Request for Exemption from 14 CFR 119.1(e)(6) for American Aviation
Information provided by ATK Launch Systems Inc., prime contractor for LUU Flares, outlines the history of LUU flares and the need for an exemption from aviation regulations to continue using a test site for Lot Acceptance Testing (LAT). The test site, located 45 statute miles from the nearest town, plays a crucial role in ensuring the safety and performance of LUU flares through controlled testing operations. The request seeks relief from the 25 statute mile limit to maintain operations critical for US military and SAR missions.
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Supporting Data and Information for American Aviation Request for exemption from 14 CFR 119.1(e)(6) Provided by ATK Launch Systems Inc. Prime Contractor for LUU Flares to US Government 1
History of LUU Flares The LUU-2/B visible light flare was initially certified for US DOD operational use in the late 1960 s and was used extensively in the Vietnam conflict. The LUU-19 flare was qualified for use by USAF in 1999 The production site at Promontory has produced over 1.8 million LUU flares Over 300 flight tests have been performed for acceptance by the US government LUU flares have been and continue to be supplied to more than 25 governments around the world. ATK on a consistent basis, responds to global Government requests for cooperation to integrate the LUU flares into new platform applications The experience gained from 40 years of flare production has yielded continuous process and design improvements that make the safety and performance of the ATK LUU flare the best in the world Combat Support 2
Test Site Overview and Reason for Request Proposed 45 statute miles from BMC 25 statute mile limit from BMC BMC An exemption is sought from 14 CFR 119.1(e)(6) which states part 119 does not apply to: Nonstop flights conducted within a 25 statute mile radius of the airport of takeoff carrying persons or objects for the purpose of conducting intentional parachute operations. Relief from the 25 statute mile limit to the extent of 45 miles is necessary to continue using the legacy test site that is used for the purpose of performing the flight requirements for Lot Acceptance Testing (LAT) for LUU flares. Each lot of flares produced must undergo LAT to demonstrate proper function per US DOD specifications before being delivered to the US DOD and/or one of 25 other foreign government customers. The LUU flares have been manufactured and tested, with FAA approval, in Utah for over 40 years to support both US Military operations and life saving search and rescue (SAR) operations by providing broad field illumination at night. Only recently during the renewal of the American Aviation s Special Permit 7648 were we notified by the local FSDO that parachute operations are to be limited to within 25 statute miles of the airport of take off and that 14 CFR 119.1(e)(6) cannot be waived. Because of this, we have been unable to meet the current needs of the United States of Defense . 3
Typical Flight Path During Testing Typical flight path Ideal Drop zone (approx.) The figure above illustrates the drop zone and flight path that is used during the flare test operation. Dropping within the zone is coordinated between the pilot and test conductor on the ground. The pilot will fly a heading thru the drop zone and the test conductor will issue the drop command to the pilot via radio. ATK desires to use the historical test site as it consists of property owned by ATK and property for which ATK has land use agreements in place. The benefits of this test site include its isolation from inhabited areas (~15 miles from the nearest town of Kelton, UT or Snowville, UT) and limited vegetation. The limited vegetation aids in the recovery of tested hardware as well as reduces the risk of fire. By allowing the exemption, continued use of the isolated and controlled drop site ATK maintains a high level of public safety. 4
Flight Plans and Notifications During Testing The site has been safely used by ATK Launch Systems Inc., and Thiokol Corporation in coordination with American Aviation for 12 years and Sunwest Aviation, respectively for several years preceding. Prior to each drop campaign a NOTAM (see draft at left) is sent to the following organizations: -AREA SUPERVISOR, FAA PRESCOT -HILL AFB RANGE CONTROL -HILL AFB BASE OPERATIONS -FAA SLC CENTER -ARTCC MILITARY OPERATIONS SPECIALIST -HILL AFB CLOVER CONTROL -HILL AFB COMMAND POST A general notice of operation is also sent to: -BOX ELDER COUNTY FIRE MARSHALL -BOX ELDER SHERIFF'S OFFICE -UTAH DNR, SOVEREIGN LANDS SPECIALIST -BEAR RIVER HEALTH DEPARTMENT 5