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 U AS 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 ap plication 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 re duction 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 outlin ed 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 lice nsed private pilot with over 180 hours logged) and I to co nduct commercial, educational UAS operations would enhance the industr y’ s knowledge of conducting safe and secure operations using state

- of

- the

- art academic theories as developed at the USC Aviati on 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 operation s 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 wi ll 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 belowthe velocities that make a risk based approach to public safety necessa ry to prevent operations.

The low expense of operati on 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 u sed for these commercial purposes benefit the public interest in the fo llowing 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 saving s 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 ac ceptance of ICAO, FAA, and international CAA standards through experiential and

well e stablished 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 combu stion, or safety incursion.

 The proven application of Aviation Safety & Security techniques following the curriculum develop ed by the USC Aviation Safety & Security Program in the following topics:

o Safety Management Systems for Remotely Piloted Aircraft

o A viation 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 co ntact me at:

Harrison Wolf 6033 W. Century Blvd, Suite 920 Los Angeles, CA 90045

310 342 1352

Harrisow@usc.eduSubmission 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 requi red by 14 C.F.R. § 91.203(a)(1). Given the small size of the UAS and the

ope rational mitigations that w ill be taken as outlined below, an exemption from Part 21 Subpart H meets the require ments of an equivalent level of safety under Part 11 and Section 333 of the

FMRA w ith consideration “of the size, weight, speed, operational cap ability, and proximity to airp orts 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 l ight

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpi t, 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 pr acticable lettering.

- 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii)

– Private and Commercial Pilot Privilege

and Limitations

4

- 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 incommand 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

comp ensation 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 outline d below, my operations will achieve an equivalent level of safety for each i ndividual 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 o f any category or class and a 3 rd 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.

Curre ntly 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 Pi C 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 pl acard 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 & Secu rity 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 programme d before or during flight in

5 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 theexemption is requested to train operators, b uild 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 1,0 00 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

ma y 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 helicopte r may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopte r 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 opera tion 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 t echnology 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 fligh t 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 mi nutes; ”

This regulation is written based on the capabilities of a traditional aircraft, which haveflight 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 effect ively deny the ability of the air vehicle to operate.

6

The Phantom 3 display s 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

- 91.4 07(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’’ inspec tion 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 cer tificates, these regulations

do n ot 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

m aintain 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

maintain ed in a record. These actions w ill meet the intent of the regu lations 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 Fact ors 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 Engin eering. 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 F actors awareness; Crew Resource M anagement; and

R isk M anagement 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 obst ructions 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 remai n at an altitude at or below 2 00 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 util ize s 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 Phanto m 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 al so 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 en gage the landing sequence. Base d 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 ma nufacturing. 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 monit ored 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 exemptfrom § 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 no t 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 r otorcraft, 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 logge d 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 environment s th roughout 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 o perational risk processing and will apply that same level of respect to any and all operations undertaken in which he is the PI C.

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

Aircraf t 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.

M y 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 inte rest 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” tr aining can only go so far

. 10 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 a n educator, I am already working to foster positive

awareness a nd safe, responsible utilizatio n 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 investiga tion 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.