid prototype radar 

system. The use of this mobile platform will greatly reduce the cost and speed the time to develop the proposed 

radar system and other advanced defense technologies by allowing remote mobile testing and advancement of 

the prototype radar system. The relief sought is from the prohibition on companies using model aircraft in their 

business operations. This relief is very limited, since the model aircraft is used in development of a radar, not 

for any other purpose. 

Regulations from which relief is sought:

Raytheon is seeking relief from a number of sections under Title 14 of the Code of Federal Regulations, 

including: 

14 CFR Part 21 – Airworthiness Certification, subpart H

14 CFR Part 61 – Certification: Pilots, Light Instructors, and Ground Instructors
Page 2 of 12

14 CFR Part 91 – General Operating and Flight Rules

91.103(b)(2) – Preflight action

91.105 – Flight crewmembers at stations

91.109 – Flight instruction

91.119 – Minimum safe altitudes

91.121 – Altimeter settings

91.151 – Fuel requirements for flights in VFR conditions

91.405 – Maintenance required

91.407 – Operation after maintenance

91.409 – Inspections

91.417 – Maintenance records

Without such relief, Raytheon would not be allowed to use the aircraft for its independent research and 

development work. 

4. Reason for Relief – Proposed Operations: 

The proposed testing requires use of an airborne camera and radar reflector. The camera is off-the-shelf 

technology, as is the UAV, and this is key to keeping costs low and delivering results quickly. 

The model aircraft will be equipped as stated above and flown in the very limited areas described below, several 

of which are on secure Raytheon property for testing of a Raytheon radar system and other advanced defense 

technologies under development at Raytheon’s Pelham, New Hampshire facility. Three of the test sites selected 

are parking lots or open areas that are on Raytheon facilities, which are fenced in and have restricted access. 

One other area is open public space adjacent to a Raytheon facility and the final test site, which is only to be 

used as a backup if no other site is viable, is a UAV test range. Since the proposed operations will comply with 

the amateur UAV user parameters – line of sight operations and no operation above 400 feet – the restricted

access to the flight areas should ensure that there is no burden on the national airspace and no impact on other 

aircraft.

Details of the proposed operations are set out below.

A. UAS System

a. Aircraft Performance and Performance Limitations

b. Operating Procedures

c. Aircraft loading information

Make: DJI 

Model: Phantom 2 (P330Z)

SN: PH645428134

Technical Specifications: 

Diagonal Wheelbase: 35cm

Phantom 2 Takeoff Weight (w/o payload): 1.16 Kg

Payload Weight: 1.3 Kg

Battery Power: LiPo 5200 mAh

Estimated Hover Time: 15min (@5200 mAh & 1.2 Kg Takeoff Weight)

Video Transmitter power: 500 mW

Video Transmitter frequencies: 5.705-5.945 GHz

Communication distance: 500 meters (operations limited to 100 m radius)

B. Pre-flight inspections, maintenance, repair

In accordance with manufacturer instructions we will follow the following instructions to the letter: 
Page 3 of 12

Figure 1. Phantom 2 Vision User Manual Flight Instructions, © 2013-2015 DJI, page 24.

Further, to ensure safe operations, the program will also follow the AMA Radio Control Large 

Model Airplane Program pre-flight inspection checklist, as shown in Attachment A.

C. RF spectrum to be used for control of UAS

The program will use the Futaba 8J controller for remote control operations. It uses the 2.4 GHz 

unlicensed band configured for RC controllers. The controller is FCC certified. This controller has 

a special feature. The UAV has an autonomous operation capability. If communication between 

the UAV and the controller is lost, or if the battery is running low, the UAV has a “return to home” 

function. The UAV will activate the function autonomously if communication with the controller 

gets too weak or if the UAV determines its battery life requires return to the home station to ensure 

safe arrival at the home station before battery exhaustion. Furthermore, if the controller is somehow 

dropped or broken, the UAV will also return to the home station. If the person in control of the 

UAV wishes to manually activate the home function, that capability is also available. This would 

be done if the UAV is operating out of the ordinary or if there is any issue with UAV control. The 

operator just pushes the home button and the UAV will return home. 

D. Associated equipment that will be part of UAS – sensors, cameras, etc.

The payload for this operation is a GoPro camera that operates at 5.8 GHz. The camera will have 

the capability of transmitting video when the UAV is in flight. A radar reflector that would be 

lightweight plastic or metal could also be on the UAV. It would be used for advanced radar 

development. 

No ground-based moving target offers the opportunity to test the capabilities required, only a target 

in motion in the air allows the radar to perform as necessary for its advanced development. That is 

why this UAV use is necessary.

E. Pilot In Command 

a. Qualifications of person who will be directly responsible for operation of UAS

Private Pilot since 1973: Single Engine Land: Various Single Engine Aircraft

Pilot has flown his own Personal, UAS Quadcopter for more than 1 year

b. Level of airman certificate held 

Private Pilot, Single Engine Land
Page 4 of 12

c. Applicable training related to the operation 

The pilot has trained and been licensed and certificated as a pilot. He has personal 

experience only in UAS systems. 

d. Minimum hours of flight experience 

Over 200 hours of flight experience

e. If operation will use visual observers, describe their roles and qualifications

The remote control operator will be the observer for all flight operations.

f. Medical standards and certification of the person(s) directly responsible for operation of the 

UAS.

Yearly Physical

F. Safety:

a. How operations will not adversely affect safety: The proposed operations are limited in 

time and scope. Testing will take place only on limited work days, when the radar testing is 

underway. The testing will be limited to 15 minute increments, which is the power 

limitation of the UAV. The areas selected, described in more detail in this Petition, are 

protected from public access, and are isolated areas, even on the Raytheon properties. No 

operations are proposed that would cause any sort of hazard.

It is important to note that the Phantom 2 is equipped with a failsafe feature that causes the 

UAV to return to its “home position” if there is any danger. A description of the feature, as 

set forth in the User Manual is below:

Figure 2. Description of Failsafe Function from Phantom 2 User Manual © 2013-2015 DJI, at p. 25.

b. How operations will provide a level of safety at least equivalent to that provided by the rule 

from which exemption is sought: The rules from which exemptions are sought are the rules

that precludes this UAV operation by this operator – Raytheon. The current rules preclude 

a business from operating the UAV, although the rules would allow an amateur to operate 

the same UAV, under less restricted circumstances. So, to ensure the proper level of safety, 

the proposed operation will be strictly in accordance with the already-permitted amateur 

operating guidelines, only by a company that needs to use the platform to expedite 

development of a radar system. Because Raytheon has a regulatory compliance program, 

the level of safety of operations will be followed strictly, leading to a level of safety at least 
Page 5 of 12

equivalent to that which results from amateur operations of the same UAV platform. Preand post-flight safety checks and operation by a licensed pilot will also ensure that the level 

of safety for these operations will be at least equivalent to the rule that allows amateur 

operations of this UAV.

The Phantom 2 has a compass calibration feature and built in GPS which help to ensure 

control and effective navigation of the UAV. Further, the Phantom 2 operates primarily in 

hover mode, which makes it easy to control. The UAV has a maximum tilt angle of 35 

degrees, and it will be operated at far less than its maximum speed. Because of these 

features, the UAV will be kept close to the operator, always in sight of the operator, and 

under control at all times.

c. Plans to implement clearly defined operational borders and procedures to ensure public 

safety, which includes persons and property both in the air and on the ground: The 

operational borders are in place because of the areas of operation selected. Those areas are 

contained on secure Raytheon facilities, with the exception of Area 4, which is a designated 

UAS test-site. The Raytheon facilities, which are the top priority sites to use, are fenced off 

from the general public, with secure access required, and all entrances to the property are 

gated with security at the gates. The area of operation is wholly contained within the 

Raytheon facilities, and the areas chosen on the Raytheon property are remote and unused. 

The areas were selected because of their remote and unused condition. Further, Raytheon 

will post signs around the operational area prior to test operations to ensure that no people 

will be exposed to any potential harm. In addition, because the area of operations is small 

and the operator will be within sight of the UAS at all times, the operator will be able to 

also watch out to protect any Raytheon employee who might be in the test area 

unexpectedly. 

The low mass and low speed of operation for this UAV will also ensure that there is no 

harm to any individual in the area of operation. 

G. Flight Characteristics

a. Maximum operating speed: The maximum speed of the UAV is 15 m/second (about 33

miles per hour). The UAV will NOT operate above 20 miles per hour. The UAV device

will take off and be used primarily to move in a small area around the controller to allow for 

development of the radar and defense technologies. For that testing, the UAV does not 

need to move very much, in fact it would impede the operation of the radar testing if it did. 

The hover capability of this UAV is the reason that the program chose a quadcopter rather 

than a fixed wing aircraft. There will be some side-to-side movement 30-40 meters either 

direction, but the testing design calls for the UAV to remain primarily in one general area at 

the test facility. The flight pattern will be either an oval or a figure 8 pattern over the test 

area. The maximum speed used in testing could go as high as 20 miles per hour. 

b. Altitude: Below 400 feet.

c. Describe minimum flight visibility: No flights will be conducted if the weather visibility is 

less than 3 miles from the control station. If the visibility is 3 miles or greater, and wind 

conditions allow for safe flight, flights may be conducted as necessary.

d. Distance from clouds for intended operations: The normal cloud ceiling in this area is 

above 3000 feet, and the maximum altitude of flight will be below 400 feet. If it is a cloudy 

day, they will not fly anyway. Further, there will always be visual line of sight between the 

operator and the UAV.

 
Page 6 of 12

e. Potential hazards and safety mitigations: The mass of the UAV is low enough that the 

device does not pose much of a safety hazard. The testing area will be cleared of any 

people who are not part of the test prior to any operations. The operator will ensure that 

the UAV operates clear of trees, power lines, buildings, street lights, and other obstructions. 

The failsafe in the UAV will help to ensure that the UAV does not land away from the 

operator, because it will return to home rather than lose signal or power.

H. Characteristics of Area of Intended Operation

a. General Description: The areas selected for operation are three open areas on Raytheon 

property, where there are no people and the actual area of operation would be away from 

buildings. The fourth site is adjacent to Raytheon property and unused. The fifth site 

selected is a UAV test range that would only be used if none of the other sites was 

available. 

The Raytheon sites: Pelham, Raytheon HQ, and Sudbury are all on property that is securely 

fenced off from public access. To gain access to the property, any visitor would have to go 

through security at the main gate. The security of the facility is high because of the nature 

of work that Raytheon conducts. There will be no passers by entering the test area. 

Further, no general public vehicle traffic will be in the area. 

MDC is at a Raytheon property in Woburn, Massachusetts. The test area is public land 

behind the Raytheon property, and the area is generally not accessed by the public. This 

site is not expected to be in use very much for the testing, but it was added in case its 

location is necessary for the geometry testing of the radar.

The UAV test range is not on Raytheon property, but it is a known UAV test range, and as 

such it is known to the public as a place where UAVs are flown. Raytheon, if it uses this 

site at all, will used enhanced precautions to ensure that there are no hazards present during 

any flights conducted there.

b. Google Earth images of each of the five test areas are below:

Site Locations (Lat, Long, & Alt -ft)

Site0: 42.737013°, -71.354670°, 412

Site1: 42.637037°, -71.249763°, 197

Site2: 42.521533°, -71.141729°, 107

Site3: 42.364951°, -71.430758°, 159

Site4: 42.616659°, -71.510590°, 204

The Figures 3-7 are taken from Google Earth, depicting the site locations with a 100 meter 

radius from the site coordinates. The radius is for informational purposes only, since the 

quadcopter will not fly throughout the whole radius. At the MDC and Sudbury sites, 

operations will be limited to the sectors shown, to ensure additional safety. When the 

quadcopter is in use, it will fly/hover in a very limited portion of the area shown. These 

images are presented to allow the reviewer to see that the areas selected are away from 

people and mostly away from buildings. In those areas, the quadcopter will fly in an oval or 

figure eight pattern, if it is not simply hovering.
Page 7 of 12

Figure 3. Pelham Site

Figure 4. Raytheon Headquarters – back parking lot, showing potential flight pattern
Page 8 of 12

Figure 5. MDC, showing potential flight pattern

Figure 6. Sudbury location, showing a potential flight pattern

8

8
Page 9 of 12

Figure 7. UAV test range

c. Associated potential hazards:

Pelham: None.

Raytheon HQ: None

MDC: None

Sudbury: None

UAV test range: None

d. Proximity to populated areas: The area of operations will be limited to the open spaces in 

the sites selected. Operations will be controlled by a licensed pilot, and the operations will 

avoid any buildings. This is essential not only for the safety of flight and the people in the 

buildings, but any flight near a building could interfere with the radar experimentation that 

is the purpose of the flight. 

I. Proximity of any Airports

Site-by-site assessment of airport proximity: 

Pelham Site – The Pelham site is near the Steck Farm Airport, which does not appear to have a 

runway, although there do appear to be some bi-planes parked at the farm, and they may use the 

field as their runway.

Raytheon HQ – About 4.5 miles from the headquarters location, to the northeast and in the 

Merrimack River is the Merrimack Valley Seaplane Base. There are no other airports or heliports 

nearby.

MDC – No nearby airports. There is a “digital heliport” within about 2 miles, but on closer 

inspection, it does not appear to be a heliport at all, since there are no markings for use by aircraft in 

the parking lot.
Page 10 of 12

Sudbury – Nearby airports: there is an old airstrip is nestled in the woods about 1.5 miles from the 

Sudbury location, but it appears to be in disrepair and not used. Also, the Marlboro Airport is 

approximately 5 miles from this test site. It is a public airport with one runway that averages about 

37 flights per day. 

UAV Test Range – The only aircraft facility within five miles of the UAV test range is the Nashoba 

Community Hospital Heliport. The next nearest airport is Pepperell Airport which is between 7 and 

8 miles away from the UAV test range. Pepperell is a private airport, used largely for sky diving 

activities. While the airport is open to general aviation, not commercial, and pilots must call first to 

use the airport. 

Summary Analysis: After review of the nearby airports, and given the height limitation of the UAV 

flights (400 feet or less) there is no anticipated concern that any UAV operations will pose a hazard 

to any airport or flight operations. 

J. Operation in Visual line-of-sight in accordance with Section 333(b)(1)

The operations will operate with visual line of sight. The UAV will never be out of sight of the 

operator. Because the area of operations will have a radius of 100 meters, with the expectation that 

the UAV will hover more than it will fly, the UAV is expected to be much closer to the operator 

than 100 meters. The areas selected for operation, as shown in figures 3 - 7, are open areas with no 

obstacles or obstructions to view. These areas were selected both for the safety of flight 

characteristics, but also because open areas are required for the testing to be effective. Figures 4, 5, 

and 6 also include overlays which show the possible flight paths of the UAV at those test sites. The 

UAV operations will be limited to oval (race track) paths or figure eight paths, to keep the UAV in a 

discrete area away from any obstacles, buildings, or people. Further, these flight paths are ideally 

designed for the radar development operations that are the purpose of the UAV flights.

The pilot in command of the UAV will maintain visual contact with the UAV as well as having 

control of the RC controller to direct flight. Finally, the pilot in command will have the ability to 

trigger the “home” command if at any point safety requires it. 

K. Procedures for pre-flight safety risk assessment to comply with 14 CFR Section 91.7(b) 

The pilot, along with the UAV team, will conduct a pre-flight safety risk assessment prior to any 

operations. The procedures will include:

Checking and monitoring weather conditions every 15 minutes the day of flight to ensure that wind 

conditions will not allow loss of control to the UAV.

Checking visibility to ensure that the minimum visibility will be maintained throughout each 15 

minute scheduled flight.

Inspecting the chosen flight area for obstacles, people, or valuable property. Adjusting the flight 

area to avoid any obstacles or people to ensure the safety of all.

Prior to each flight, the flight area will be cordoned off with signs posted that a flight is in progress 

and that people should avoid the area. This will protect any Raytheon staff from inadvertently 

entering the area during a flight, thereby minimizing any chance of risk to humans.

Further, to ensure the airworthiness of the aircraft, the pilot will conduct all of the pre-flight safety 

checks and inspections listed in the AMA manual – see Attachment A – and in the aircraft user 

manual – See Figure 1, above – before every flight. 
Page 11 of 12

Raytheon’s proposed testing would fly the quadcopter in specifically designated areas, below 400 

feet, to allow work on advancement of the radar system. 

The central radar, where system development is taking place is located at: Pelham, New Hampshire 

- Site0: 42.737013°, -71.354670°, 412 ft AMSL

The operations would be conducted by a specialized team of operators who are expert in use of the 

quadcopter as well as very familiar with the FAA’s requirements for see and avoid procedures with 

regard to any and all other aircraft operating in the nearby National Air Space. 

5. How would this request benefit the public as a whole:

The proposed operations will deliver a high quality technology to potential US government customers at a rapid 

rate and economical cost. This benefits the public by delivering advanced technology rapidly that will enhance 

national security. Further, the use of commercial off the shelf components as a platform for developing the 

radar system will save tax payer dollars over development of a customized UAV as the platform for the radar 

simulator. Further, there is no harm to the public from the proposed operation. The goal is to use this UAV as 

part of a research experiment, not as a device for hire. 

The whole purpose of the operation is to use the UAV as a platform that will advance the development of a key 

radar system. Testing of this UAV is not the reason for this request. The experimentation is devoted to radar

system development. Advances in the radar system will prove fruitful for Raytheon’s DOD customers.

6. Reasons why this exemption will not adversely affect safety or how this exemption will provide safety 

at least equivalent to the existing rule:

The proposed operations will be conducted by a licensed pilot who is very familiar with the FAA’s rules on 

UAS operations. 

Use will be limited to the greatest extent possible, and the burden on the national air space will be as low as 

possible, since flight operations will only take place to advance the science of the radar. The primary locations 

for this testing are on Raytheon plant sites, and not at publicly available spaces. The areas selected, as described 

above, are fenced off from the public and only personnel with proper authority are allowed on site. With the 

low altitude of flight, there is no chance of any interference with any aircraft or other UAVs.

Further, testing will only be conducted sporadically, in good weather conditions, and by personnel who are 

experienced with the need to protect the national air space using see and avoid techniques. 

The operations will be conducted by a certificated airman with many years of experience as a pilot. His 

experience in conducting pre-flight and post-flight inspections will prove invaluable to ensuring that the flight 

operations are conducted in compliance with all procedures. Further, his experience will also prove invaluable 

in ensuring that the flight operations will be conducted in accordance with the proper diligence and care. 

This level of experience and attention to proper procedure is essential to ensuring Raytheon’s compliance with 

the FAA’s regulations. Since these aircraft are otherwise flown by amateurs for recreational purposes, in areas 

which may not be controlled, the proposed exemption will provide safety at least equivalent to the existing rule.

7. Summary:

Raytheon is seeking an exemption from the FAA for the use of a commercial-off-the-shelf UAV to speed the 

development of advanced defense technologies. The use of the UAV will allow for rapid prototyping of a radar 

system and speed the troubleshooting of various technical issues by using a radar reflector that will test the radar 

performance. 
Page 12 of 12

The exemption request seeks authorization for use of the DJI Phantom 2 Quadcopter to carry the radar reflector 

and a GoPro camera that will assist in operations. The FAA’s current regulations preclude a business from 

using an amateur UAV in their business operations. Because the aircraft does not yet have an airworthiness 

certificate, this petition seeks to waive various FAA regulations regarding the use of certificated aircraft. 

However, the key to the testing is that Raytheon will be using a UAV that is widely available to amateur users, 

and Raytheon will be using the UAV in highly controlled environments and with stringent safety protocols. 

Raytheon will utilize the experience of a licensed pilot to command the operations of the aircraft. The aircraft 

will operate below 400 feet in altitude. The aircraft in question has a homing feature which will ensure that it 

never loses power far from its starting point and which ensures that it will not fly out of range of the controller.

Operations will be limited to visual line of sight, with an emphasis on see-and-avoid procedures being followed. 

Flights will be sporadic and limited to 15 minutes at a time, not constant, and certainly not daily. Furthermore, 

the UAV will only be in use during the workday, not at night nor on the weekends.

Grant of this Petition for Exemption is in the public interest because it will advance the radar science through 

the use of innovative technology, at a lower cost to the public and at a quicker pace that is important for our 

nation’s security. Further, the proposed operations, which include command by a trained pilot, do not pose a 

greater risk to the public than operations already taking place by amateurs. 

This Petition does not seek an exemption for use of the UAV for hire. It is simply a highly efficient tool for 

advanced development of a radar technology which is important to the US Department of Defense.

Conclusion:

For the foregoing reasons, Raytheon IDS respectfully requests that the FAA grant this Petition for Exemption to 

allow it to operate a UAV platform for the rapid and cost-effective development of its advanced radar system. 

Raytheon IDS will take all precautions to protect the national airspace, as described above. Should you have 

any questions or need further information, please contact me.

This request is vital to our national security. Thank you very much for your consideration. 

Sincerely,

Karen Dyberg 

Spectrum Manager

Raytheon Integrated Defense Systems
Large Model Airplane Program—Preflight Checklist

Page 13 of 29

GUIDELINES FOR LARGE MODEL AIRPLANE INSPECTIONS

No one can predict equipment failure or pilot error in the flying of radio controlled airplane. 

However, if the following preliminary precautions are met, equipment and structural failures can 

be minimized.

Whether you are the owner of a LMA or an appointed LMA Inspector, you will evaluate every

aspect of the airplane awaiting certification.

The following is considered the criteria for certification of Large Model Airplane:

Check List for Preflight Inspection

1. UN-ASSEMBLED INSPECTION

1.1 WING GROUP

( ) Fuselage attachment points

( ) Strut attachment points

( ) Rigging wire attachment points

( ) Servo mounting

( ) Pushrods/cables and actuating links

( ) Control horns

( ) Control surface hinges and area around hinges

( ) Undercarriage integrity and attachment points

( ) Structural integrity overall

( ) Covering integrity

1.2 FUSELAGE GROUP

( ) Wing attachment points

( ) Undercarriage integrity and attachment points

( ) Servo mounting

( ) Pushrods/cables and actuating links

( ) Control horns

( ) Control surface hinges and area around hinges

( ) Fin and rudder assembly

( ) Horizontal stabilizer assembly

( ) Bracing/strut attachment points

( ) Structural integrity overall

( ) Covering integrity
Large Model Airplane Program—Preflight Checklist

Page 14 of 29

1.3 ENGINE(S)

*( )Propeller secure and undamaged

*( )Spinner secure and clear of propeller blades

*( )Engine mounting and accessories secure

*( )Cowling attachment

*( )Magneto switch functioning and OFF

*( )External servicing points (fuel, plus, etc.)

1.4 RADIO EQUIPMENT

( ) Receiver installation

( ) Battery installation

( ) Antenna installation

( ) Switch installation

( ) Wiring and plugs clean, undamaged and secure

2. ASSEMBLED INSPECTION

2.1 GENERAL

( ) First ensure that all components fit together correctly, and that no undue strain is

needed to achieve proper alignment.

2.2 RIGHT WING

( ) No non-design twists or warps

( ) Wing tips true

( ) Wing leading edge

( ) Struts and rigging secure

( ) Attachment to fuselage

( ) Undercarriage attachment

( ) Alignment of control surfaces

2.3 FUSELAGE AND TAIL GROUP

( ) Horizontal stabilizer attachment

( ) Fin and rudder attachment

( ) Struts and bracing secure

( ) Alignment of tail group with respect to wing

( ) Alignment of control surfaces

( ) Tail wheel assembly

( ) Canopy
Large Model Airplane Program—Preflight Checklist

Page 15 of 29

2.4 LEFT WING

( ) No non-design twists or warps

( ) Wing tips true

( ) Wing leading edge

( ) Struts and rigging secure

( ) Attachment to fuselage

( ) Undercarriage attachment

( ) Alignment of control surfaces

2.5 MISCELLANEOUS

 ( )Center of gravity

*( )Correct movement and centering of all control surfaces

*( )Battery charge, fuel, air pressure all sufficient

2.6 CHECKS WITH ENGINE(S) RUNNING

*( )Airplane secure before start (tied down preferred)

*( )Engine performance and reliability

*( )Propeller and spinner balance

*( )Minimal airplane vibration

*( )Radio reliability

*( )Radio range check

The above check list is to be completed by the owner of a LMA or an appointed inspector prior 

to test flights. All items are to be marked “N/A” if not applicable, checked if passed, or left blank 

pending re-inspection if failed.

The Check List is subsequently used by the operator of the airplane:

(a) Once at the beginning of a flying session (all items)

(b) Before every flight (items marked with an * only)
Large Model Airplane Program—Preflight Checklist

Page 16 of 29

PREFLIGHT CHECKOUT TEST

(Should be completed prior to each flight)

CONTROL SYSTEM:

( ) Perform a range check with your radio. Use the recommended range check distances as 

described by the radio manufacturer as a minimum test range requirement. Perform the range 

check, without the engine operating, to the maximum range achievable without control 

degradation. 

( ) Run a similar check with the engine operating at power levels from idle to maximum power. 

If there is range degradation with an operating engine there is an issue with ignition noise and/or 

a vibration induced problem. Do not fly until this is resolved. ANY reduction in range means a 

loss in signal/noise ratio and a chance of control loss in flight.

The engine off/engine on test should be conducted prior to each flying session since degradation 

of shielding and spark plugs with usage is a historical fact.

( ) Check servo operating for erratic performance, especially with the engine(s) operating. Be 

sure they operate smoothly throughout the entire control range. Apply hand load to surfaces 

while being moved by transmitter action to check for non-flexing of control cables/rods.

( ) Transmitter battery life MUST have been previously established by a discharge test, prior to 

first flight.

( ) Keep a daily record of transmitted "ON" time.

( ) Check the state of charge of the flight battery packs, UNDER LOAD, just prior to each 

flight. Flight battery packs MUST have been previously checked for design capacity prior to first 

flight.

( ) Check the function of the fail-safe system by turning off the transmitter and observing the 

results.

VEHICLE:

Thoroughly inspect the airplane and components for assembly and for structural integrity.

( ) Inspect the wing and tail assembly for signs of structural failure.

( ) Examine all control surface hinging for design integrity.

( ) Examine servo mounting and retention screws or bolts.

( ) Examine all push rods and keepers.
Large Model Airplane Program—Preflight Checklist

Page 17 of 29

( ) Be SURE there is no looseness or slop in the control components.

( ) Check the mounting provision for tightness and security of all components that are 

removable for transporting to and from the flying site.

( ) Inspect fuselage for signs of potential failure or damage during previous flights or 

transporting.

( ) Check servo installation and be sure the servo arm retention screws are tight.

( ) Inspect receiver/servo wiring for integrity and see that all plugs connecting the components 

are taped or in some way protected from vibrating apart. Include battery pack plugs.

( ) Check to see that receiver antenna(s) are routed away from servos. Vertical orientation of 

antenna is preferred.

( ) Check for NO STRAIN on antenna/receiver connection.

( ) Examine landing gear mounting and function. (retract/steering)

( ) Examine fuel tank(s) installation for adequate support, isolation from vibration and ZERO 

leakage. Special care must be given to gasoline systems in view of the increased fire hazards 

involved.

ENGINES:

( ) Inspect mounting for looseness, cracks or evidence of degradation.

( ) Check for loose bolts, muffler looseness, routing and integrity of ignition wiring, etc.

( ) Check propeller(s) and installation for tightness. Propellers must have the edges rounded to 

prevent hand cuts on starting. Always use a glove or engine starter.

( ) Check spinner(s) for tightness or cracks. (Loss of a spinner and/or propeller in flight can 

quickly generate a panic situation).

( ) Inspect cowl area for loose nuts and bolts.
Large Model Airplane Program—Preflight Checklist

Page 18 of 29

ENGINE RUN-UPS:

( ) Exercise extreme caution when starting and operating engines. A starter is preferred to avoid 

hazards to the hands or body.

 Securely restrain the vehicle. Do not allow ANYONE to be positioned in the plane of

rotation of the propeller(s).

 The use of safety glasses is encouraged. Avoid loose clothing, transmitter straps, etc. that 

might engage the propeller.

( ) Always have a FIRE EXTINGUISHER available when operating gasoline engines.

( ) Start the engine(s) and check for proper idle.

 

( ) Be sure that the engine(s) operates at desired top end R.P.M. and does not sag with prolonged 

running, from inadequate cooling.

PILOT STANDARDS:

The inspector will review the pilot’s skill level at the same time as the model’s qualification 

flight.

Safe operation is a mixture of several ingredients: design, construction, pre-flight check-out and 

the pilot. A proficient pilot can often avoid a disaster when power failure, partial loss of control 

or many other incidents occur. The larger the airplane is, the more it will fly like a full-scale 

airplane than smaller models. Control and engine(s) response are quite different from smaller 

airplane.

The following constitutes the standards for pilots of airplanes in the LMA-2 classification:

( ) At least five years background in model design, construction, and/or piloting of radio 

controlled model airplane.

( ) Has demonstrated successful flying experience of LARGE heavy models in excess of 40 

pounds. 

( ) A demonstrated ability to recognize stall and loss of aerodynamic control.