September 15, 2015

Chris Harris

President

Northwest UAV (NWUAV)

McMinnville, Oregon 97128

chris.harris@nwuav.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 

1. AVINC Puma AE Specification Sheet

2. InfoTron IT180-5 Specification Sheet

3. Brican TD-100E Specification Sheet

4. Insitu Scaneagle Specification Sheet

5. FAA TCDS Q00017LA

Attachments: 

1. FAA Exemption No. 12068, Regulatory Docket No. FAA-2015-1237 In the matter of the 

petition of UA TacSolutions LLC.

2. FAA Exemption No. 11876, Regulatory Docket No. FAA–2014–1064 in the matter of 

the petition of KalScott Engineering LLC.

3. FAA Exemption No. 12447 Regulatory Docket No. FAA−2015−0812 in the matter of the 

petition of Cochise College

Dear Sir or Madam,

Northwest UAV (NWUAV) is the Largest UAV Propulsion System Manufacturer in the U.S.

NWUAV designs and builds Unmanned Aerial Vehicles (UAV) engines, UAV control systems 

and support systems for numerous Unmanned Aircraft Systems (UAS). NWUAV currently 

builds the INSITU ScanEagle engine listed under FAA Type Certificate (TC) Q00017LA.

The primary purpose of NWUAV is to build and deliver the most reliable, dependable and cost 

effective UAV/UAS systems while providing exceptional customer interface throughout the 

design, development and manufacturing phases. In addition, NWUAV is AS9100/ISO9001

certified (engineering and quality) which ensures success and safety while providing reliable, 

high performance solutions to multiple UAV platforms.
In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 

333 of the FAA Modernization and Reform Act of 2012, I Chris Harris, President of NWUAV, 

referred to hereafter as the petitioner, request exemption from the following sections of Title 14, 

Code of Federal Regulations:

§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1);

91.409(a)(2); 91.417(a) & (b)

This exemption request is in order to operate UAS commercially in airspace regulated by the 

Federal Aviation Administration (FAA) for the purposes of capability demonstration, aerial 

onboard data collection and other flight operations that will be performed safely and effectively 

with the use of various small UAS at low altitude within the U.S. national airspace system. 

Operations will be performed only at the request of and with the authorization and permission of 

clients or their authorized agents in order to facilitate commerce, raise awareness of the 

beneficial uses of small unmanned air systems and test UAV component systems in the course of 

developing ever-evolving capabilities, so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333. 

The conditions identified and proposed by the petitioner are drawn from the following 

references:

The Code of Federal Regulations (CFR/FAR):

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

 61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of 

pilots, who hold a SPORT PILOT (or greater) certificate. Any pilots operating under this 

exemption would be required to comply with any conditions as set forth and in a similar 

fashion to previously granted exemptions.

 91.119; As discussed in Exemption 11876 (KalScott Engineering), Section 91.119 

establishes safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less than the minimums 

prescribed, provided the person operating the helicopter complies with any route or 

altitudes prescribed for helicopters by the FAA. As this exemption is in part for UAS that 

is a rotorcraft by design and the exemption requests authority to operate at altitudes up to 

400' AGL. As set forth herein, the UAS will never operate at altitudes higher than 400' 

AGL. It will however be operated in an area with perimeter, where buildings and people 

will not be exposed to operations without their pre-obtained consent. The equivalent level 

of safety will be achieved given the size, weight, speed of the UAS as well as the location 

where it is operated. No flight will be taken without the permission of the property 

owner. Compared to flight operations with aircraft or rotorcraft weighing far more and 

the substantive lack of flammable fuel, any risk associated with these operations is far 

less than those presently presented with conventional aircraft operating at or below 400' 

AGL. In addition, the low-altitude operations of the UAS will ensure separation between 

these small UAS operations and the operations of conventional aircraft that must comply 

with Section 91.119. The FAA issued an exemption to this regulation in Exemption No. 

11876.
 91.121; As discussed in Exemption 12447 (Cochise College) 91.121 is inapplicable since

the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric 

sensor for altitude information. Section 91.121 requires each person operating an aircraft 

to maintain cruising altitude by reference to an altimeter that is set "to the elevation of the 

departure airport or an appropriate altimeter setting available before departure." As the 

UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption is required. An equivalent level of safety will be achieved by the operator, 

pursuant to the applicable Operator's Manual, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight.

 91.151(a); As discussed in Exemption 11876 (KalScott Engineering), prior relief has 

been granted for unmanned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific 

relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR 

conditions. Complying with the 30 minute reserve requirement in 14 C.F .R. § 91.151, 

would unnecessarily limit the length of NWUAV’s UAS flights. The batteries powering 

current rotorcraft and small fueled engine UAS’s provide approximately 15-20 minutes 

of flight time. To meet the 30 minute reserve requirement in 14 C.F .R. § 91.151, UAS 

flights would not be possible. Given a UAS power endurance limitations, the PIC will 

initiate a landing procedure when power/fuel remaining reaches a specified level. Given 

the limitations on proposed operations and the location of those proposed operations, 

petitioner submits that a reduced minimum power reserve for flight in daytime VFR 

conditions is unreasonable.

 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 

11876 and 12447, the petitioner proposes to inspect and ensure that the UAS is in a 

condition for safe flight in accordance with the operating documents. The FAA 

previously found that adherence to petitioner’s operating documents and the conditions 

and limitations specified, describing the requirements for maintenance, inspection, and 

recordkeeping, were sufficient to ensure that safety would not be adversely affected.

The UAS:

 Puma AE (All Environment) is a fully waterproof, small, unmanned aircraft system 

(UAS) designed for land and maritime operations. Capable of landing in water or on land, 

the Puma AE empowers the operator with an operational flexibility never before 

available in the small UAS class. The Puma AE delivers 3.5+ hours of flight endurance

with versatile smart batteries options to support diverse mission requirements. Its 

powerful propulsion system and aerodynamic design make it efficient and easy to launch 

especially in high altitudes and hotter climates. Puma AE carries a gimbaled payload with

an electro-optical (EO) and infrared (IR) cameras. For increased payload capacity, an 

optional under wing Transit Bay is available, plus a plug and play secondary power 

adapter is incorporated for increased mission flexibility. The enhanced precision 

navigation system with secondary GPS provides greater positional accuracy and 

reliability of the Puma AE. AV’s common ground control system allows the operator to 

control the aircraft manually or program it for GPS-based autonomous navigation. Range 

is 15 km. Endurance is 3.5+ hours with a speed of 37-83 km/h, 20 to 45 knots. Operating 
altitude is 500 ft (152 m) AGL Altitude (Typ.). Wing Span is 9.2 ft (2.8 m), length is 4.6

ft (1.4 m) and weight is 13.5 lbs (6.1 kg).

 Infotron is a rotor UAS that has either a 46cm3 two-stroke powerplant or brushless DC

motor. The rotor diameter 1.80 m. It’s total mass (loaded) is 19 Kg 17 Kg and the 

unloaded mass is 14 Kg 14 Kg. Payload is 5 Kg or 3 Kg for electric powerplant variant. 

Maximum airspeed is 90 Km/h with a maximum altitude of 3000 meters and and 

endurance of 90 minutes or 30 minutes for electric variant. Selectable pilot modes are 

Manual, Automatic, and Land monitoring. Radio link 41 MHz – 72 MHz - 2,4 GHz. 

Automatic functions are Takeoff, Flight, and Landing.

 The TD100E is Brican’s high performance composite aircraft platform fitted with an 

electric motor and LiPo batteries for extended duration flight of approximately 4 hours in 

the air. The TD100 aircraft carries a modified version of Aventech’s ARIM320 Digital 

Air Probe sensor suite. The climatology payload package provides the user with the 

ability to review and react to sampled data in real-time via an online interface (in the 

form of Ground Station readout). This allows the Ground Station Operator to interact 

with the aircraft in-situ and add additional waypoints based on real-time data feedback 

and therefore re-task or extend the scope of the mission or survey area while the aircraft 

is still in flight. 

 The INSITU SacnEagle is agile, virtually undetectable and can stay on station until the 

job is done. The hardworking ScanEagle delivers persistent imagery on land or at sea at 

a fraction of the cost of other surveillance methods. The aircraft’s superior live video 

feeds keep you one step ahead of the situation, whether your mission is agricultural 

assessment or force protection. And because no nets or runway are required, you can 

keep your footprint small, even when the stakes are big. The airframe length is 5.6 ft / 

1.71 m, wingspan is 10.2 ft / 3.11 m and weights empty are 30.9-39.68 lb / 14-18 kg. The 

max takeoff weight is 48.5 lb / 22 kg and possesses a max payload weight of 7.5 lb / 3.4 

kg. It can remain aloft for 24+ hours at a service ceiling of 15,000 ft / 4,572 m. Max 

horizontal speed is 80 knots / 41.2 m/s with a nominal cruise speed of 50-60 knots / 25.7-

30.9 m/s. The powerplants rely on heavy fuel (JP-5 or JP-8) or gasoline engine.

Proposed Conditions of the Exemption:

1. UAS operations under this exemption would be limited to conducting operations for the 

purpose of technology demonstrations or testing in Class G airspace nationwide, unless 

otherwise prescribed by an ATO issued COA.

2. The UA may not operate in Class B, C, or D airspace without written approval from the

FAA.

3. Flights will be operated within line of sight of a pilot and visual observer.

4. Flights of rotorcraft variant UAS will be operated at an altitude of no more than 400 feet 

AGL, as indicated by the procedures specified in the operating documents. Flights of 

fixed wing UAS’s will be below 2000 feet AGL. All altitudes reported to ATC must be 

in feet AGL.

5. Minimum flight crew for each operation will consist of the UA pilot in command (PIC) 

and a visual observer (VO).
6. The PIC will have, at minimum, a sport pilot license and a third class medical certificate 

or a U.S. driver’s license.

7. The petitioner will not permit any PIC to operate unless the PIC meets its qualification 

criteria and 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. 

8. PIC qualification flight hours and currency will be logged in a manner consistent with 14 

CFR § 61.51(b). A record of the PIC training will be documented and made available 

upon request by the Administrator. Training operations will only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, 

all persons not essential for flight operations will be considered nonparticipants, and the 

PIC will operate the UAS with appropriate distance from nonparticipants in accordance 

with 14 CFR § 91.119.

9. The VO will not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions, and will not be 

permitted to operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her

designation for the duration of the flight. The PIC will ensure that the VO can perform 

the functions prescribed in these conditions and the operating documents.

11. A briefing will be conducted in regard to the planned UAS operations prior to each day’s

activities. It will be mandatory that all personnel who will be performing duties in 

connection with the operations be present for this briefing.

12. Prior to each flight, the PIC will inspect the UAS, including the Ground Control Station, 

to ensure it is in a condition for safe flight. If the inspection reveals a condition that 

affects the safe operation of the UAS, the PIC will not operate the UA until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe 

flight. All maintenance and alterations will be properly documented in the aircraft 

records.

13. Petitioner will conduct a functional flight test on any UAS that has undergone 

maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component. The PIC who conducts the functional test 

flight will make an entry in the aircraft records.

14. The petitioner will carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements set forth in 

the operating documents.

15. Maintenance, inspection, alterations, and status of replacement/overhaul component parts 

will be noted in the aircraft records, including total time in service, description of work

accomplished, and the signature of the authorized person returning the UA to service. 

The authorized person will make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections.

16. The UAS will be operated within visual line of sight (VLOS) of the PIC and VO at all 

times.

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

corrective lenses. PIC and VO will at all times be able to communicate verbally. They 
will not be permitted to use electronic messaging or texting to communicate during flight 

operations.

18. The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and 

prepare to land with 25% battery power or fuel remaining.

19. The UAS will have the capability to abort a flight in case of unexpected obstacles or

emergencies.

20. Petitioner will obtain written and/or oral permission from the landowners/authorized 

agents of the landowners over which flights will be conducted.

21. Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. All operations will be conducted in 

accordance with airspace requirements in the ATO issued COA, including class of 

airspace, altitude level and potential transponder requirements.

22. The UAS will not be operated within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s management has been obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. Any letter of agreement 

with the airport management will be made available to the Administrator upon request.

23. The UAS will not be operated by the PIC from any moving device or vehicle.

24. Petitioner will conduct all flight operations at least 200 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless one of the following three conditions is 

met:

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

from the UAS and/or debris in the event of an accident. The petitioner will 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 UAS, the PIC will ensure that flight operations cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

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.

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

Risk Mitigation:

The petitioner has reviewed FAA exemptions reference’s 13 Conditions and Limitations section 

and believes that the procedures and conditions specified therein are reasonable and will be 

utilized in order to manage and mitigate risk and ensure public safety. Per conditions prescribed 

above, preflight processes will be developed and employed to ensure that the UAS airworthiness

will be verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on failureprone components.
Public interest:

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, 

carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate 

commerce could lead to economic growth. Operations for this petition will enable service for 

UAS owners or their designees seeking an enhanced perspective for effective and reliable 

development of safe UAS systems. The petitioner will provide clients with system data for these 

purposes on a ‘for hire’ basis. A visual observer will be utilized for all tests and demonstrations. 

Liability insurance will be obtained commensurate with the granting of this request for

exemption. Flight data including UAS demonstrative flight time, Control Unit operation time, 

incident, accident, and details concerning any deviations from normal operations will be 

available to FAA for use in collecting data regarding the use of UAS as part of this application.

This data may be submitted to FAA via traditional means, e.g. COA Monthly reports, or other 

means as required.

Conclusion:

The petitioner is requesting this exemption for the purposes of UAS technology demonstration, 

aerial onboard data collection and other flight operations that will be performed safely and 

effectively with the use of various small UAS at low altitude within the U.S. national airspace 

system. The reason for such a general and broad based request is that the petitioner wishes to 

utilize a business and technology strategy of horizontal integration and maximize economies of 

scope in order to capitalize on opportunities as they may arise in the future without the long 

turnaround time associated with additional exemptions. The petitioner's business model is based 

on the idea of offering ad hoc small UAS services to individuals or companies who wish to 

employ these services as a safe, effective, and legal option to enhance their business or UAS 

technology. The petitioner has refrained from engaging in commercial use of the UAS. The 

primary purpose of seeking this exemption is to obtain the capability to offer those services 

while remaining in compliance. The petitioner has numerous years of experience in general, 

military, and commercial aviation and holds airman certificate, airframe and powerplant 

certificates, as well as current FAA medical certificates.

Respectfully submitted,

Chris Harris

President

Northwest UAV (NWUAV)