NORTHLANDCOMMUNITY&TECHNICALCOLLEGEMay25,2015U.S.DepartmentofTransportationDocketManagementSystem1200NewJerseyAve.,SEWashington,DC20590Re:ExemptionRequestSection333oftheFAAReformActof2012andPart11oftheFederalAviationRegulationsfrom14C.P.R.§21,SubpartHand14C.P.R.§91.203(a)(l);14C.P.R.§91.9(b);14C.P.R.§45.23(b);14C.P.R.§91.203(a)and91.203(b);14C.P.R.§91.109(a);14C.P.R.§91.103;14C.P.R.§61.113(a)and(b);14C.P.R.§91.119;14C.P.R.§91.121;14C.P.R.91.151(a)14C.P.R.§91.405(a),407(a)(l),409(a)(2),417(a)DearSirorMadam:PursuanttoSection333oftheFAAModernizationandReformActof2012(theReformAct),TheMinnesotaStateCollegeandUniversitiesSystem,dbaNorthlandCommunityandTechnicalCollege(thepetitioner),herebyappliesforanexemptionfromthelistedFederalAviationRegulations("FARs")toallowcommercialoperationofitssUAS,solongassuchoperationsareconductedwithinandundertheconditionsoutlinedhereinorasmaybeestablishedbytheFAAasrequiredbySection3 33.NorthlandispartoftheMinnesotaStateCollegesandUniversitiesSystem(MnSCU).TheMnSCUsystemisthelargestsingleproviderofhighereducationinthestateofMinnesotaandthefifthlargestsystemofcollegesanduniversitiesintheUnitedStates.Thesystemincludes31institutions(24technicalandcommunitycollegesandsevenstateuniversities)spanning54campusesacross47Minnesotacommunitiesservingmore than435,000studentsannually.Northlandprovidesinnovativetrainingprogramsandhigh-qualitytechnicaleducation.Northlandcurrentlyoffersover110programs,whichleadtoAssociate'sinScience(AS),Associate'sinArts(AA),andAssociate'sofAppliedScience(AAS),degrees,diplomasandcertificates.Northland'saviationprogramshavearichhistoryofexcellence,qualityandinnovation.Morethan20individualsstaffNorthlandAerospace,withhundredsofyearsincombinedexperienceinaviationeducationandindustryapplications.NorthlandhasbeenofferingtheAviationMaintenanceTechnologyprogramsince1959.Theprogram,whichisaFederalAviationAdministration(FAA)Part147certifiedprogram,concentratestraininginallfacetsofrepairandinspectioninelectrical,pressurization,hydraulics,instruments,navigation,andenginesystems.NorthlandAerospacehasshowntremendousvisionandinnovationintherapidlygrowingindustryofUnmannedAircraftSystems(UAS).In2010,Northlanddevelopedthenation'sfirst1UAS Maintenance Technician program

to train students for positions

in the emerging, highgrowth UAS industry. The UAS certificate concentrates

on the maintenance
and repair of the components

of unmanned aircraft systems

to include: unmanned aircraft (UA), ground control stations (GCSs), understanding

the function
of data links or; the communication/guidance
system between vehicle and satellites (line of sight), and

a basic understanding

of computer networks and their functionality within UAS. In 2011, Northland developed

a unique Imagery and Geospatial Analysis program

as a result of growing demand for technicians educated

in collection, processing and product development

of imagery and information data for diverse industries. On April11, 2014 Northland received

a Certificate

of Authorization 2013-CSA-107

to operate the proposed aircraft
in Roseau County, MN to research applications ofUAS

in precision agriculture practices. Operations were conducted over the 2014 growing season under this COA without any incidents

or accidents.

As
a result of these operations and the continued interest by other programs

in the Minnesota State Colleges and Universities System, Northland

is requesting an exemption

to continue building education, training and awareness
for UAS operations and applications. Northland also has

a pending National Science Foundation Advanced Technological Education Project Grant, which would be greatly enhanced

as it focuses on developing education and pathways around

U AS technology. With this exemption Northland

is seeking
to: Conduct UAS flight operations
for education and training purposes. Conduct UAS flights
to develop marketing and career pathways materials. Conduct UAS flights
in support
of research projects. Approving these exemptions

for Northland will create

a great benefit
in increasing access
to UAS education and training, leading

to safe operating environments
and discoveries

in many industries that will benefit from the technology, ultimately

in the public interest. Operations under the exemption will be subject

to strict operating requirements
and conditions

to ensure
at least an equivalent level of safety
to currently authorized operations using manned aircraft and under conditions

as may be modified
by the FAA as required
by Section 333. As described more fully below, the requested exemption would permit the operation

of sUAS by the applicant
for commercial
use under controlled conditions

in airspace that is (1) limited; (2) predetermined;

(3) controlled

as to access; and

( 4) would provide
an increased level of safety beyond that existing when fixed or rotor wing manned aircraft are used to accomplish
the same purpose. Northland would operate

a fixed-wing sUAS, weighing 4lbs. or less, including payload. The UAS operates under normal conditions

at a speed of no more than 50 mph.
It will operate

in line of sight over uncongested airspace

as depicted
on VFR and WAC sectionals. Such operations 2will ensure that the sUAS will not create

a hazard
to the users of the National Airspace System
or the public. Considering

the equivalent level of safety and reduction

in environmental impacts (including reduced emissions associated with allowing sUAS for the proposed operations),
the grant of the requested exemptions

is in the public interest. While Northland

is filing this exemption request on its own behalf,

it anticipates that its industry partners and other MNSCU institution,

in the future, will file exemption applications

to allow them to operate the Vireo sUAS
in commercial operations

as well. Northland will work with these entities

to ensure similarity

to this exemption application. Northland

is submitting under

a request for confidentiality

the following documents

in support
of this exemption application

for the Vireo sUAS: Vireo Training Manual (Exhibit

1), currently approved FAA COA granted

to Northland vetting the systems and operation (Exhibit
2). Consistent with the requirements

of 14 C.P.R.

§ 11.81, Northland provides the following information

in support
of its petition for exemption: The name and address
of petitioner

is: Minnesota State Colleges and Universities dba Northland Community
and Technical College Attn: Curtis Zoller 13892 Airport Drive Thief River Falls, MN 56701 Phone: (218) 683-8831 Fax: (218) 683-8994 Email: jonathan.beck@northlandcollege.edu AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply
to civil aircraft that have the characteristics

and that operate with the limitations listed herein. These limitations provide for an exceptional level of safety
to operations. These limitations

and conditions

to which Northland agrees
to be bound when conducting commercial operations under an FAA issued exemption include:

1. Safety will be the first and foremost consideration

in any sUAS operation. 2. The sUAS will weigh less than four lbs. 3. Flights will be operated

at an altitude
of no more than 400 feet AGL and will not be conducted within navigable airspace. Flights will be conducted only in VLOS during daylight hours and in VFR conditions 4. The sUAS operator will obtain training
in accordance with Original Equipment Manufacturer (OEM) guidelines

to become certified

in the proper safety and operations ofthe sUAS. 5. The sUAS operator will hold

a recreational

or sport pilot certificate. 6. The sUAS operator will hold at least

a driver's license

to satisfy the medical requirement.

37. Prior to a sUAS flight, an area of operation will be established. This area of operation will include

a defined lateral and vertical area, where the sUAS will operate. 8. Coordination
will be made with all persons and property owners within the area of operation. 9. The operator will have received training

in general operations

of sUAS and up-to-date information

on the particular sUAS
to be operated

as required. 10. If the sUAS loses communication

for longer than 30 seconds, the sUAS

is preprogrammed
with

a contingency plan which will be in a place
to safely terminate flight 11. If the sUAS loses its GPS for longer than 10 seconds, the sUAS has the capability

to begin

a circular landing near its current location. 12. The sUAS operator has the capability

to abort

a flight plan and manually
fly the aircraft
in case ofunpredicted obstacles, emergencies

or other events. 13. The sUAS will at all times give way to all other aircraft. 14. Flight planning will include flight completion with at least 10% battery power remaining

or appropriate timing
as measured

by the sUAS reported
on the ground control station. 15. A briefing will be conducted

in regard
to the planned sUAS operations prior to operation

at each new location. All personnel who will be performing duties within the boundaries

of the area of operation will be present for this briefing. 16. The sUAS operator will comply with all appropriate laws and regulations

of state, county
or city jurisdictions, including local law enforcement,
fire, or other appropriate governmental agencies. 17. Written,

to include electronic, and/or oral permission from the relevant property owners will be obtained prior to an operation. 18. The sUAS will operate, under normal conditions,

at a speed of no more than 50 mph. 19. Operations will not be conducted closer than

5 nautical miles from any airport
or heliport without prior coordination with the airport operator and the airport air traffic control tower,
if applicable. 20. A Notice
to Airmen ("NOT AM") will be issued not more than 72 hours
in advance
of flight, but not less than 48 hours before flight. EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Northland seeks an exemption

to operate Vireo sUAS for compensation

or hire within the national airspace system (NAS). The Vireo sUAS

is comprised

of a fixed wing fuselage, electric rechargeable battery power source, and sensor payload. The Vireo sUAS has
a maximum gross weight of approximately
four (4) lbs., and has

a wingspan

of 3.2 feet and

a length of 1.9 feet. The Vireo sUAS

is equipped with

a single propeller driven by an electric motor and Smart battery technology,
and is gimbal stabilized. The sensor payload includes multispectral
HD video and IR video sensors swappable with

a variety of other sensors.

It is hand launched and automatically lands with

a rugged belly landing. Northland

is currently operating the Vireo UAS safely within the NAS in northern Minnesota pursuant

to a COA (2013-CSA-107) granted by the FAA in 2014. 4Northland requests
an exemption

to the following regulations

as well as any additional regulations that may technically apply
to the operation

of sUAS. A.
14 C.F.R.

§ 21, Subpart Hand
14 C.F.R.

§ 91.203(a)(l)- Airworthiness certificate B.
14 C.F.R.

§ 91.9 (b)- Flight manual, marking, and placard requirements C.

14 C.F.R.

§ 45.23(b) Markings ofthe Aircraft) D.
14 C.F.R.

§ 91.203(a) and 91.203(b)- Certificate requirements E.
14 C.F.R.

§ 91.109(a)- Flight instruction F.
14 C.F.R.

§ 91.103- Preflight Action G.
14 C.F.R.

§ 61.113(a) and (b)- Private pilot privileges and limitations H.

14 C.F.R.

§ 91.119- Minimum safe altitudes I.
14 C.F .R.
§ 91.121

- Altimeter Settings J.
14 C.F.R. 91.151(a)- Fuel requirements

for flight in VFR conditions K.
14 C.F.R.

§ 91.405(a), 407(a)(l), 409(a)(2), 417(a)- Maintenance inspections In detail: A. 14 C.F.R

. .§ 21, Subpart

H

- Airworthiness Certificate and 14 C.F.R

. .§ 91.203(a)(l) Northland seeks an exemption from 14 C.F.R. Part 21, Subpart
H, which establishes
the procedural requirements

for the issuance
of airworthiness certificates

as required
by 14 C.F

. R. Section 91.203(a)(l). Given the size and limited operating area associated with the sUAS
to be utilized
by the petitioner
for Part 21 Subpart
H, it meets the requirements

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement

for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity

to airports and populated areas of the particular sUAS. In all cases, an analysis
of these criteria demonstrates
that the sUAS operated without airworthiness certificates,

in the restricted environment
and under the conditions proposed will be at least as safe, or safer, than

a conventional fixed-wing aircraft
or rotorcraft operating with an airworthiness certificate without the restrictions
and conditions

of the proposed sUAS operations. Each sUAS
to be operated hereunder weighs less than

4 lbs. fully loaded, carries neither

a pilot nor passenger, carries no explosive materials

or flammable liquid fuels, and operates exclusively within

a secured area. Unlike other civil aircraft, the proposed operations

in this petition for exemption will be controlled and monitored

by the operator. These safety enhancements, which already apply
to civil aircraft operated

in connection with existing inspection operations, provide

a greater degree of safety
to the public and property owners than conventional operations conducted with airworthiness certificates issued under
14 C.F.R. Part 21, Subpart
H. Lastly, application

of these same criteria demonstrates
that there
is no credible threat to national security posed by the sUAS, due to their size, speed of operation, location
of operation, lack of explosive materials

or flammable liquid fuels, and inability

to carry a substantial external load.

5B.14C.F.R..§91.9(b)-FlightManual,Marking,andPlacardRequirementsNorthlandseeksexemptionfromtheflightmanual,marking,andplacardrequirementsoftheFARsbecausetheVireosUASweighsapproximatelyfour(4)lbs.atitsmaximumgrossweightandduetothesizecannotcarrytheapprovedairplaneflightmanualonboard.Furthermore,sincetheVireosUASisunmanned,theaircrewmemberislocatedatagroundcontrolstation.Assuch,NorthlandproposesthefollowingconditionsandlimitationstoitsrequestforexemptionfromSection91.9(b):Theapprovedairplaneflightmanualmustbekeptatthegroundcontrolstation,whereitisimmediatelyavailableforreferencebytheaircrewmember(pilotincommand)oftheVireosUASanytimetheunmannedaircraftisoperating.Theapprovedairplaneflightmanualmustbemadeavailablewithin10daystoanyFAA,U.S.DepartmentofDefense,orlawenforcementofficialuponrequest.Inorderofidentifytheaircraft,thepetitionerproposesthattheinformationfoundontheregistrationcertificatebepermanentlyaffixedtotheaircraft:Manufacturer:NorthlandCommunityandTechnicalCollegeModel:VireoAirVehicleSerialNumber:XXXXXRegistrationNumber:XXXXXC.14C.F.R..§45.23(b)Markingso{theAircra{t),states:WhenmarksincludeonlytheRomancapitalletter"N"andtheregistrationnumberisdisplayedonlimited,restrictedorlight-sportcategoryaircraftorexperimentalorprovisionallycertificatedaircraft,theoperatormustalsodisplayonthataircraftneareachentrancetothecabin,cockpit,orpilotstation,inlettersnotlessthan2inchesnormorethat6incheshigh,thewords"limited","restricted","light-sport","experimental",orprovisional",asapplicable.InpreviousGrantofExemption,theFAAdeterminedthatexemptionfromtheserequirementswaswarrantedprovidedthattheaircraft"haveidentifications(N-Number)markingsinaccordancewith14CFRPart45,SubpartCifthemarkingsareaslargeaspracticable."FAADocketNo.FAA-2014-0352.PetitionerwillmarkallaircraftwiththeirN-Numberinaprominentspotonthefuselagewithmarkingsthatareaslargeaspracticable.D.14C.F.R..§91.203(a)and91.203(b)-CertificateRequirementsNorthlandrequestsexemptionfromtherequirementofSection91.203(a)(i.e.,thatanappropriateandcurrentairworthinesscertificateandaneffectiveU.S.registrationcertificatebecarriedwithintheaircraft),andfurther,requestsrelieffromtherequirementofSection91.203(b)(i.e.,thattheairworthinesscertificatebedisplayedatthecabinorcockpitentrancesothatitislegibletopassengersorcrew).AstheVireosUASisunmanned,ithasnocabin,cockpit,pilotstation,orentrancesthereto.Therefore,theaircrewmemberislocatedatagroundcontrol6station and no passengers
are carried

at any time. As such, Northland proposes the following conditions and limitations

to its request for exemption from Sections 91.203(a) and (b): The documents required
by Sections 91.203(a) and (b) must be kept at the ground control station, where

it is immediately available

to the aircrew member (pilot in command) ofthe Vireo sUAS any time the unmanned aircraft

is operating. The documents required
by 91.203(a) and (b) must be made available within
10 days to any FAA, U.S. Department

of Defense,

or law enforcement official upon request. The FAA has issued numerous exemptions

to this regulation.

A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. E. 14 C.F.R

. .§ 91.109(a)- Flight instruction Northland requests exemption from Section 91.109(a) provides 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. sUAS and remotely piloted aircraft,
by their design typically

do not have fully functional dual controls. Flight control

is accomplished through the use of a ground control station that communicates
with the aircraft via radio communications.

The Vireo ground control station

is based on a computer and while

it does not offer

a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands-on"
the controls during flight, we feel that this technique meets the intent 91.109 and provides
an equivalent level of safety. The equivalent level of safety

is provided
by the fact that neither

a pilot nor passengers will be carried
in the aircraft and by the size and speed of the aircraft. The FAA has approved exemptions

for flight training without fully functional dual controls for
a number
of aircraft and for flight instruction

in experimental aircraft. See Exemption Nos. 5778K and 9862A. Also, see most recent exemption approvals
for Astraeus Aerial, Aerial MOB. HeliVideo Productions,
RC Pro Productions. Snaproll Media and Pictorvision

for further justification

of approval. F. 14 C.F.R

. .§ 91.103 -Preflight Action Northland request exemption from the requirements

of Section 91.103. Section 91.1 03 requires

a PIC to become familiar with specific information before each flight, including information contained

in the FAA-approved Flight Manual
on board the aircraft. While the PIC will be familiar with all information necessary

to safely conduct the flight, an exemption

is requested

to the extent that an FAA-approved Flight manual

is required. An equivalent level of safety will be provided
by following
the Aircraft Operations Manual and flight manual provided
by the manufacturer.
The PIC will take all required preflight actions, including performing

all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas, before initiation
of flight.

7G. 14 C.F.R

. .§ 91.119 -Minimum safe altitudes Northland requests exemption from the requirement

of Section 91.119. Section 91.119 prescribes
the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle,

or structure

in non-congested areas. To provide the intended aerial surveys and inspections,

the sUAS are normally operated below 400 feet AGL. In addition, due to the nature of the proposed operations,
the operator may at times be less than 500 feet away from structures during the operation. Compared

to flight operations with conventional fixed-wing aircraft and rotorcraft weighting
far more than the maximum

4 lbs. proposed herein, and the lack of flammable fuel, any risk associated with these operations

is far less than those presently presented with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where they will be operated.
As described,
the sUAS will be operated

in a restricted area, where buildings and people will not be exposed

to operations without their preobtained consent. No flight will be taken without the permission

of the relevant property owner and/or local officials

. Because
of the advance notice
to the property owner and participants,

all relevant affected individuals will be aware of the planned flight operations

as set forth herein. Furthermore,

by operating

at such lower altitudes, the sUAS will not interfere with other aircraft that are subject

to the minimum safe altitude regulations. H. 14 C.F.R

. .§ 61.113(a) and (b)- Private pilot privileges and limitations Section 61.113(a) limits private pilots
to being
in command

of non-commercial flights. Section 61.113(b)(1) provides

an exemption that allows

a private pilot to command

an aircraft without passengers

or property,

in connection with business

or employment if"[t]he flight

is only incidental

to that business

or employment."
That exemption likely does not apply to the proposed operations under this petition for exemption,

as the flights are not incidental

to the proposed aerial surveys and inspections
but rather essential

to it. Accordingly,
this petition seeks an exemption

to § 61.113 (a)'s commercial limitation and/ or Section 61.113 (b)( 1)' s requirement that the flight be incidental

to the business

to benefit from the exception. The purpose
of 61.113

is to ensure that the skill and competency

of any PIC matches the airspace in which the PIC will be operating,

as well as requiring certifications

if the pilot
is carrying passengers

or cargo for hire. In this case, while the sUAS will be operated

as part of a commercial operation, but unlike

a conventional aircraft that carries the pilot and passengers,
the sUAS are remotely controlled with no living thing on board. Additionally,

the area of operation is controlled,
and all flights are planned and coordinated

in advance. The level of safety provided
by the requirements outlined exceeds that provided
by the F ARs for
a single individual holding

a commercial pilot's certificate operating

a conventional aircraft
in accordance with Sections 61.113 (a) and (b). The level of risk associated with the operation

of small, lightweight UAS
is less than the level of risk associated with commercial operations contemplated

by Part 61 when drafted

- that is, allowing the proposed operations

in this petition for exemption exceeds the present level of safety achieved
by Sections 61.113 (a) and (b). I. 14 C.F.R

. .§ 91.121-A/timeterSettings

8Section 91.121 provides that aircraft shall maintain cruising altitudes
by reference

to an altimeter setting available within

1 00 nautical miles of the aircraft. The aircraft will fly below 400 feet AGL and will not need to maintain hemispherical cruising altitudes

in order to de-conflict with other aircraft. As such, an appropriate altimeter measurement presented

to the pilot should be Above Ground Level and should be based on the barometric pressure

at the point of launch. To provide
an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground prior to every flight. Since the aircraft will fly no more than 50 minutes, even rapid changes

in barometric pressure will have limited effect on the safety of the flight. Additionally,

the aircraft maintains cruise altitude mostly from GPS altitude readings,

so rapid fluctuations

in atmospheric pressure will have even less of an effect. Given these conditions

an equivalent level of safety

is provided

in line with previous exemption to Astraeus Aerial, Docket No. FAA-2014-035

2
. J. 14 C.F.R. 91.151(a)- Fuel requirements

(or {light
in VFR conditions This regulation prohibits

an individual from beginning

"a flight in an airplane under Visual Flight Rules (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;

or (2) At night,
to fly after that for at least 45 minutes." The Vireo batteries provide approximately

60 minutes
of powered flight without posing risk to the battery system. This allows
to cover approximately

a quarter section
or standard field size in agriculture. Without
an exemption from

§ 14 CFR 91.151, the U AS's flights would greatly limit the system's ability
to perform effectively. Given the limitations

on its proposed operations and the location
of those proposed operations, and daylight only VFR flight conditions,

a longer time frame

is reasonable. Northland believes that an exemption from 14 CFR

§ 91.151 (a)

is safe and within the scope of a prior exemption. Operating
the sUAS, without
30 minutes
of reserve fuel does not engender the type of risks that Section 91.151(a) was meant
to prevent given the size and speed
at which the sUAS operates. The fact that it carries no pilot, passenger,

or cargo also reduces
its liability. Additionally, limiting Vireo flights
to 30 minutes would greatly reduce their utility.
In the unlikely event that the Vireo should run out of fuel,
it would simply land. Given its weight and construction material, the risks are less than contemplated

by the current regulation. Northland believes that an equivalent level of safety can be achieved
by maintaining

10 min battery reserve and would be more than adequate

to return the sUAS
to its planned landing zone from anywhere

in its operating area. Similar exemptions have been granted

to others, including Exemptions 2689F, 5745, 10673, 11311 and 11062. K. 14 C.F.R.

§ 91.405(a), 407(a)(1), 409(a)(2), 417(a)- Maintenance inspections Section 91.405(a) requires that an aircraft operator

or owner "shall have that aircraft inspected

as prescribed

in subpart

E of this part and shall between required inspections, except
as provided

in 9paragraph

(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 airworthiness certificate. Section 91.417(

a) requires the owner or operator

to keep records showing certain maintenance 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. Maintenance ofthe Vireo will be accomplished

by the owner/operator pursuant

to the training manuals, such as Exhibit

1, provided

in the attachments.

An equivalent level of safety will be achieved because the sUAS

is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not
a complex mechanical device. As provided

in the attached documents (Exhibit
2), which

is included

as a part ofNorthland's existing COA, the operator
of the Vireo will ensure that the sUAS

is in working order prior to initiating flight, perform required maintenance,
and keep

a log of any maintenance
that is performed. Moreover, the operator

is the person most familiar with the aircraft and is best suited
to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. OPERATOR REQUIREMENTS Northland respectfully proposes that operator requirements
should take into account the characteristics

of the particular sUAS. Certain sUAS, such as the Vireo, are characterized

by a high degree of pre-programmed control and various built-in technical capabilities that limit the potential
for operation outside of the operating conditions

set forth above. The Vireo has
a semi-autonomous navigation and control system comprised

of a ground control station and auto-pilot system. All flights are pre-programmed
with GPS guidance and do not require human intervention. However, flight mission area and routing can be changed after launch. The operator can change the route and the altitude; however these changes are all stabilized/assisted

by the auto-pilot system, and the airspeed, altitude, and bank angle limits are all enforced
by the auto-pilot,

so that true

1 00% manual flight

is never allowed. Flights are not directed
by positive manual control, nor are evasive maneuvers.

In the case of unplanned events, the operator inputs pre-programmed evasive maneuvers from the control unit and the control unit executes that maneuver. Pre-programmed operator interventions include diversion

to the right; initiation

of holding

at present position; suspension

of mission;
fly back to launch point; fly to point and hold; abort mission and land; and emergency power cut off and land. Additional automated safety functions and safety enhancing features
of the Vireo include the following: A. Auto-pilot detection

of lost GPS or of insufficient satellites initiates

a circular landing after 10 seconds. B. Low power on the aircraft triggers
an automatic landing;

at 10.6V battery remaining
the Vireo returns

to the rally waypoint and lands;
at lOV battery remaining
the Vireo performs

a circular landing

at its current location. C. If the auto-pilot detects

a lost-link

to the ground control station for longer than 30 seconds, the Vireo returns

to the rally waypoint;

if the communication connection

is lost for more than 120 seconds, the Vireo performs the predetermined landing sequence. 10D. The Vireo
is inherently unstable,

so auto-pilot fail will result in very rapid exit from flight. E. The Vireo auto-pilot will not allow an operator

to command

a dive with greater than approximately 40mph (e.g., by changing the altitude
or using the manual override modes). F. When the Vireo

is on final descent for landing

it will limit the auto landing speed to less than 40 mph (typically, approximately

33 mph). G. In the case of a loss of propulsion power (e.g.

, motor failure), the Vireo will maintain airspeed within safe limits (between 25-40 mph), and will glide to the ground along the previously programmed flight plan. H. The aircraft

, weighing less than

4 lbs., fully loaded,

is constructed

of rugged Kevlar, carbon fiber, and form injected wings, which

is intended

to absorb impact energy. I. The motor

is driven by a pulse width modulated signal, not an analog signal. Given these safety features, Northland proposes that operators

of the Vireo should not be required

to hold

a commercial

or private pilot certification. Instead, operators should be required to have completed

a minimum

of a recreational

or sport airman certificate. SPECIFICATIONS

OF THE VIREO sUAS Endurance

> 60 minutes Weight

> 4lbs. Payloads
Multispectral sensors HD video IR video Stabilizing gimbal Flying speed

30-40 mph Typical altitude

200-400

ft. Launch

Hand launch, auto take-off Landing

Auto land, rugged belly landing Control link

900 Mhz spread spectrum Propulsion

Electric motor, Smart battery technology Material

Rugged Kevlar and carbon fiber airframe; foam core wings Maximum operating wind speeds 30mph Wireless data

WiFi imagery transfer Preflight

< 5 minutes Flight control Point-and-click professional-grade autopilot Scout planning

Auto route planning; auto area coverage Dimensions

- Wingspan

3.2 ft. Dimensions

- Length

1.9 ft. Assembly

Quick set-up; no tools PUBLIC INTEREST An opportunity exist to bridge the gaps between
an industry seeing potential

in new technology and academic training programs that can provide education
on safe operating procedures and guidelines. sUAS flights
in the NAS are becoming more frequent and many incidence have recently been reported
by unauthorized operators. Many of the individuals responsible

for these 11incidencesarenotprofessionalandhavenotreceivedformalizedtraininginsUASoperation.GrantingthisexemptionwillcontinuefurtheringeducationonsafeoperationsofsUAS.TheexemptionwillprovidetheindustrywithoperatorswhodemonstrategoodaeronauticaljudgmentbyimplementingproperriskmanagementandsafetypracticeswhileoperatingsUASintheNAS.Consistentwiththerequirementsof14C.F.R.§11.81(d),Northlandoffersthefollowingreasonswhygrantingthispetitionforexemptionisinthepublicinterest.GrantingthepresentpetitionofexemptionwillfurtherthepublicinterestbyallowingNorthlandtosafely,efficiently,andeconomicallyperformaerialdataacquisitionandagriculturalresearchinsupportoffarmersandagriculturalproductdealers.ThedatacapturedbytheVireosUASwillbeusedtohelpfarmersplantheirplantingandharvestingmethods,addressfertility,disease,andpestissuesinatimelymanner,andmarkettheircrops.Additionally,theuseoftheVireosUASsignificantlyimprovessafetyandreducesriskbyalleviatinghumanexposuretodangerandemissionsassociatedwithcurrentaerialsurveyandinspectionmethods,namelyfull-sizedmannedaircraft.IfoneoftheVireosUAScrashes,thereisnofueltoigniteandexplode.AnyimpactoftheVireosUASisfarlessthanafull-sizedmannedaircraft.Also,theuseoftheVireosUAStohelpfarmersmanagetheircropswilldecreasecongestionintheNASandreducepollutionbylesseningfarmers'anddealers'dependenceonmannedaircrafttocapturetheaerialdataoftheirrowcrops.Furthermore,therearenoprivacyissuesthatwillberaised,becausetheVireosUASwillonlybeoperatedinruralareas,withthepermissionoftherelevantpropertyowners,andinaccordancewithallFederalAviationRegulations.SUMMARYNorthlandseeksexemptionfromtherequirementsof14C.P.R.§21,SubpartHand14C.P.R.§91.203(a)(1);14C.P.R.§91.9(b);14C.P.R.§45.23(b);14C.P.R.§91.203(a)and91.203(b);14C.P.R.§91.109(a);14C.P.R.§91.103;14C.P.R.§61.113(a)and(b);14C.P.R.§91.119;14C.P.R.§91.121;14C.P.R.91.151(a)14C.P.R.§91.405(a),407(a)(l),409(a)(2),417(a)CONCLUSIONSatisfactionofthecriteriaprovidedinSection333oftheReformActof2012-size,weight,speed,operatingcapabilities,proximitytoairportsandpopulatedareas,andoperationwithinvisuallineofsightandnationalsecurity-providesmorethanadequatejustificationforgrantingtherequestedexemptionsallowingcommercialoperationofNorthlandintheagriculturalaerialsurveyindustryinaccordancewiththeexhibitappendedhereto.Ifadditionalinformationisrequired,donothesitatetocontacttheundersigned.Sincerely,AssociateDeanAerospaceProgramsNorthlandCommunityandTechnicalCollege12