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U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Under Section 333 of the FAA Modernization and Reform Act of

2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FAA Reform Act”) and 14 C.F.R. Part 11, AeroVironment, Inc. (“AV”) requests exem ptions from several provisions

of the Federa l Aviation Regulations (“FAR”), specifically portions of 14 C.F.R. Parts 45 , 61, and

91 to allow, among other things, commercial operations of its Puma AE DDL unmanned aerial system (“Puma”) in remote and rural a reas of the United States , as further defined herein, by a Pilot in Command holding a private pilot certificate

. 1

The Puma is an all

- environment, electric

- powered, hand

- launched

, small unmanned aerial system (“UAS”) that, depending on its payload, is capable of transmitting live airborne video images and location information to a Ground Control Station ( “ GCS ” ) or conducting high resolution photogrammetry or Light Detection and Ranging ( LIDAR ) data collection. If used for

h igh resolution photographs an d LIDAR data , the Puma store s the photographs and data on board and makes them available for download after completion of the flight. The Puma has a maximum weight of 15.5 pounds, a wingspan of 9.2 feet, and a length of 4. 7 feet. The Puma’s

minimum cruis ing speed and maximum speed are 36 feet /s and 69 feet /s, respectively. It is battery powered, has a flight endurance between two and three and one

- half hours, can operate in temperatures ranging from

- 22 ° F to 122 ° F

, and ca n be either hand

- launched or launched

from a rail launcher system to remove possible inco nsistencies with hand

- launching. The

Puma’s omni

- directional antenna has a range of 6.2 miles , and its directional antenna has a range of 12.4 miles

. 2

The Puma is unique among the various UAS s ap plying for exemptions under Section 333

because it has receive d a restricted category type certificate from the FAA based on its

1 AV has filed an e xemption request under Section 333 in FAA Docket 2014

- 0715 . This exemption
request is materially different than the prior exemption application in its definition of areas where the Puma will operate and the licensing requirements for the PIC (private pilo t)

. Additionally, this exemption

would rely on the Certificate of Authorization (COA) process to identif y the specific areas where

commercial operations will take place.

2 For more detailed information on the Puma’s specification, AV directs the FAA to its type certificate data sheet Q00018LA. AV also incorporates by reference all of the materials submitted in support of its application for a Restricted Category Type Certi ficate , Q00018LA, and Certificate of Waiver or
Authorization, 2014

- AHQ

- 100.U.S. Department of Transportation September 24, 2014 Page Two

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. 3 The Puma has an unparalleled safety record based on this experience . When its experie nce is considered in tandem with the remote and rural areas in which it will operate, it becomes clear that the Puma can operate safely in the N ational

A irspace S ystem (“NAS”) , without posing a threat to national security, by operating in

accordance with the requirements discussed herein.

The Puma’s capabilities, along with AV’s experience to date , make it ideally suited to conduct commercial operations such as agriculture, aerial surveying

, and patrolling in remote area s ( i.e.

non

- congested or sparsely po pulated areas, private or controlled

- access property ) under Class E or Class G airspace and within Visual Line of Sight (“VLOS”) . Some Class D airspace may be

used on a case

- by

- case basis and would be further defined during the COA process

. Use of the

Pu ma reduces the need to operate manned aircraft, decreasing the r isk to the pilot

, c rew , and those on the ground as the Puma is carried to the site and not flown there with a load of

flammable fuel

.

As a result of the Puma’s size, weight, maximum speed, op erational capability, and safety

record ; the distance at which it will operate from airports and populated areas ; and its operation using visual observers to provide deconfliction from other air traffic

, the Puma does not create a

hazard to users of the NAS or the public . Neither does it pose a threat to national security. Therefore, the FAA should grant AV the requested exemptions. Alternatively, if the FAA finds that modification of AV’s application is required for safe operation of the Puma in the N AS , AV requests that the FAA delineate the required modifications and either process AV’s application as if the modifications were already made or allow AV to amend its application to incorporate the FAA’s findings.

The name and address of the applicant ar e:

AeroVironment, Inc. Address: 900 Enchanted Way, Simi Valley, CA 93065 Attn: Andy Thurling Attn: Doug Scott Ph: (805) 581

- 2198 ext. 1892 Ph: (805) 581

- 2187 ext. 2694 Fax: (805) 581

- 4512 Email: scott@avinc.com Email: thurling@avinc.com

AV’s exemption request encompasses the following regulations: 4

3 FAA, Press Release, FAA Approves First Commercial UAS Flights over Land (June 10, 2014)

, http://www.faa.gov/news/press_releases/news_story.cfm?newsId=16354

. A copy of the Restri cted Category Type Certificate is attached as Exhibit 1.

4 Based on a recent legal interpretation, AV does not believe that it needs an exemption from 14 C.F.R. §§ 91.9(b), 91.203(a), and 91.203(b) because the Puma’s flight manual, airworthiness exemption, and registration certificate will be maintained at the pilot’s control station. FAA Legal Interpretation from Mark W. Bury, Assistant Chief Counsel for International Law, Legislation and Regulations (August 8, 2014).

Should the FAA determine that an exe mption is required, AV respectfully requests one on the basis that similar exemptions have been granted on numerous occasions. See Exemptions 8607, 8737, 9299,
9565, 9665, 9789, 9797 10167, 10602, 10700, and 32827.U.S. Department of Transportation September 24, 2014 Page Three

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- 7899 WWW.COOLEY.COM 14 C.F.R. § 45.23(b) 14 C.F.R. § 61.113(a) and (b) 14 C.F.R. § 61.133(a) 14 C.F.R. § 91.7(a) and (b) 14 C.F.R. § 91.109(a) 14 C.F.R. § 91.119 14 C.F.R. § 91.151(a) 14 C.F.R. § 91.405(a)

14 C.F.R. § 91. 407(a)(1) 14 C.F.R. § 91. 409(a)(2) 14 C.F.R. § 91. 417(a)

Section 333 ’s Mandate and the Federal Aviation Act

G rant of this exemption application for use of the Puma in agriculture, precision aerial surveys

, and patrols, p ursuant to the exemption requested herein, will advance the Congressional

mandate in Section 333 of the FAA Reform Act to accelerate the introduction of UASs into the

NAS. Section 333 directs the Secretary of Transportation to consider whether certain UAS s may operate safely in the NAS before completion of the rulemaking required under Section 332

of the FAA Reform Act. To make that determination, the Secretary must evaluate which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of several criteria :

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

FAA Reform Act § 333(b )(1). Once the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace sy stem.” Id. § 333(c) (emphasis added). 5

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 49 U.S.C. § 44701(f). This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §4 0101 of the Act, from the requirement s that all civil aircraft must have a current

airworthiness certificate , 49 U.S.C. § 44711(a), and those used in commercial service must be piloted by commercial pilots. 14 C.F.R. § § 91. 61.113(a) and (b), 61.133

.

The grant of the requested exemption is in the public interest based on (i) the clear direction in

Section 333 of the FAA Reform Act; (ii) additional authority in the Federal Aviation Act, as amended; (iii) the strong equivalent level of safety surrounding th e proposed operations; and (iv) the significant public benefit, including enhanced safety and cost savings associated with utilizing UASs for agriculture, aerial survey photography

, and patrolling . Accordingly, AV respectfully requests that the FAA grant t he requested exemption without delay.

5 A V submits that this provision places a duty on the Administrator not only to process applications for exemptions under Section 333, but for the Administrator to supply conditions f or the safe operation of the

Puma if he deems the conditions proposed herein require modifica tion necessary to a llow approval

. AV

would welcome the opportunity to consult with FAA staff in order to address any issues or concerns

related to this proposal that they believe may require modification.U.S. Department of Transportation September 24, 2014 Page Four

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The Puma is safe and fit for operation in the NAS under the conditions listed herein. The FAA

has deemed the Puma safe because the US Military has accepted it for use

. The US Military

has flown the Puma since 2007 , amassing over one million flight hours on the AV family of

s UAS . Based on the US Military’s acceptance of the Puma , the FAA issued the Restricted Category Type Certificate Q00018LA and also recently granted AV a Certificate of Waiver or

A uthorization to conduct commercial operations over land in Alaska. 6

In support of this application, AV is submitting, under separate cover and with a request for confidentiality, the following documents: the FAA

- approved A irplane F light M anual (“AFM”) f or the Puma , accepted May 20, 2014 by the FAA (Exhibit 3); the Puma’s M aintenance M anual dated July 18, 2013 (Exhibit 4); the North Slope Standard Operating Procedures Manual (“SOP”) dated May 2014 (Exhibit 5) 7 ; the AV Training Conduct Support Document dated May 4,

2012 (Exhibit 6) ; and the AV Remote Area UAS Operations Safety Case Assessment dated September 13, 2014 (Exhibit 7)

.

Mandatory Operating Conditions

AV proposes that the g rant of the exemption be subject to the following mandatory conditions

, which are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates of Waiver or Authorization, the conclusions of the Remote Area UAS Safety Case Assessment

, and with additional restrictions:

• All operat ions to occur in Class E or Class G airspace over areas with a population density of 360 persons per square mile or less

. 8 Some Class D airspace may be used on

a case

- by

- case basis and would be further defined during the COA process.

• Operations to be con ducted over private or controlled

- access property to limit the number of person s not associated with the operations placed at risk

.

• Permission from land owner/controller required before commencing any flight.

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS).

• Operations to occur during daylight hours.

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

6 A copy of the COA for Alaska operations is attached as Exhibit 2.

7 The North Slope SOP identifies requirements and describes procedures for the AV Digital Imaging and Mapping team to coordinate, plan, and conduct imaging operations for services in support of BP Exploration Alaska North Slope, Alaska. AV submits the Nort h Shore SOP to illustrate to the FAA that AV takes the safety of its Puma operations very seriously. AV intends to supplement its application with a Standard Operating Procedures manual for operations in the three remote areas described below as

soon as p ossible

. 8 See Section 2.2. 5 of Exhibit 7 for explanation of “remote area” definition. The benefits of operating in

“remote areas” are discusse d in further detail in the Section below entitled “Proposed Operations

Locations

. ”U.S. Department of Transportation September 24, 2014 Page Five

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• Flights over sensitive infrastructure such as pipelines or roads will be minimized to reduce the time the infrastructure is placed at risk.

• Flights over sensitive infrastructure will be offset appropriately for the wind at the time of flight to reduce the risk to the infrastructure.

• Launch and recovery areas will be cordoned off to limit access only to personnel associated with the flight operation.

• A dedicated Visual Observer (usually, but not always the PIC) will be utilized to maintain overall operation situational awareness; maintain VLOS and scan for intruder traffic;

monitor all radio communication t o include “ Guard ” in accordance with any COA ; and report on CTAF and other frequencies as appropriate.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway c enterline measured from runway thresholds.

• Operator will file a NOTAM for each flight.

• All required authorizations and permits will be obtained from territorial, state, county

, or city jurisdictions, including local law enforcement, fire, or other governme ntal agencies.

Proposed Operations Locations

AV proposes to operate in areas where the population density i s less than 360 people per square mile. Operating in these “ remote areas ” lowers the risk posed to third parties to

1 x 10 - 9

. Section 2.2.5 of Exhibit 7 describes the methodology for determining the suitability of operational areas for these proposed commercial operations. Operations in such sparsely populated areas and at low altitudes do not create hazards for users of the NAS or the public.

Operator Requirements

AV respectfully proposes that operator requirements should take into account the characteristics of the particular UAS. The Puma is an inherently stable, light

- weight aircraft that weighs 15.5 pounds and will be ope rated in remote areas. The safety concerns addressed by requiring a commercial pilot certificate are not present; moreover, although the Puma can be configured to give the pilot full control of the aircraft and payload during flight, the Puma has an advan ced autopilot that flies the aircraft, managing altitude and flight path within the intended flight envelope at all times when that flight mode is engaged. The autopilot limits maneuvering to simple airspeed, altitude, and turn rate changes. These limits are hard coded into the autopilot and define the aircraft’s normal flight operating envelope. The autopilot manages pitch, bank, and throttle to maintain target airspeed, target turn rate, and target altitude. For in flight modes that do not use GPS, th e operator manually guides the flight path by controlling target airspeed, target altitude, and target turn rate directly. In flight modes that use GPS, the autopilot controls target turn rate to fly to waypoints. The system does not allow commands that a re outside of the normal operating envelope, and the operator never affects control surface movements directly. See Puma AFM, Exhibit 3, at 55

- 56.

Equally significant, even if a problem were to ever arise, the Puma is a modular structure, comprised of co mposite materials, several of which disassemble on impact to decrease risk of injury to people, absorb energy, and reduce damage to the Puma during landing. To that end,U.S. Department of Transportation September 24, 2014 Page Six

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- 7899 WWW.COOLEY.COM the Puma’s wing is composed of Styrofoam laminated with a thin layer of Kevlar that

d isassembles into its sub

- components upon impact.

The Puma Autoland feature enables landings in confined areas. Once Autoland begins, power is cut to the motor, the gimbaled payload is stowed (if installed), and the stabilator deflects fully trailing

- edge upward. As a result, the aircraft pitches nose

- up, with wings level, and begins a descent to the ground with approximately a 1:1 glide ratio. The pilot can steer during the Autoland phase, if required. Impact with the ground usually causes the Puma’s components to separate. As noted above, this helps alleviate the impact of the landing and protects the airframe. During water landings, lanyards prevent separated parts from floating away from the fuselage, which will float. Lan ding pads on the bottom of the fuselage also provide impact protection.

During Loss of Link (“LOL”), 9 the Puma has three options

— finish the programmed flight, land immediately, or go to a rally point. If link is re

- established during LOL, the aircraft op erator can simply press the enter button on the hand controller to resume the indicated flight mode or change to a desired flight mode. Setting the LOL action prior to launch is a mandatory check on the pre

- flight check list. During loss of GPS, the pilot should use the Puma’s last known bearing or terrain association to fly toward a landing site or select a suitable landing site and command

the Puma to autoland.

Given these safety features, AV proposes that operators of the Puma should not be required to possess a commercial pilot certification. Instead, operators should be required to meet the following criteria:

• Possess private pilot certificate;

• Maintain, at a minimum, a valid FAA second

- class medical certificate; and

• Complete the manufacturer’s US M ilitary

- approved training program for operation of the UAS, which is discussed in Exhibit 6.

AV notes that the FAA has found that safety factors have permitted operation of UASs by operators with these qualifications pursuant to COAs for public aircraft w hen the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice

N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013).

9 Loss of Link is identifie d by unchanging video and unchanging data and time, as well as the appearance of a clock symbol on the Link Status Bar. Loss of Link does not necessarily mean that the Puma has lost

GPS.U.S. Department of Transportation September 24, 2014 Page Seven

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- 7899 WWW.COOLEY.COM Specific Exemption Requests and Equivalent Level of Safety Showings

14 C.F.R. § 45.23(b)

– Display of marks; general

Section 45.23(b) provides as follows :

When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “ limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

The Puma has no entrance to the cabin, cockpit, or pilot station on which the word

“ Restricted ” can be placed as required by this provision

. T wo

- inch lettering also i s not possible g iven the overall size of the Puma. AV, therefore, requests an exemption to display, with one

- inch lettering, t he word “ Restricted ” on the forward fuselage in compliance with § 45.29(f).

The equivalent level of safety will be achieved by h aving the Puma marked with one

- inch lettering on its forward fuselage because the pilot, observer, and others working with the UAV

will see the identification of the UAS as “ Restricted. ” The FAA has issued similar exemptions to this regulation, including to Pioneer Hi

- Bred International, Inc., Exemption No. 10810; Raytheon Missile Systems/Advanced Programs, Exemption No s . 10167 and 8738; and Trimble Navigation Limited, Exemption s No. 10700 and 11042

.

14 C.F.R. §§ 61.113(a) and (b), 61.133(a)

– Private Pil ot Privileges and Limitations: Pilot in Command; Commercial Pilot Privileges and Limitations

Subsections (a) and (b) of § 61.113 prohibit private pilots from operating aircraft in commercial operations, and Section 61.133(a) requires an individual operati ng an aircraft for compensation or hire to hold a commercial pilot certificate. As mentioned above, the FAA has the statutory authority to waive the pilot requirements for commercial operations. 49 U.S.C. § 44701(f).

AV requests an exemption from 14 C. F.R. §§ 61.113(a) and (b) and 14 C.F.R. § 61.133(a) so that the Puma may be operated by individuals who (a) have a private pilot certificate, and (b) have completed AV’s US Military

- approved training program for operation of the Puma.

Based upon the desi gn features of the Puma, its autopilot system, and safety factors, the FAA should permit operation of UASs by operators with a private pilot certificate when the conditions

described above have been satisfied. The above

- described conditions are in

- line wi th those set forth in Volume 16, Chapter 4, Section 1 of FAA Order 8900.1.

AV proposes to conduct operations in accordance with these restrictions. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing opera tion ofU.S. Department of Transportation September 24, 2014 Page Eight

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- 7899 WWW.COOLEY.COM the Puma with a private pilot certificate. The risks associated with the operation of the Puma (given its size, speed, operational capabilities, and lack of combustible fuel) are so much less than the level of risk associated with fixed wing and r otorcraft operations, both private and commercial, as contemplated by Part 61, that allowing operations of the Puma, as set forth above, meets or exceeds the present level of safety provided under 14 C.F.R. §§ 61.113(a) & (b) and 61.133(a).

14 C.F.R. § 91.7(a) and (b) : Civil aircraft airworthiness.

Sections 91.7(a) and (b) prohibit operation of a civil aircraft unless it is in airworthy condition. AV requests an exempti on from this regulation because the Puma would not operate with an

airworthines s certificate under the proposal set forth in this filing

. 10 Given the size of the aircraft and the requirements that have already been met in approval of AV’s Restricted Category Type

Certificate and Certificate of Waiver or Authorization , an equivalent l evel of safety will be achieved by insuring compliance with AV manuals prior to each flight.

14 C.F.R. § 91.109(a): Flight Instruction

Sections 91.109(a) provide s that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

The Puma is a remotely piloted aircraft

, and

, by design, it does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with

the aircraft via radio communications. Completing instruction through AV’s training program will

ensure an equivalent lev el of safety.

The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K

and 9862A.

14 C

. F

. R

. § 91.119: Minimum S afe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Puma will never operate at higher than 400 feet AGL. It will, however, be operated in a manner that avoid s congested or populated areas as described in the Proposed Operations Locations section above . Because agriculture, aerial survey work

, and patrolling must be accomplished at relatively low altitudes

, i.e.

, less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

10 The restricted category type certificate that AV has received for the Puma is limited to Alaska.U.S. Department of Transportation September 24, 2014 Page Nine

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- 7899 WWW.COOLEY.COM The equivalent level of safety will be achieved given the size, weight, speed, and material with

which the Puma is built. Also, no flight will be taken without the permission of the lan d owner or the party control ling the land. With advance notice to the landowner, all affected individuals will

be aware of the agriculture, survey

, and patrolling flights. Compared to similar operations

conducted with conventional aircraft or rotorcraft

, which w eigh thousands of pounds and carry flammable fuel, any risk associated with these operations will be far less than those currently

allowed with such conventional aircraft operating at or below 500 feet AGL. AV has received a waiver for such operat ions in Alaska. See Exhibit 8 . AV believes such operations can be

conducted in Class E and Class G airspace in the proposed operational locations specified

above for the same reasons justifying the waiver in Alaska.

14 C.F.R. § 91.151(a): Fuel Requirem ents for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) Duri ng the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” 14

C.F.R. § 91.151(a).

The Puma’s batteries provide between 2 and 3.5 hours of powered flight. Without an exemption from 14 C

. F

. R

. § 91 .151, the Puma ’s flights w ould be limited to approximately 1.5

hours in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable.

AV be lieves that an exemption from 14 C

. F

. R

. § 91.151(a) is safe and consistent with the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the Puma, a small UAS, with out 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent.

The fact that the Puma carries neither pilot, passenger, n or cargo also enhances its safety. Additionally, limiting Puma flights to 1.5 hours would greatly reduce its utility. In the unlikely

event that the Puma should run out of fuel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.

AV believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, which, allowing one hour and 50 minutes of flight time, would be more than adequate to return the UAS to its planned landing zone from anywhere in its o perating area.

Similar exemptions have been granted to others, includ ing Exemptions 2689F, 5745, 10673

, and 10808

.

14 C.F.R. § § 91.405(a); 91

. 407(a)(1); 91

. 409(a)(2); 91

. 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operat or or owner “ [s]hall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed i n part 43 ofU.S. Department of Transportation Septem ber 24, 2014 Page Ten

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- 7899 WWW.COOLEY.COM this chapter .” S ection 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate.

Section 91.417(a) requires that an owner or operator keep records showing certain

mai ntenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Maintenance of the Puma will be accomplished by the owner/operator pursuant to the manuals

, provided by AV

. See Exhibit 4. An equivalent level of safety will be achieved because the

Puma is small in size, will carry no external payload, will operate only in restricted predetermined areas

, and is not a complex mechanical device . As provided i n the attached

Maintenance Manual (Exhibit 4) and the SOP (Exhibit 5) 11 , the operator of the Puma will ensure

that it is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with

the aircraft and is best suited to maintain the aircraft in an airw orthy condition and to ensure an equivalent level of safety.

The Puma comes with one Field Repair Kit (“FRK”). The FRK includes the items necessary to complete field repairs or routine maintenance

.

Federal Register Summary

Pursuant to 14 C.F.R. § 11.8 1(f), the following summary is provided for publication in the Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA

- 2014

-

____ Petitioner: AeroVironment, Inc. Section of 14 CFR: 14 C.F.R. § 45.23(b), 14 C.F.R. § 61. 113(a) and (b); 14 C.F.R. § 61.133(a), 14 C.F.R. § 91.7(a) and (b), 14 C.F.R. § 91.109(a), 14 C.F.R. § 91.119, 14 C.F.R. § 91.151(a), 14 C.F.R. § 91.405(a), 14 C.F.R. § 91.407(a)(1), 14 C.F .R. § 91.409(a)(2), 14 C.F.R. § 91.417(a). Description of Reli ef Sought: AeroVironment is seeking an exemption to conduct commercial agriculture, aerial survey, and patrol operations using a small unmanned vehicle (55lbs or less) in remote and rural areas of the United States using private pilots

.

AV will file an application for a Certificate of Authorization (COA) for approval of specific flight locations. Should the FAA need or require identification of such location in this application, AV will supplement the record as requested.

11 Although the remote area SOP will differ in some respects from the North Slope SOP, it will include the identical requirements that the Puma operator ensure the Puma is in working order prior to fli ght, perform required maintenance, and keep a log of any maintenance performed.U.S. Department of Transportation September 24, 2014 Page Eleven

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- 7899 WWW.COOLEY.COM Based upon the foregoing, AV requests that the FAA grant it the necessary exemptions under Section 333 of the FAA Reform Act and 49 U.S.C. § 44701(f) as requested herein to allow commercial operations of the Puma within the areas defined above.

Si ncerely,

Jonathan B. Hill

M. Anne Swanson Benjamin M. Berlin Counsel for AeroVironment, Inc.

cc: Doug Scott Andrew Thurling

James Williams Robert Pappas

Jake Troutman

Dean Griffith Joseph Morra Thuy Cooper