September 15 , 2015

Chris Harris

President Northwest UAV (NWUAV) McMinnville, Oregon 97128

c hris.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. FA A

- 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 i n 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 design s and build s Unmanned Aerial Vehicles ( UAV ) engines, UAV control systems and support systems for numer ous 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 ensure s success and safety while providing reliable

, high performance solutions to multiple UAV platforms

.In accordance with the FAA’s Guidelines for Submitting a Petition f or Exemption under section

333 of the FAA Moder

nization 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 i n 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 al titude 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, s o long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by S ection 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 prescrib ed 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'

A GL. 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 o perations of the UAS will ensure separation between these small UAS operations and the operations of convention al aircraft that must comply with Section 91.119. The FAA issued an exemption to this regulation in Exemption No.

11 876

. 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 ap propriate 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 applicab le 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 11 876 ( KalScott Engineering )

, prior relief has been granted for unm anned 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 dayti me, 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 mi nutes 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 leve l. Given the limitations on proposed operations and the location of t hose proposed operations, petitioner submits that a reduced minimum power reserve for flight in daytime VFR

conditions is un reasonable.

 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.41 7(a) & (b) As discussed in Exemption

11 876 and 12447, t he 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 availab le, 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 s peed of 37

- 83 km/h, 20 to 45 knots

. Operatingaltitude is 500 ft (152 m) AGL Altitude (Typ.)

. Wing Span is 9.2 ft (2.8 m) , l ength is 4.6

ft (1.4 m) and w eight is 13.5 lbs (6.1 kg)

.

 Infotron is a rotor UAS that has either a 46cm3 two

- stroke powerplant or b rushless DC

motor. The rot or diameter 1. 80 m . It ’s t otal 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 m aximum altitude of 3000 m eters and and

e ndurance of 90 minutes or 30 minutes for electric variant. Selectable p ilot 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 a ircraft 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 allow s the Ground Station Operator to interact

with the aircraft in

- situ and add additio nal 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 SacnEagl e is a gile, virtually undetectable and can stay on station until the job is done

. T he 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 becaus e 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 w eights empty are 30.9

- 39.68 lb / 14

- 18 kg . The max takeoff weight is 48.5 lb / 22 kg and possesses a m ax payload weight of 7. 5 lb / 3.4 kg . It can remain aloft for 24+ hours at a service c eiling of 15,000 ft / 4,572 m . Max horizontal speed is 80 knots / 41.2 m/s with a nominal c ruise 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

.

Prop osed 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

fix ed 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 lice nse 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 UA S in a manner consistent

with how t he UA S will be operated under this exemption, including evasive and

emerg ency 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

- build ing flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UA S 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 UA S operations prio r 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 UA S , including the Ground Control Station,

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

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

maintenance has been performed and the UA S is found to be in a condition for s afe flight. All maintenance and alterations will be properly documented in the aircraft

records.

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

maintenance or alterations that affect the UA S 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 keepin g requirements, in accordance with the UA S 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, a nd the signature of the authorized person returning the UA to service.

The authorized person will make an entry in the aircr aft record of the corrective action taken against discrepancies discovered between inspections.

16. The UA S 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. Theywill not be permitted to use electronic messaging or texting to communicate during flight

operations.

18. The PIC will not begin a flight unless (considerin g 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 UA S will have the capability to abort a flight in case of unexpect ed 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 ad vance, 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 UA S 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 NO TAM 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 UA S 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 UA S 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 UA S , the PIC will e nsure 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 M itigation :

The peti tioner 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 co nditions prescribed above, preflight processes will be developed and employed to ensure that the UA S 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 failure

prone 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

e xemption. Flight data including UA S 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 appli cation. This data may be submitted to FAA via tradi tional means, e.g. COA Monthly r eports, 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 reques t 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 petitione r 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,

militar y, 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)