THE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

November 23

, 2015

To: US Department of Transportation From : Andrew Lewis, President Docket Management System The Ulysses Group, LLC 1200 New Jersey Ave, SE 87B S Market St. Washington, D C 20590 Charleston, SC 29401 (Submitted electronically to the Federal Docket Management System

- FDMS)

Re: Request for Exemption under Section 333 of the FAA Reform Act

Summary of Exemption Request

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, and the Fe deral Aviation Administration’s general exemption authority under Title 49, United States Code, Section 44701(f), The Ulysses Group, LLC (Ulysses) hereby petitions for exemptions from the following Federal Aviation Regulations specified in Title 14 Code of Federal Regulations:

14 CFR Part 21, Subpart H 14 CFR 45.23( b ) 14 CFR 61.113(a)(b) 14 CFR 61.133(a) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.109(a) 14 CFR 91.119(c)

14 CFR 91.121 14 CFR 91.151(a)(1) 14 CFR 91.203(a)(b) 14 CFR 91.319(a)(1) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1)(2) 14 CFR 91.417(a)(b)

These proposed exemptions, if granted, will allow Ulysses to operate their 3DR Iris + (3DR) Unmanned Aircraft System ( UAS ) and may benefit the following commercial applicati ons:

Disaster Response, including Emergency Search & Rescue Critical Infrastructure Monitoring, including Spectral & Thermal AnalysisTHE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

Security Awareness Agriculture, Oil, Gas, and Mineral Survey/Scan

3

- Dimensional Terrain and Structural Modeling

UAS Operations Research & Development

The 3DR UAS uses interchangeable onboard sensors to capture high definition imagery and video that may be translated into three

- dimensional models of a surveyed area. Ulysses’ use of

the UAS will grant landowners, corporations, emergency respo nse teams, and others a greater awareness, heightened security, and increased level of safety during operations , as well as

remove the need for conventional aircraft and the associated risk involved with manned flight

. This res ults in an immediate environmental benefit, as well as enhanced efficiency and safety for any activity conducted

.

Operation under the anticipated exemption will be subject to strict conditions and requirements, ensuring

, at a minimum, an equivalent level of safety to currently authorized operating standards and procedures per FAA Regulations. Additionally, we are prepared to revise operational procedures and limitations in accordance with FAA guidance.

Supplemental Information:

The following information is to be submitted separately to assist the FAA in making an effective

evaluation:

3DR Iris + Operation Manual 3DR Iris+ Flight Checklist

Background of Applicant

The Ulysses Group, LLC, headquartered in Charleston, SC, is conducting contracted services for the Department of Defense with a particular emphasis in aviation operations and geospatial mapping. Currently, the company offers services specific to aviation o perations and has a wealth of knowledge in aviation operations and unmanned flight operations.

At this time, the Ulysses Group employs multiple pilots who possess a combined total of approximately 6,884 hours manned flight hours, 390 UAS combat flight ho urs, 50 Medium Altitude Long

- Endurance (MALE) UAS simulator flight hours, and 1850 USAF Aircrew flight hours. Certifications among employees include a senior military rotary

- wing/fixed

- wing pilot with CPL and IR, two CFIs, one PPL with IR, and one addition al PPL. These pilots are very passionate and knowledgeable regarding flight safety, air traffic operations, and unmanned aviation. In addition to the extensive flight experience, Ulysses Group pilots possess formal educations which include bachelor’s degre es in Aeronautics, Air Traffic Management,THE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

Aeronautical Science, and Unmanned Aircraft System Science from Embry

- Riddle Aeronautical University.

The Ulysses Group is eager to commence flight operations in the unmanned sector and intendeds to proceed with the same discipline and commitment to flight safety as our pilots have demonstrated in their previous manned, unmanned, and combat operational experiences. We look forward to working with the FAA and we are confident in our ability to safely and

effective ly integrate with and contribute to this exciting and emerging aviation community.

Aircraft Overview

The Aircraft: 3DR Iris+

UAS Design:

The Iris+ UAS is built from a variety of durable, lightweight and modular components that aid in its capability to be on mission in a variety of conditions. The modular construction allows for easy exchange of structural, propulsion or sensor components in the field.

As defined by 3DR Aircraft Performance/Specifications:

• Aircraft Composition: polymers/plastic • Flight Controls: Primary: GPS Guided Autopilot (Ground Control Station) Backup: Standard Flight Controls (RC Transmitter) • Power Supply: Electric Motor /5100 Mah battery pack • Speed: 35kts • Empty Weight: 1282g/2.83lbs • Max Payload: 400g/.81bs • Launch (Take Off): GPS assisted or manually • Recovery (Landing): GPS assisted or manually

Training

Ulysses requires every Operator to be fully qualified on its 3DR Iris + UAS appropriately as determined by the chief pilot for the operation . Trainees are given insturction in general skills

such as: maintaining altitude, maintaining visual line of sight, general n avigation principles, obstacle avoidance, air traffic de

- confliction, and emergency procedures. Qualification as an Operator for the 3DR Iris + UAS requires that the trainee show proficient levels of all aforementioned skill areas, with special emphasis on emergency procedures and UAS flightTHE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

logic

. Operators will meet applicable flight review requirements in an aircraft in which s/he is

rated through flights and instruction as required

.

Ulysses requires every person who will be acting as a V isual O bserver t o be a rated pilot proficient in airspace knowledge, emergency procedures, aeronautical chart interpretation and airspace safety, ground operations, and radi o communication s . Two

- w ay radio communication will be established between the UAS operator and visu al observer(s) during flight operations.

Operations

Ulysses intends to operate the 3DR UAS in accordance with the following restrictions:

1. The	UAS	will	weigh	less	than	55	lbs.

2. Flights	will	be	op erated	within visual line	of	sight	of	the	Operator and/or Visual

O bserver.

3. Flights	will	be	operated	at	an	altitude	of	no	more	than	400ft	AGL.

4. Flight	operations	will	take	place during	daylight	hours	under	VFR	or	Marginal	VFR

conditions.

5. Minimum	crew	for	each operation	will	consist	of	the	UAS	Operator	and	the	Visual Observer.	The	Operator	and	Visual	Observer	will	be	able	to	communicate	by	voice	at

all	times.

6. The UAS Operator will	be	an	FAA	licensed	airman with	an	FAA	medical	certificate	or

a	valid	U.S.	driver’ s	license.

7. The	PIC	may	train other	pilots	in	the	use	of	the	UAS.

8. The UAS	will	operate	within	an	area	that	has	been	determined	to	be	safe	and	at	least 200ft	away	all	persons	who	are	unaware	of	the operation .	The	operator	will	obtain

written and/or	verbal c onsent	of	all	persons	involved	or	in	the	area	of	the operation.

9. Written	and/or	verbal	permission	from	the	relevant	property	holders	will	be

obtained when	conducting	flights	over	private	property

. 10. The	UAS	will	operate	at	least	100ft	away	fro m	buildings	in urbanized	areas	with	the exception	of	buildings	which	may	be	the	subject	of	the	operation.

11. A	briefing	will	be	conducted	in	regard	to	the	planned UAS	operation prior	to	each flight .	It	will	be	mandatory	that	all	personnel	who	will	be	performing	duties	withi n the operational	area be	present	for	this	briefing

12. The	Operator and Visual	O bserver	will	be	trained	in the	operation	of UAS	and
receive	up

- to

- date	information	on 3DR	UAS

. 13. All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	cou nty or	city	jurisdictions,	including	local	law	enforcement,	fire,	or	other	appropriate governmental	agencies.

14. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	t he UAS	will	have	capability

to	return	to	a	pre

- determined	location	and	land.THE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

15. The UAS	w ill	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or emergencies.

Authority for Petition

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a method for seeking expedited FAA authorization of safe, civil UAS operation in the National Airspace System (“NAS”). Section 333(a) states that the Secretary of Transport ation “shall determine if certain Unmanned Aircraft Systems may operate safely in the National Airspace System before completion of the plan and rulemaking required by Section 332 of this Act or the guidance required by Section 334 of this Act.”

Section 333(b) outlines any factors the Secretary of Transportation must consider in order to determine whether commercial UAS operation should be approved. These factors include at minimum “[the UAS’s] size, weight, speed, operational capability, proximity to air ports and populated areas, and operation within visual line of sight do not create a hazard to users of the National Airspace System or the public or pose a threat to National Security [...]”

Section 333(c) states that should the Secretary determine a cert ain UAS may operate safely in the NAS, “the Secretary shall establish requirements for safe operation of such aircraft systems in the National Airspace System.” Section 44701(f) of Title 49, United States Code, states that “The [FAA] Administrator may gran t an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of this title if the Administrator finds the exemption is in public interest.”

Explanations

14 CFR Part 21, S ubpart H; Section 91.203(a)(1) : Procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificate s, and airworthiness approvals.

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91 .203(a)(1). Given the size and weight of the 3DR aircraft and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety l evels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act.THE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement fo r an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS

involved. An analysis of these criteria demonstrates that the 3DR Iris +

, operated witho ut an
air worthiness certificate and acting under the conditions proposed herein, will be at a minimum as safe, if not safer, than a conventional aircraft (fixed wing or rotorcraft) that contains an

airworthiness certificate. The 3DR Iris + weighs no more than 3.7 lb s fully configured. The 3DR

Iris + will not carry a pilot or passenger, it will not carry flammable fuel, and it will operate exclusively within an area pre

- disclosed and in compliance with the conditions set forth herein. Operations under this exemption wi ll be monitored and tightly controlled by both the operator, pursuant to the conditions set forth above, and by local public safety requirements.

After consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, Ulysses believes exemption from 14 CFR Part 21 should be granted.

14 CFR 45.23( b ): A ircraft marking and identification requirements

.

Since the 3DR UAS will not be certificated under 14 CFR 21.191, a grant of exemption for 14 CFR 45.23(b) is not necessary, as the FAA has commented in the grant for exemption for

Astraeus Aerial

.

Ulysses will identify the UAS by serial number and will display any required markings in accordance to this exemption as large as practicable in order to meet an equivalent level of safety as intended by 14 CFR 45.23(a)

.

14 CFR 61.113(a) and (b); 61.133(a): Pri vate pilot privileges and limitations; Pilot in Command; Commercial Pilot Privileges and Limitations

.

Ulysses will require that all UAS operators be FAA certificated airmen and possess an FAA medical certificate or a valid U.S. driver’s license. UAS oper ators will complete the training requirements as described herein and will maintain all applicable flight review and currency requirements for their pilot qualifications

.

For these reasons, Ulysses believes exemption from 14 CFR 61.113(a) and (b); 61.133( a) should be granted.

14 CFR 91.7(a): Civil aircraft airworthinessTHE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

Under t his regulation

, a civil aircraft may only be operated if it is in airworthy condition. As there is no published standard for validating the airworthiness condition of the 3DR Iris + UAS, Ulysses will achieve an equivalent level of safety by ensuring compliance with all mai ntenance and inspection manuals as well as conducting a pre

- flight check of the aircraft and its components in accordance with the procedures outlined in the m anufacturer’s operation manual.

For these reasons, Ulysses believes exemption from 14 CFR 91.7(a) should be granted.

14 CFR 91.9(b)(2): Civil aircraft flight manual in the a ircraft

This regulation requires that any person to operate a U.S.

- registered civil aircraft “[...] (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or R otorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.”

Given the small size of the 3DR Iris + and the fact that the Operator will be located on the ground

, the UAS has no ability or need to carry such a flight manual on the aircraft. However, an equivalent level of safety will be achieved by keeping the operation manual and flight checklist at the groun d control point where the Operator and anyone involved in the operation will have

immediate access to t he documentation.

Ulysses believes exemption from 14 CFR 91.9(b)(2) should be granted, as an equivalent level of marking and documentation will be achieved.

14 CFR 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide 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. In operational configuration, the 3DR Iris + is a remotely piloted aircraft and does not

have ful ly functional dual controls. Flight control is accomplished through the use of a

transmitter or ground control station that communicates with the aircraft via line

- of

- sight radio

communications. The flight plan is preprogrammed into the autopilot before or during flight and

the UAS may also receive manual pilot input control functions to alter the pre

- programmed flight. Instruction will be accomplished as outlined herein; therefore, an equivalent level of safety will be assured.

For these reasons, Ulysses believes exemption from 14 CFR 91.109(a) & 91.319(a)(1) should be granted.THE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

14 CFR 91.119(c): Minimum s afe a ltitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft . Specifically, 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 t o any person, vehicle

, vessel , or structure.

Ulysses will conduct all UAS operations below 400ft AGL and will	operate	within	an	area	that has	been	determined	to	be	safe	and	at	least	200ft	away	from	all	persons	who	are	unaware of	the	operation.	The	UAS	wi ll	operate	at	least	100ft	away	from	buildings	in	urbanized areas	with	the	exception	of	buildings	which	may	be	the	subject	of	the	operation.	In addition,	any	objects	or	hazards	will	be	identified	and	mediated	prior	to	the	flight.	The small	size	and	weight	o f	the	aircraft,	the	lack	of	flammable	fuel	on	board,	and	continuous communication	between	the	Operator	and	Visual	Observer	further	reduce	any	potential risk	associated	with	UAS	operations.

For these reasons, Ulysses believes exemption from 14 CFR 91.119 (c) should be granted because an equivalent level of safety will be achieved.

14 CFR 91.121: Altimeter settings

Section 91.121 requires aircraft operators to maintain cruising altitude or flight level by reference

to an altimeter. The 3DR UAS utilizes a Global Positioning System and altitude will be determined using this type of equipment

.

Ulysses believes exemption from 14 CFR 91.121 should be granted as an equivalent level of safety will be achieved using this type of equipment.

14 CFR 91.151(a) (1) : Fuel requirements for flight in VFR conditions

The 3DR UAS is battery powered and flight duration will be planned based on battery capacity, which is approximately 15

- 25 minutes. Flight control software will automatically return the

aircraft to the launch point and land once the battery reaches 25%.

Because the 3DR UAS is battery powered and comes programmed with this safety feature, Ulysses believes exemption from 14 CFR 91.151(a)(1) should be granted.

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and RegistrationTHE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

This regulation provides as follows: (a) [...] no person may operate a civil aircraft unless it has [...] an appropriate and current airworthiness certificate. (b) No person may operate a civil

aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

When fully configured for fli ght operations, the 3DR Iris + weighs no more than 3.7 lbs. Due to its light weight, there is no ability or place to carry certification and registration documents or to display them on the UAS. In addition, there is no pilot on board the aircraft. An equiv alent level of safety will be achieved by keeping aircraft specific documents at the ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation.

Ulysses believes exem ption from 14 CFR 91.203 (a) & (b) should be granted, as the regulation is not applicable to its 3DR UAS.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)(b) : Maintenance Requirements

Section 91.405(a) requires that an aircraft ope rator or owner “shall 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 in part 43 of this chapter [...] ” Section 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 the owner or operator to keep records showing certain ma intenance 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.

Ulysses will conduct pre

- and post

- flight inspections, as well as regularly scheduled inspections, of the aircraft and its components. Ulysses will maintain inspection and maintenance logs in order to comply with the intent of these regulations. Unscheduled maintenance will be accomplished as required and will be documented appropriately in the maintenance logs. A test flight in a controlled area will be conducted after any maintenance or alterations to the UAS have taken place and prior to any other flight operations.

Due to the relative simplicity, ease of maintenance, and low risk associated with the 3DR UAS, Ulysses believes exemptions from these regulations should be granted.THE ULYSSES GROUP, LLC

87B S, Market St.
Charleston, SC 29401

Phone: 843

- 437

- 1144

alewis@theulyssesgroup.com

Summary

The 3DR Ir is + UAS will capture aerial data including: high definition and/or multispectral imagery and video that may be translated into three

- dimensional models of a surveyed area,

electronic measureme nt with precision surveying, or any other gathering of data by instruments

aboard the UAS

. Ulysses believes this approval from the FAA will enhance the efficiency of all activities conducted and will provide multiple economic, environmental, and safety benefits regarding these operations and alternative methods of data collection, and is therefore beneficial to the public’s interest.

V/R,

Andrew Lewis, Presid ent The Ulysses Group, LLC

87B S Market St. Charleston, SC 29401