Harrison Wolf

Wolf UAS & McQuin Engineering

6033 W Century Blvd., Suite 920

Los Angeles, Ca. 90045

310-342-1352

Harrisow@usc.edu

Aug 13, 2015

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”), I, Harrison Wolf

hereby request a determination by the Secretary of Transportation authorizing conduct of commercial 

operations of its UAS for the purposes of aviation education focusing on Human Factors, Aircraft 

Accident Investigation, Safety Management Systems in the use of small Unmanned Aircraft Systems. 

Pending a grant of exemption, I will provide in-class flight scenarios for the application of unmanned 

aircraft safety theory as developed based on ICAO, FAA, and international CAA leading regulation in 

conjunction with Mc Quin Engineering and Wolf Unmanned Aircraft Systems. 

A secondary use for the UAS will be in the videography, photography, and aerial surveying use of UAS. 

These industries have exhibited the need for Unmanned Aircraft to replace fully manned aircraft 

providing new vantage points, increased safety, and the reduction of environmentally unfriendly fuel 

sources

Wolf UAS will be using unmanned aircraft systems manufactured by DJI (To include the DJI Vision 2+, 

DJI Inspire, and DJI Phantom 3). Operations will be conducted within and under the safeguards outlined 

herein and as may be established by the FAA under FMRA Section 333(c).

I also petition for exemptions as necessary to effect the determination requested pursuant to FMRA

Section 333. The attached documentation includes detailed exemption requests that demonstrate how 

these exemptions are in the public interest and will maintain at least an equal

level of safety to existing regulations.

Authorizing my pilot (fully licensed private pilot with over 180 hours logged) and I to conduct 

commercial, educational UAS operations would enhance the industry’s knowledge of conducting safe and 

secure operations using state-of-the-art academic theories as developed at the USC Aviation Safety & 

Security Program. Further, use of this UAS in these operations offer a safer, more realistic, flight 

environment. While this serves to protect those involved in the operation directly, indirectly, these 

training scenarios and application of safety theory will improve safety of the public exponentially. 

Wolf UAS and McQuin Engineering will conduct the UAS operations in a manner that will meet, and in 

many cases exceed, the current level of safety of commercial helicopter and UAS operations already 

undertaken in the NAS. We will employ UAS that are under 12 lbs., have a low noise signature, and carry 

no volatile fuel (other than LiPo batteries and will have all necessary mitigations in place for battery 

protection), which will limit collateral damage in the event of catastrophic failure. We will fly well below 
the velocities that make a risk based approach to public safety necessary to prevent operations.

The low expense of operation and the dire need for demonstrated operations of safety theory and 

application in a classroom environment necessitate this type of flight, while the ever increasing demand 

for aerial footage without manned operations further define this need to the public.. For these reasons, 

granting an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for 

these commercial purposes benefit the public interest in the following ways:

 Increased public and industry awareness regarding safe and responsible utilization of UAS and 

the development of community safety education for all levels of operator.

 Increased economic wellbeing to local businesses via cost reductions, and increased insurance 

savings for operators certified in Safety Management Systems for Remotely Piloted Aircraft.

 Enabling aerial business solutions to be available to a larger market through proper safety 

knowledge and regulatory understanding.

 Industry acceptance of ICAO, FAA, and international CAA standards through experiential and 

well established safety knowledge and application to UAS.

 Aerial footage that would otherwise be unable to be attained or a nuisance to the public due to 

noise, gasoline combustion, or safety incursion. 

 The proven application of Aviation Safety & Security techniques following the curriculum 

developed by the USC Aviation Safety & Security Program in the following topics:

o Safety Management Systems for Remotely Piloted Aircraft

o Aviation Security Program Management

o Aircraft Accident Investigation

o Human Factors in Aviation & Human Factors for Remotely Piloted Aircraft

I appreciate you consideration of this application for Exemption. 

For further information and amendments including Flight Operations Manual, Safety Management 

Systems Manual, Pilot Training Records, or Maintenance and User Manuals for DJI Phantom 3 please do 

not hesitate to contact me at: 

Harrison Wolf

6033 W. Century Blvd, Suite 920

Los Angeles, CA 90045

310 342 1352

Harrisow@usc.edu
Submission of Request for Determination under Section 333 of the FAA Modernization and 

Reform Act and Exemptions under 14 C.F.R. Section 11.81

Table of Contents

I. Regulations – Exemptions Requested

II. Commercial Operation/Operator

III. Unmanned Aircraft System (UAS)

IV. UAS Pilot-in-Command (PIC)

V. Public Interest

VI. Summary

VII. Appendix A – Phantom Vision 3 Operating Documents

I. Regulations – Exemptions requested

Pursuant to 14 C.F.R. § 11.81(e), I, Harrison Wolf, seek exemption from the below mentioned

regulations and provide reason as to why the exemption should be approved based on the level of

safety at least equal to that of which the rules require.

- 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

Establishes: The procedural requirements for the issuance of airworthiness

certificates as required by 14 C.F.R. § 91.203(a)(1). Given the small size of the UAS and the 

operational mitigations that will be taken as outlined below, an exemption from Part 21 Subpart 

H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the 

FMRA with consideration “of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAS.”

- 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

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.

My UAS will ensure compliance with § 45.29(f) to meet the intent of the regulation by

displaying the registration number in the largest practicable lettering.

- 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) – Private and Commercial Pilot Privilege

and Limitations

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- 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this

section, no person who holds a private pilot certificate may act as pilot in

command (PiC) of an aircraft that is carrying passengers or property for compensation

or hire; nor may that person, for compensation or hire, act as pilot in command of

an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in
command of an aircraft in connection with any business or employment

- 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a

commercial pilot certificate may act as pilot in command of an aircraft – (ii) For

compensation or hire, provided the person is qualified in accordance with this part

and with the applicable parts of this chapter that apply to the operation.”

Currently, there are no applicable areas identified for UAS in either the private or the

commercial sector and therefore an exemption is required to conduct commercial

operations. As flight operations will be conducted with an abundance of caution

following the procedure outlined below, my operations will achieve an equivalent level of

safety for each individual flight especially when compared to commercial flights

identified in Part 61 when originally developed. My operation will be conducted with

pilots who hold, at a minimum, a private certificate of any category or class and a 3rd

class medical. I, Harrison Wolf, hold a UAV Basic Flight Training Certification and am 

currently participating in private pilot training. 

- 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

“No person may operate a civil aircraft unless it is in an airworthy condition.

Currently there is no airworthiness certificate for 3DR UAS. Daily pre and post flight

inspections will be accomplished in accordance with manufactures maintenance

manual(s) and guidance. During flight, the PiC will adhere to § 91.7(b) and abort air

operations immediately upon identification of an in-flight emergency or other unsafe

condition. By complying with procedures outlined by the manufacturer, an equivalent

level of safety will be achieved.

- 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements

“(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available

in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved

manual material, markings, and placards, or any combination thereof.”

By keeping all operating documents, manuals, authorizations and exemptions in a binder

co-located with the GCS, I can meet the intent of the regulations and therefore achieve an

equivalent level of safety. Further, my work at USC Aviation Safety & Security Program has led 

to the adoption of a Safety Management Manuals (SMS) and SMS related Operational Risk 

Assessments that will always be present at GCS. 

- 14 C.F.R. 91.109(a) – Flight Instruction

“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 majority of sUAS by design are developed with single operational control through

the use of pre-determined GPS enabled waypoints programmed before or during flight in

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addition to the use of a single hand held transmitter or control station controlled by the

PIC. The design does not allow for dual controls during flight training and therefore the
exemption is requested to train operators, build experience, and maintain proficiency. An

equal level of safety will be achieved by conducting all training in stile environment.

Training sessions will be accomplished separately from flights conducted for

compensation or hire.

- 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

“Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes: (b) Over any congested area of a city, town, or

settlement, or over any open air assembly of persons, an altitude of 1,000 feet

above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. 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. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If

the operation is conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in

paragraph (b) or (c) of this section, provided each person operating the helicopter

complies with any routes or altitudes specifically prescribed for helicopters by the

FAA.”

Commercial UAS operations will be conducted at or below 200 ft. AGL as a function of the 

sought blanket CoA flight arrangement. I will not be seeking a COA above 200 ft. Given the 

size, weight and lack of fuel; combined with operation limitations listed below, the operation

will be conducted with a greater level of safety than exists with current manned aviation

operations.

- 14 C.F.R. 91.121 – Altimeter Settings

“Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating...”

SUAS are equipped with Global Positioning System (GPS), which provide altitude and

geo-location data to the operator without utilizing an altimeter. Due to this fact, an

exemption is required. GPS are precise within a few feet and combined with fail-safes

and a visual observer the operation will meet an equivalent level of safety. Further, the Phantom 

3 system combines GPS location technology with downward facing optical location technology 

that allows for minimal lateral movement without GPS connection. In this way, it prevents Lost 

Link scenarios when GPS signal is lost or degraded. 

- 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

“No person may begin 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)

During the day, to fly after that for at least 30 minutes;”

This regulation is written based on the capabilities of a traditional aircraft, which have
flight times of several hours or greater; therefore, with the majority of sUAS which have

flight times of only an hour or less, this regulation would effectively deny the ability of

the air vehicle to operate.

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The Phantom 3 displays a visual and emit an audible low battery alert at 25% at which

time the UA will automatically engage the landing sequence. Based upon that safeguard

and the small operational area in VLOS, the operation can meet an equivalent level of

safety through these operational risk mitigations. 

- 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance

Inspections

-91.405(a) States: Each owner or operator of an aircraft—(a) 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

-91.407(a)(1) States: (a) No person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has

been approved for return to service by a person authorized under § 43.7 of this

chapter

-91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no

person may operate an aircraft unless, within the preceding 12 calendar months, it

has had—(2) An inspection for the issuance of an airworthiness certificate in

accordance with part 21 of this chapter. No inspection performed under paragraph

(b) of this section may be substituted for any inspection required by this

paragraph unless it is performed by a person authorized to perform annual

inspections and is entered as an ‘‘annual’’ inspection in the required maintenance

records.

-91.417(a) & (b) States: (a) Except for work performed in accordance with §§

91.411 and 91.413, each registered owner or operator shall keep the following

records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i

– iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for

the periods prescribed: (paragraphs 1 – 3)

Because DJI Phantom 3 UAS at present do not have airworthiness certificates, these regulations 

do not apply and therefore an exemption is required. Pre/Post flight inspections and

maintenance will be conducted in accordance with the manufacturer’s guidance as stated

in the operations manual. In addition, to meet the intent of these regulations, I will

maintain daily logs of pre and post flight inspections. If maintenance is required, a

dedicated test flight will be conducted to ensure safety before resuming commercial

operations. All inspection, maintenance and alterations will be documented and

maintained in a record. These actions will meet the intent of the regulations from which

exemption is being requested and lead to an equivalent level of safety.
II. Commercial Operator/Operation

I will be the sole operator and pilot of the DJI Phantom 3 conducting flight safety demonstrations 

for the University of Southern California’s Aviation Safety & Security Program. While for the 

last two years we have been conducting these SMS and Human Factors Training flights indoors 

– in an accident investigation training hangar in East Los Angeles, California. 

I have approximately 3 years of experience operating UAS in hobbyist and AMA run airspace 

having conducted training with the UAV University Basic Flight Training (16 hour ground 

school and 10 hour flight training). 

7

I am a UAS subject matter expert and am currently teaching in academia at the University of 

Southern California’s Aviation Safety & Security Program within the Viterbi School of 

Engineering. I hold the USC Aviation safety & Security Certifications in Safety Management 

Systems for Remotely Piloted Aircraft, Human Factors in Aviation, Aviation Security Program 

Management, and Threat and Error Management. I am the current ASTM F-38 s task l;eader for 

developing Best Practices in Operational Risk Assessment for sUAS and plan on applying this 

knowledge of operational risk to mitigations of hazards; both active and latent.

I have roughly 200 hours of document flight time as a hobbyist and 50 hours of in-hangar 

documented flight hours for course work demonstrations at the USC School of Engineering. 

I am extremely knowledgeable in Human Factors awareness; Crew Resource Management; and 

Risk Management as well as Safety Management Systems. I will apply those principles to my 

operation.

For each flight, I:

 Will contact the controlling air traffic organization to issue a NOTAM.

 Will conduct a preflight briefing with any present.

 Will conduct a comprehensive worksite inspection and analysis, identifying limits of

environment or property.

 Will conduct preflight planning in accordance with Section 91.103 Preflight Action.

 Will operate in those areas only with the consent of the landowner or designated

representative.

 Will identify potential obstructions or other hazards to safe operation and document 

those hazards in accordance with my SMS manual.

 Will clear the area of personnel or bystanders that are non-essential to the operation,

And maintain at a minimum, 500 feet away from non-participating persons.

 Will conduct a preflight safety briefing to Visual Observer (VO) and participating

persons.

 Will at all times yield to manned air traffic.

 Will operate within VLOS of both PIC and VO during daylight hours only.

 Will maintain voice communications with VO and participating persons.

 Will operate under Class D visual flight rules, defined as 500 feet below and 2000 

feet horizontal from clouds with a minimum of 3 statute miles of visibility.
 Will not exceed an altitude 400 feet AGL as determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a binder 

collocated with the GCS.

 Will immediately terminate flight, in the safest manner possible, when safety to 

persons or property become compromised.

 Will terminate flight, in the safest manner possible, when unable to comply with these

limitations or any other limitations granted as part of this exemption.

In order to remain at an altitude at or below 200 feet AGL, relief is needed from Section 91.119

(c) and (d). By following these operating standards, the commercial operation will meet an

equivalent level of safety to the regulation in which relief is sought.

8

III. Unmanned Aircraft System

I seek an exemption to operate the DJI Phantom 3 for commercial purpose. The DJI Phantom 3 is 

the primary aircraft in our operation for which we seek exemption. We will also be utilizing the 

DJI Phantom Vision 2+ and so wish to include that platform in this exemption as well. The DJI 

Phantom series utilizes a common autopilot system and common ground control station software 

(GCS). The UAS will be flown via a combination of RC control, cellular phone relay, and tablet 

control. The DJI Phantom series are quadcopter, electric powered UAS. 

The DJI Phantom series has a top speed of 33.6 MPH though it will be flown as per operational 

guidance no greater than 15 MPH. The UAS are powered by 5200 mAh lithium-polymer 

batteries. The UAS will carry integrated, onboard 4K HD cameras when with payload..

The UAS also has several fail-safes for loss of RC signal, loss of GPS, and low battery as

outlined in the respective Operation Manuals. The UAS display a visual and emit an audible low

battery alert at 25% at which time the UA will automatically engage the landing sequence. Based

upon that safeguard, I request exemption from Section 91.151(b) Fuel requirements for flight in

VFR conditions.

The UA also has a geofence “No Fly” function that will prevent the flight into unauthorized 

environments as developed by DJI manufacturing. While I will not rely on this function, it is a 

safeguard worth mentioning. I will maintain situational awareness of all airspace through the use 

of the BETA test for FAAs B4UFLY smartphone app as well as the Airmap.io map. These will 

be monitored continuously by student participating in the course being taught, the information 

will be relayed via crew chief to PiC.

I will not have an installed barometric altimeter and will rely on GPS to determine altitude and

speed. Given the aircraft will be operated within VLOS with the aid of a VO, I believe the

operation can be conducted with an equivalent amount of safety and therefore request exemption

from Section 91.121

Given the size, weight, speed, and controlled operating area associated with the UA to be

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §

91.203 (a) and (b) is requested. I seek exemption from § 45.23 Marking of the aircraft. The UA

will display the registration number in the largest practicable lettering. He wished to be exempt
from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections will

be conducted according to operations manual and prudent judgment as previously outlined to

determine the integrity and safety of the UAS and associated equipment. Further, I require relief

from 91.7(a), which prohibits the operation of an aircraft without an airworthiness certificate and

91.9(b) (2) requiring an approved flight manual in the aircraft. 

The UAS will not be operating with an airworthiness certificate therefore, this would be 

inappropriate. The UAS are too small to carry the operating documents so an equivalent amount 

of safety can be achieved through keeping the operating documents and manuals at the GCS.

IV. UAS Pilot in Command (PIC)

9

I request an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in 

command. All UAS PICs will have logged, in accordance with 61.51 (b), appropriate training on 

the UA consisting of 25 hours as UAS rotorcraft, 10 hours multirotor UAS or 25 hours as UAS 

airplane, 10 hours single-engine as appropriate. PICs will maintain recent flight experience on 

the UAS. Training and experience flights will be conducted separate from commercial 

operations.

The chief pilot for commercial operations will be Christopher McQuin. He is a certified private 

pilot (License # 3032255) with 166 hours of logged flight hours in the Northrop T-38C Twin-Jet 

Trainer aircraft and Cessna T-37. He has a further 82 hours logged in various small single engine 

aircraft. Throughout his time in the Air Force, Christopher McQuin learned the facets of aviation 

safety, aeronautical knowledge, and the necessary experience to control situational awareness in 

a variety of environments throughout flight. Further, Chris McQuin is an MIT Aerospace

Engineer with management experience in developing innovative technologies with the National 

Aeronautics and Space Administration (NASA) and SpaceX. He has an uncompromising respect 

for safety and operational risk processing and will apply that same level of respect to any and all 

operations undertaken in which he is the PIC.

Further, Harrison Wolf is pursuing his private pilot license and will likely complete it prior to 

January 1, 2016. No member of the Wolf UAS or McQuin Engineering team will operate a UAS 

for commercial reasons without a private or sports recreation pilot certification. While they will 

be involved in operations, the PIC will always hold certifications as described above to ensure

full knowledge, experience, and responsibility of the pilot. 

PIC Training and continuing education will consist of:

- Pre-flight Tasks

 Assembly and inspection of UAS

 Set-up and configuration of RC radio and GCS

 DJI Phantom 3 Operational Manual Knowledge

 SMS Manual Knowledge

 Software Update and configuration management

 System checks

 Operational Risk Assessment and CONOPS understanding

- Mission Tasks
 Pre-flight Checklist & Site-Survey

 Takeoff and landing

 Manual flight modes

 Autonomous flight modes

 Emergency Procedures

- Post-flight Tasks

 Inspection

 Shutdown

 Disassembly

 Post-Flight De-brief & Documentation

- Other Tasks

 Regulations

 Operating limitations

 Flight planning

 Safety Assurance and Safety Promotion

V. Public Interest

Given the above stated evidence, procedures, and precautions; I feel that operating my UAS

commercially for the purposes of Human Factors training, Accident Investigation with sUAS 

training, Operational Risk Assessment training, and Safety Management for Remotely Piloted 

Aircraft training is in the public interest and can only lead to greater awareness and pursuit of 

proper safety operations. 

These operations, when executed with prudence, will exceed the current level of safety as the 

regulations from which I seek exemption.

My operation will allow the training of UAS pilots from law enforcement, private and public 

commerce, utilities, agriculture, and international economic leaders focused on safety and 

security as never before possible. This will provide a much needed outlet for flight in safety 

training. My operation will be conducted with less risk of collateral damage to persons and 

property while providing a “real site location” rather an a sterile, indoor environment. 

A major factor to consider regarding the public interest is the current state of UAS operations in

the US. As a aviation educator, the need to integrate UAS into the national airspace system in a

safe, deliberate, and realistic scenario, is always at the forefront of my mind as sterilized

“simulation” training can only go so far. 

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As the technology becomes more readily available, the challenges will intensify. By allowing 

commercial educational training operations, it will enable communities to become educated in 

the proper use of this technology. As an educator, I am already working to foster positive 

awareness and safe, responsible utilization of UAS technology. Granting my exemption will 

result in a direct extension of these efforts, which is in the public interest.
VI. Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform

Act of 2012”, Harrison Wolf, hereby applies for authorization to conduct commercial unmanned 

aerial systems (UAS) operations for the purposes of human factors training, accident 

investigation training, operational risk assessment training, and safety management systems 

training in conjunction with aerial photography and videography. 

.

Rules in which I seek exemption:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.113 and 61.133(a)(1)(ii)

 14 C.F.R. § 91.7(a)

 14 C.F.R. 91.9(b)

 14 C.F.R. § 91.103

 14 C.F.R. § 91.109(a)

 14 C.F.R. § 91.119

 14 C.F.R. § 91.121

 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) & (b)

Throughout this exemption request, I have shown how my expertise, and team member’s pilot 

experience, and knowledge with UAS technology will ensure the public’s best interest through 

exceptional safety oriented training, limiting risk of flight operations, and providing future pilots 

even greater access to safety theory and application.