# G LEIM 

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# I NC. (800) 87 GLEIM ▪ (352) 375-0772 ▪ FAX (352) 375-6940 http://www.gleim.com ▪ E-mail: irvin @gleim.com 

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December 15 th, 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Rm W12-140 1200 New Jersey Avenue, SE Washington, DC 20590 To Whom It May Concern:

Gleim Publications, Inc. (known henceforth as “Gleim”, “Gleim Publications” or “the petitioner”) hereby requests for an exemption from the regulations listed in this document pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR § 11.

Since 1980, Gleim Publications has been dedicated to providing the highest quality of aviation training material to the public. This means keeping up to date with the latest technologies that the world has to offer. Gleim Publications already uses state of the art online technology to bring aviation training material right to the devices that students carry with them every day. As technology progresses in the aviation field, especially in the area of sUAS operation, it is vital to prepare operators with a better understanding of safe operations. The sUAS industry is rapidly growing both in commercial and non-commercial use. Each day, thousands of hobbyist flights are conducted for the purpose of photography, recreation, or even education. Gleim seeks to use sUAS to further the production of aviation training material of the highest quality, and for developing our sUAS crewmember training curriculum. The contents of this petition is as follows. I. Petitioner Information II. Regulations Which Require Exemption III. Gleim's Proposed Operations and Safety Procedures IV. Public Interest of this Exemption V. Syma X5C-1 Information and Specifications VI. Federal Register Summary VII. Closing

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I. Petitioner Information Gleim Publications Inc. Attn: Dr. Irvin N. Gleim 4201 NW 95 th Blvd. Gainesville, FL 32607 Phone: (352) 224-1310 Email: Irvin@gleim.com

Gleim Publications Inc. is owned by Dr. Irvin N. Gleim and his family . Dr. Gleim is a professor emeritus at the Fisher School of Accounting, University of Florida in Gainesville, Florida. Since 19 80 , Gleim Publications is dedicated to providing aspiring Accountants and Aviators with high quality training materials in order to pass their exams and realize that dream. Dr. Gleim holds a Commercial Pilot certificate with CFI Airplane Single Engine and Instrument Airplane privileges , and is an Advanced and Instrument Ground Instructor.

II. Regulations Which Require Exemption 14 CFR § 21 Subpart H 14 CFR § 61.3(d) (Requirement for certificates, ratings, and authorizations. - Flight

Instructor Certificates.) 14 CFR § 61.23 (Medical Certificates) 14 CFR § 61.101 (Recreational pilot privileges and limitations) 14 CFR § 61.113 (Private pilot privileges and limitations: Pilot in command.) 14 CFR § 91.103 (Preflight Action) 14 CFR § 91.105 (Flight crewmembers at stations) 14 CFR § 91.109 (Flight instruction) 14 CFR § 91.119 (Minimum Safe Altitudes) 14 CFR § 91.121 (Altimeter settings) 14 CFR § 91.151 (Fuel Requirements for flights in VFR) 14 CFR § 91.405 (Maintenance Required) 14 CFR § 91.407 (Operation after maintenance) 14 CFR § 91.409 (Inspections) 14 CFR § 91.417 (Maintenance Records)

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III. Gleim's Proposed Operations and Safety Procedures This section serve s as an explanation of the extent of the exemption requested as well as the reason for the request. This section covers the safety procedures that Gleim adhere s to and the reason why this exemption will not adversely affect safety or cause safety concerns.

Gleim Publications plans to use the device(s) described in Section V for research and development of Aviation training material, and for developing our sUAS crewmember training curriculum. Gleim believes that safety is the most important part of operating any aircraft and as such we plan to provide the highest quality training and reference material available. This exemption will permit Gleim Publications to operate sUAS for the following purposes:

• Research and development of aviation safety material and pilot training material.

• Developing our sUAS crewmember training curriculum.

• Aerial photography and videography for use in aforementioned material. The following are safety procedures that Gleim strictly adheres to in order to ensure a safe environment.

• Careful pre-flight and planning to minimize possibility of an accident or crash due to battery life, pedestrian traffic, weather, or any other reason.

• Specifically designated areas and times to operate the proposed sUAS within.

• The sUAS will never exceed the 55 pound limit or 400 foot altitude limit imposed on recreational sUAS pilots.

• Flights for the purposes above will be conducted by a certificated pilot in airspace sufficiently away from other air traffic.

• Careful observation of the listing of current TFRs will be in place as to not conduct flights in any restricted area.

• All flights will be within the limitations of the sUAS outlined in the official manufacturer's documentation.

• Strict policies are in place to ensure that the PIC of the sUAS is not under the influence of any impairing substances, e.g. drugs and alcohol.

• Regular inspections and preventative maintenance will be performed ensuring the sUAS is in airworthy condition.

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IV. Public Interest of this Exemption

Gleim Publications is a leading provider of aviation training materials, and apart 141 ground school operator. It is of public interest for both commercial and noncommercial crewmembers to be properly trained and provided with all of the documentation necessary to facilitate a safe environment. Any crewmember operating an aircraft without proper training is a significant hazard to themselves and the public. Gleim Publications plans to use this exemption and the operation of sUAS to greatly minimize this risk by developing a sUAS training curriculum, safety and reference materials. V. sUAS Information and Specifications

Gleim Publications currently uses a Syma X5C as our sUAS. This is a small quadcopter that is well beneath the 55 pound hobbyist limitation. The Syma X5C has an advertised range of approximately 100 feet which is also well beneath the hobbyist altitude limitation of 400 feet. Additional information is listed below

• 31.5cm length, 31.5cm width, 7.5cm height, 103g weight.

• Uses 3.7V Lithium-polymer batteries.

• Fine tuning controls allow for accurate flight.

• 2.4GHz band remote control.

• Landing Skids and Propeller Guards for safety. VI. Federal Register Summary Petitioner:Gleim Publications, Inc. Rules from which exemption is sought: 14 CFR §§ 21 Subpart H; 61.23; 61.101; 61.113; 91.103; 91.105; 91.109; 91.119; 91.121; 91.151; 91.405; 91.407; 91.409; 91.417. Description: Petitioner seeks exemption from the listed regulations under 14 CFR to operate small Unmanned Aircraft Systems (sUAS), specifically the Syma X5C-1, in a controlled private area for the purpose of conducting research and development related to educating the public in the safety of sUAS operation.

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VII. Closing Gleim Publications is excited to begin operation of sUAS. Safety is our goal first and foremost and we plan to continue producing the best pilot training material available and developing our sUAS flight training curriculum to make airspace safer. The use of sUAS through this exemption will allow us to do so. We are prepared to follow strict safety guidelines in order to virtually preclude the risk of incidents or accidents. Additionally, exemptions have been granted based on similar petitions, such as exemptions number 11062, 11109, 11112, 11213, and 13456. Our petition is in similar interest to the public as these previous petitions. We hope to hear good news soon.
Thank you and have a great day. Please always be safe.

Irvin N. Gleim

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