Lenoir Community College 

Jeffrey Jennings Program Chair Aviation 

2772 Rouse Road Extension 

Kinston, North Carolina 27863 

jliennings79@lenoircc.edu 

252-522-1735 

February 10, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

"I 

' 

Re: Exemption Request Section 333 of the FAA Reform Act (Reform Act) and Title 14 Part 11 Code of 

Federal Regulations (CFR): 14 CFR 45.23(b), 14 CFR Part 21, 14 CFR 61.113 (a) & (b), 91.7 (a), 91.9 (b) 

(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) & (b);91.405 (a), 91.407(a) (1), 91.409 (a) 

(2), 91.417 (a) & (b) for sUAS operations. 

"To Whom It May Concern: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 and Title 14 CFR Part 11, ( 

Lenoir Community College (LCC) is a developer and operator of Small Unmanned Aircraft Systems 

("sUASs") is requesting CFR exemption approval to conduct; 

• Education 

• Crew Training 

• Remote Sensor Training 

• Aerial photography applications for open set filming and photography 

LCC is applying for an exemption from the detailed CFR's listed in this letter to allow commercial 

operation of UASs so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.1 

The requested exemption would permit the operation of sUAS under controlled conditions in airspace 

that is 1) limited 2) predetermined 3) access controlled and 4) would provide a minimum equivalent 

level of safety to conventional operations. LCC can provide an infrastructure that would thereby fulfill 

the Secretary of Transportation's responsibilities to " ... establish requirements for the safe operation of 

such aircraft systems in the national airspace system," as stated in Section 333(c) of the Reform Act. 
Lenoir Community College Aviation History 

LCC Aviation was founded in 1970 by aviation professionals in Lenoir County North Carolina. The current 

program chair Mr. Jeffrey Jennings is an ATP Pilot, Flight Instructor, Ground Instructor, A&P, lA 

Mechanic. He has over 25 years of aviation experience including all areas of operations under both Part 

61 and 141. 

Regulations from,which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.109 

14 C. F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability 

• Operation of the UAS in close proximity to airports and populated areas 

• Operation of the UAS within visual line of sight of the operator 
AIRCRAFT 

LCC sUASs are battery powered fixed wing and rotorcraft aircraft weighting less than 55 lbs. (including 

payload) made of lightweight plastic, foam, composite and limited lightweight metals that meet the 

definition of sUAS. They operate, under normal conditions at a speed of no more than 50 knots and have 

the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate 

within Line Of Sight (LOS) and within a safely controlled environment. Such aircraft and operations will 

ensure that sUAS will"not create a hazard to users of the national airspace system, national security or 

to the public." 

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 at least 

an equivalent or even higher level of safety to operations under the current regulatory structure. 

These limitations and conditions to which LCC agrees to be bound when conducting commercial 

operations under an FAA issued exemption include: 

1. The sUAS will weigh less than SSibs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Flights will be terminated at 25% battery power reserve. 

4. Flights will be operated at an altitude 400 feet AGL and below. 

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 

6. sUAS will operated by LCC Student's for educational purposes. 

7. sUAS Pilot will be Pilot in Command (PIC). 

8. The UAS will only operate within a controlled area with a secure perimeter for the flight operations 

area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's flight 

activities. It will be mandatory that all personnel who will be performing duties within the boundaries of 

the safety perimeter be present for this briefing. 

10. The operator will obtain the consent of all persons involved in the operations area. 

11. Pilot and observer will receive LCC training in the mission and operation of the specific UAS. 

12. Observer and pilot will at all times be able to communicate by voice and/or text. 

16. Obtain required permissions and permits prior to operation. 
17. If the sUAS loses communications the UAS will have capability to; return to a pre-determined 

"home" location or manually flown to a landing. 

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 {a) {1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H 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 of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without 

the restrictions and conditions proposed. 

14 C.F.R. § 45.23 {b). Marking of the Aircraft 

The regulation requires: 

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," "lightsport," "experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance to the cabin, cockpit or pilot station. 

"Experimental" can be placed on the sUAS; however given the size ofthe sUAV, two-inch lettering will 

be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f) in 

the largest possible lettering practical. 

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe 

UAS as "Experimental." 

14 C.F.R. § 61.113 {a) & {b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the Pilot In Command (PIC) operating the aircraft to have a private pilot 
certificate rather than a commercial pilot certificate to operate this small UAS. Unlike a conventional 

aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on 

board. The area of operation is controlled and restricted, and all flights are planned and coordinated in 

advance. Private Pilot certification as the PIC exceeds the present level of safety achieved by 14 C.F.R. 

§61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft the use of 

maintenance procedures and use of safety check lists prior to each flight an equivalent level of safety 

will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Aircraft Flight Manual (AFM) is not required by §21.5 of this chapter, unless there is 

available in the aircraft a current approved manual, material, markings, and placards, or any 

combination thereof. 

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft. Since there is no pilot on-board it is more appropriate to have the current approved (AFM) in 

the carrying case of the respective sUAS. 

The equivalent level of safety will be maintained by keeping the AFM in the carrying case where the pilot 

flying the sUAS will have immediate access to it. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.109 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. 

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. 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. The equivalent level 

of safety 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. Control under the provision of flight training the instructor can assume 

control of the hand controller and associated "abort switch" and/or through a dual controller system. 
14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. As this exemption is for a sUAS 

DPS request exemption to operate at altitudes up to 400 AGL, or not more than 200 above an elevated 

platform from which filming is planned, an exemption may be needed to allow such operations. Flight 

operations will be conducted in a secure perimeter to ensure safety. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or via 

required permits. Because of the advance notice to the property owner and participants affected 

individuals will be aware of the planned flight operations. Compared to flight operations with aircraft 

weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft 

missions that exist below 500 Above Ground Level (AGL). In addition, the low-altitude operations of the 

sUAS will ensure separation between these smaii-UAS operations and the majority of operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption is needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the operating procedures, confirming the altitude of the field elevation as read via 

the GPS to determine the maximum flight altitude of 400' AGL. When GPS altitude is not available the 

sUAS Pilot can make conservative estimates based on local topography such as trees, buildings, antenna, 

etc. 

14 C.F.R. § 91.151{a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "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; or (2) At night, to fly after that for at least 45 minutes." Since these requirements were 

designed for primarily fossil fuel powered manned aircraft that are operating outside of the immediate 

area they are impractical for battery powered sUAS operations. Given the limitations on UAS's proposed 

flight area, battery life and the location of its proposed operations within a predetermined area, an 

alternative is necessary since most flights are shorter than 30 minutes with current battery technology. 

An equivalent level of safety can be achieved by terminating flights when 25% of battery power is 

reached. This parameter would be more than adequate to return the sUAS to a safe landing area within 

its limited operating area. 

14 C.F.R. §91.203 {a) and {b): Carrying Civil Aircraft Certification and Registration 
The regulation provides in pertinent part: 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) An appropriate and current airworthiness certificate .... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

Since sUAS weigh less than 55 lbs. and is operated without an on board pilot there is no ability or place 

to carry certification and registration documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the carrying case where 

the sUAS pilot will have immediate access to documents specific to the sUAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections (tQrtsieft~(lj)ijt~ 

llf\Sill~~j-tlgifij:l~ilif"'p;~Ql 

These regulations require 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 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished pursuant to the company 

procedures for airworthiness (software and hardware) with related maintenance record keeping in 

addition to the pre-flight duties of the sUAS pilot. An equivalent level of safety will be achieved because 

these small UASs are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. 

********* 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

DronePilotSafety seeks an exemption from the following rules: 

"14 CFR §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2};91.103(b);91.109; 91.119; 91.121; 91.151(a};91.203(a) and (b); 91.405 (a); 91.407 (a) (1}; 91.409 (a) 

(2}; 91.409 (a) (2} and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (weighing less 

than 551bs) for research and development, crew training, market survey, aerial photography applications 

for closed set filming and photography." 
Approval of exemptions allowing commercial operations of sUASs can enhance safety over conventional 

certificated aircraft especially when operated on flight missions at low altitudes at or below 400' AGL. By 

comparison, a battery powered sUAS weighing less than 55 lbs. eliminates a great portion of that risk 

especially when combined with reduced mass and lack of combustible fuel. Since sUAS will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the secure conditions outlined in 

this document will provide an equivalent level of safety to support the granting of exemptions for 

commercial operations. These lightweight aircraft operate at slow speeds, relatively close to the ground 

in a secure environment and as a result are far safer than conventional aircraft operations. Thank you 

for your consideration. 

Sincerely, 

Jej:f Jennings 

~noir Community College 

jljennings79@lenoircc.edu 

Ph: 252-522-.1735 
*New Curriculum Beginning August 2016 

AVIATION MANAGEMENT AND CAREER PILOT 

TECHNOLOGY A60180 

The Aviation Management and Career Pilot Technology curriculum prepares individuals for a 

variety of aviation and aviation-related careers including the commercial airlines, general 

aviation, the aerospace industry, the military, unmanned aircraft systems industries, and state and 

federal aviation organizations. 

Course work includes fundamentals of flight, aerodynamics, aircraft performance, meteorology, 

navigation, federal regulations, aviation management, unmanned aircraft systems, and instrument 

and commercial ground training, flight and simulator training, and entrepreneurship or business 

management training. 

Graduates may earn a commercial pilot certificate with an instrument rating, specialize in 

aviation management or in unmanned air systems, and may find employment as commercial, 

corporate, and military pilots, fixed base operators and airport managers, as pilots or technicians 

in the unmanned air systems industry, or as flight instructors, and flight dispatchers. 

Title 

Pilot (Manned) 

Associate in Applied Science A60180 

(Revised 2016*03) Course and Hour Requirements 

Hours 

Class Lab 

Work 

Exp. Credits 

I. General Education Courses: 15 Hours 

A. English: 6 Hours 

ENG 111 Writing and Inquiry 

ENG 112 Writing/Research in the Disc 

B. Social/Behavioral Sciences: 3 Hours 

3 

3 

0 

0 

0 

0 

3 

3 

Selected from the list of social/behavioral sciences electives for the Associate in 

Applied Science degree appearing in the current catalog. 

C. Humanities/Fine Arts: 3 Hours 

Selected from the list of humanities/fine arts electives for the Associate in Applied 

Science degree appearing in the current catalog. 

D. Math/Natural Sciences: 3 Hours 

MAT 121 Algebra/Trigonometry I 2 2 0 3 

or MAT 171 Precalculus Algebra 3 2 0 4 

II. Major Courses: 50 Hours 

A. Core: 23 Hours 

1. Technical Core: 11 Hours 

AER 110 Air Navigation 2 2 0 3 

AER 111 Aviation Meteorology 3 0 0 3 

AER 112 Aviation Laws and F ARs 2 0 0 2 

AER 150 Private Pilot Flt Theory 2 2 0 3 

2. Required Subject Areas: 12 Hours 

AER 151 Flight-Private Pilot 0 3 0 1 

AER 160 Instrument Flight Theory 2 2 0 3 

AER 161 Flight-Instrument Pilot 0 6 0 2 

AER 170 Commercial Flight Theory 3 0 0 3 

AER 171 Flight-Commercial Pilot 0 6 0 3 

1 
"• 

Pilot (Manned) 

Associate in Applied Science A60180 (Continued) 

Hours Work 

Title Class Lab Exp. Credits 

B. Other Major Courses: 27 Hours 

1. Required Courses: 23 Hours 

AER 113 History of Aviation 2 0 0 2 

AER 114 Aviation Management 3 0 0 3 

AER 211 Air Traffic Control 2 0 0 2 

AER 213 Avionics 2 0 0 2 

AER 215 Flight Safety 3 0 0 3 

AER 216 Engines & Systems 2 2 0 3 

AER 217 Air Transportation 3 0 0 3 

AER 218 Human Factors in Aviation 2 0 0 2 

CIS 11 0 Introduction to Computers 2 2 0 3 

2. Select 4 Hours from the following: 

AER 115 Flight Simulator 0 2 0 1 

BUS 152 Human Relations 3 0 0 3 

BUS 153 Human Resource Management 3 0 0 3 

CTS 130 Spreadsheet 2 2 0 3 

DBA 110 Database Concepts 2 3 0 3 

PHY 131 Physics-Mechanics 3 2 0 4 

UAS 110 Intro to UAS Operations 3 0 0 3 

UAS 111 Unmanned Aircraft Systems 3 0 0 3 

WBL 111-112 Work-Based Learning I 0 0 10-20 1-2 

III. Other Required Courses: 1 Hour 

ACA 111 College Student Success 1 0 0 1 

Total Credits 66 

2 
Title 

AVIATION MANAGEMENT & CAREER PILOT TECHNOLOGY 

Aviation Management 

Associate in Applied Science A60180M 

(Revised 2016*03) Course and Hour Requirements 

Hours 

Class Lab 

Work 

Exp. Credits 

I. General Education Courses: 15 Hours 

A. English: 6 Hours 

ENG 111 Writing and Inquiry 3 0 0 3 

ENG 112 Writing/Research in the Disc 3 0 0 3 

B. Social/Behavioral Sciences: 3 Hours 

Selected from the list of social/behavioral sciences electives for the Associate in 

Applied Science degree appearing in the current catalog. 

C. Humanities/Fine Arts: 3 Hours 

Selected from the list of humanities/fine arts electives for the Associate in Applied 

Science degree appearing in the current catalog. 

D. Math/Natural Sciences: 3 Hours 

MAT 121 Algebra/Trigonometry I 2 2 0 3 

or MAT 171 Precalculus Algebra 3 2 0 4 

·n. Major Courses: 53 Hours 

A. Core: 23 Hours 

1. Technical Core: 11 Hours 

AER 110 Air Navigation 2 2 0 3 

AER Ill Aviation Meteorology 3 0 0 3 

AER 112 Aviation Laws and F ARs 2 0 0 2 

AER 150 Private Pilot Fit Theory 2 2 0 3 

2. Required Subject Areas: 12 Hours 

AER 114 Aviation Management 3 0 0 3 

BUS 115 Business Law I 3 0 0 3 

BUS 137 Principles of Management 3 0 0 3 

BUS 152 Human Relations 3 0 0 3 

or BUS 153 Human Resource Management 3 0 0 3 

B. Other Major Courses: 30 Hours 

1. Required Courses: 26 Hours 

AER 113 History of Aviation 

AER 160 Instrument Flight Theory 

AER 170 Commercial Flight Theory 

AER 211 Air Traffic Control 

AER 213 Avionics 

AER 215 Flight Safety 

AER 216 Engines & Systems 

AER 217 Air Transportation 

AER 218 Human Factors in Aviation 

CIS 11 0 Introduction to Computers 

2. Select 4 Hours from the following: 

AER 115 Flight Simulator 

BUS 230 Small Business Management 

CTS 130 Spreadsheet 

3 

2 

2 

3 

2 

2 

3 

2 

3 

2 

2 

0 

3 

2 

0 0 2 

2 0 3 

0 0 3 

0 0 2 

0 0 2 

0 0 3 

2 0 3 

0 0 3 

0 0 2 

2 0 3 

2 0 1 

0 0 3 

2 0 3 
--

DBA 110 Database Concepts 2 3 0 3 

PHY 131 Physics-Mechanics 3 2 0 4 

UAS 110 Intro to UAS Operations 3 0 0 3 

UAS Ill Unmanned Aircraft Systems 3 0 0 3 

WBL 111-112 Work-Based Learning I 0 0 10-20 1-2 

III. Other Required Courses: 1 Hour 

ACA Ill College Student Success 1 0 0 1 

Total Credits 69 

4 
Title 

AVIATION MANAGEMENT & CAREER PILOT TECHNOLOGY 

Pilot (Unmanned Aircraft Systems) 

Associate in Applied Science A60180U 

(Revised 2016*03) Course and Hour Requirements 

Hours 

Class Lab 

Work 

Exp. Credits 

I. General Education Courses: 15 Hours 

A. English: 6 Hours 

ENG 111 Writing and Inquiry 3 0 0 3 

ENG 112 Writing/Research in the Disc 3 0 0 3 

B. Social/Behavioral Sciences: 3 Hours 

Selected from the list of social/behavioral sciences electives for the Associate in 

Applied Science degree appearing in the current catalog. 

C. Humanities/Fine Arts: 3 Hours 

Selected from the list of humanities/fine arts electives for the Associate in Applied 

Science degree appearing in the current catalog. 

D. Math/Natural Sciences: 3 Hours 

MAT 121 Algebra/Trigonometry I 2 2 0 3 

or MAT 171 Precalculus Algebra 3 2 0 4 

II. Major Courses: 51 Hours 

A. Core: 23 Hours 

1. Technical Core: 11 Hours 

AER 110 Air Navigation 2 2 0 3 

AER 111 Aviation Meteorology 3 0 0 3 

AER 112 Aviation Laws and F ARs 2 0 0 2 

AER 150 Private Pilot Flt Theory 2 2 0 3 

2. Required Subject Areas: 12 Hours 

UAS 110 Intro to UAS Operations 3 0 0 3 

UAS 150 UAS Flight Simulation 2 3 0 3 

UAS 152 Remote UAS Sensing & Control 2 2 0 3 

UAS 230 UAS Aerial Photo Surveys 2 2 0 3 

B. Other Major Courses: 28 Hours 

1. Required Courses: 24 Hours 

AER 113 History of Aviation 2 0 0 2 

AER 160 Instrument Flight Theory 2 2 0 3 

AER 170 Commercial Flight Theory 3 0 0 3 

AER 211 Air Traffic Control 2 0 0 2 

AER 217 Air Transportation 3 0 0 3 

AER 218 Human Factors in Aviation 2 0 0 2 

CIS 11 0 Introduction to Computers 2 2 0 3 

UAS 111 Unmanned Aircraft Systems 3 0 0 3 

UAS 112 UAS Communications/Telemetry 3 0 0 3 

2. Select 4 Hours from the following: 

AER 115 Flight Simulator 0 2 0 1 

AER 213 Avionics 2 0 0 2 

AER 215 Flight Safety 3 0 0 3 

5 
, . 

Pilot (Unmanned Aircraft Systems) 

Title 

Associate in Applied Science A60180U (Continued) 

Hours 

Class Lab 

BUS 153 Human Resource Management 

CTS 130 Spreadsheet 

DBA 110 Database Concepts 

PHY 131 Physics-Mechanics 

WBL 111-112 Work-Based Learning I 

III. Other Required Courses: 1 Hour 

ACA 111 College Student Success 

Total Credits 

6 

3 0 

2 2 

2 3 

3 2 

0 0 

1 0 

Work 

Exp. 

0 

0 

0 

0 

10-20 

0 

Credits 

3 

3 

3 

4 

1-2 

1 

67 
P.O. Box 26959 

Las Vegas, Nevada 

89126-0959 

February 15, 2016 

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue, SE., 

Room W12-140, West Building Ground Floor 

Washington, DC 20590-001 

Via UPS 

RE: Section 333 exemption 

Dear Sir or Madam: 

Jc 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R., 

Part 11, ZUFFA, LLC, ("ZUFFA"), operator of Small Unmanned Aircraft Systems ("sUAS") 

equipped to conduct aerial videography of professional football game and training facilities, 

requests a limited exemption from the below-listed regulations to allow commercial operation of 

its sUASs, provided that the proposed sUAS operations comply with the conditions outlined 

below or as established by the Federal Aviation Administration ("FAA") under Section 333. The 

name and address of the applicant is: ZUFFA, LLC, 2960 W. Sahara, Las Vegas, NV 89102, c/o 

Tim Bellamy, Senior Vice President & Associate General Counsel, (702) 851-2478, 

tbellamy@ufc.com. 

ZUFFA makes this request under the "summary grant" process that the FAA announced in 

April 2015.1 This request is similar in all material respects to a number of recent grants of 

exemption, including Grant of Exemption No. 11488 to Advanced Aerial Cinematography, LLC 

(FAA Docket No. 2014-0090). 

Regulations from which the exemption is requested: 

14 C.F.R. part 21 

14 C.F.R. § 45.23 (b) 

14 C.F.R. §§ 61.113 (a) & (b) 

14 C.F.R. § 91.7 (a) 

14 C.F.R. § 91.9 (b) (2) & (c) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F.R. § 91.119 

14 C.F.R. § 91.121 

14C.F.R.§91.151 (a) 

14 C.F.R. §§ 91.203 (a) & (b) 

14 C.F.R. § 91.405 (a) 

14 C.F.R. 407 (a) (1) 

14 C.F.R. § 409 (a) (2) 

14 C.F.R. §§ 417 (a) & (b) 
P.O. Box 26959 

Las Vegas, Nevada 

89126-0959 

ZUFFA proposes that it receive an exemption to use sUAS to gather footage from UFC 

Events held throughout the nation. ZUFFA would use the footage in its sports and entertainment 

programming. 

The proposed sUAS operation will be conducted safely to minimize risk to the national 

airspace system ("NAS") or to persons and property on the ground. ZUFFA proposes that the 

exemption apply to civil aircraft that operate within the limitations listed below. These limitations 

were established in the FAA's grant of Advanced Aerial Cinematography's request for an 

exemption: 

1. The sUAS will weigh less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this 

exemption. 

2. Operations for the purpose of picture and television filming are permitted. 

3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per 

hour). ZUFFA may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated 

at airspeeds greater than the maximum UA operating airspeed recommended by 

the aircraft manufacturer. 

4. The UA will be operated at an altitude of no more than 400 feet above ground 

level (AGL) Altitude will be reported in feet AGL 

5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge 

(PIC) at all times. This requires the PIC to be able to use human vision unaided 

by any device other than corrective lenses, as specified on the PIC's FAA-issued 

airman medical certificate or U.S. driver's license. 

6. All operations will utilize a visual observer (VO). The UA will be operated within 

the VLOS of the PIC and VO at all times. The VO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains the VLOS capability. The 

VO and PIC will be able to communicate verbally at all times; electronic 

messaging or texting will not be permitted during flight operations. The PIC will be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC will ensure that VO can perform the duties required 

of the VO. 

7. This exemption and all documents needed to operate the sUAS and conduct its 

operations in accordance with the conditions and limitations stated in the grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents will be accessible during sUAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and will be 

followed. Otherwise, ZUFFA will follow the procedures as outlined in its operating 

documents. ZUFFA may update or revise its operating documents. It is ZUFFA's 

responsibility to track such revisions and present updated and revised documents 

to the Administrator or any law enforcement official upon request. ZUFFA will also 
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89126-0959 

present updated and revised documents if it petitions for extension or amendment 

to this grant of exemption. If ZUFFA determines that any update or revision would 

affect the basis upon which the FAA granted this exemption, then ZUFFA must 

petition for an amendment to its grant of exemption. The FAA's UAS Integration 

Office (AFS- 80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations under 

this exemption. Functional test flights may only be conducted by a PIC with a VO 

and must remain at least 500 feet from other people. The functional test flight 

must be conducted in such a manner so as to not pose an undue hazard to 

persons and property. 

9. ZUFFA is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the 

sUAS is in a condition for safe flight. The pre-flight inspection will account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the sUAS, the 

aircraft will be prohibited form operating until the necessary maintenance has 

been performed and the sUAS is found to be in a condition for safe flight. 

11. ZUFFA will follow the sUAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each sUAS operated under this exemption will comply with all manufacturer 

safety bulletins. 

13. ZUFFA will not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the sUAS in a manner consistent with how the sUAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles, and 

structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51 (b). Flights for the purposes of training the 

operator's PIGs and VOs (training, proficiency, and experience-building) and 

determining the PIC's ability to safely operate the sUAS in a manner consistent 

with how the sUAS will be operated under this exemption are permitted under the 

terms of this exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC will operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

14. UAS operations will not be conducted during night, as defined in 14 C. F. R. § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

ZUFFA will not operate flights under special visual flight rules (SVFR). 
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15. The UA will not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA AirporUFacility Director (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport's 

management is obtained or otherwise permitted by a COA issued to the 

exemption holder. The letter of agreement with the airport management will be 

made available to the Administrator or any law enforcement official upon request. 

16. The UA will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 

17. If the sUAS loses communications or loses its GPS signal, the UA will return to a 

pre-determined location within the private or controlled-access property. 

18. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

19. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the UA to 

conduct the intended operation and to operate after that for at least five minutes 

or with the reserve power recommended by the manufacturer if greater. 

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations will be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached CO A. 

21. All aircraft operated in accordance with this exemption will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will 

be as large as practicable. 

22. Documents used by ZUFFA to ensure the safe operation and flight of the sUAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available 

to the PIC at the Ground Control Station of the sUAS any time the aircraft is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request. 

23. The UA will remain clear and give way to all manned aviation operations and 

activities at all times. 

24. The sUAS will not be operated by the PIC from any moving device or vehicle. 

25. All Flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures, unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. ZUFFA 

will ensure that nonparticipating persons remain under such protection. If 

a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations will cease 

immediately in a manner ensuring the safety of nonparticipating persons; 

and 
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b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard. 

The PIC, VO, operator trainees, essential persons, or individuals who have signed consent 

forms are not considered nonparticipating persons under this exemption. 

26. All operations will be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

27. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents 

will be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. 

If this exemption permits operations for the purpose of closed-set motion picture and television 

filming and production, the following additional conditions and limitations apply: 

28. At least 3 days before aerial filming, ZUFFA will submit a written Plan of Activities 

to the local Flight Standards District Office (FSDO) with jurisdiction over the area 

of proposed filming. The 3-day notification may be waived with the concurrence of 

the FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the sUAS aerial filming 

conducted under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene 

operation of the sUAS; 

d. Make, model, and serial or N-Number of the sUAS to be used; 

e. Name and certificate number of the sUAS PICs involved in the aerial 

filming; 

f. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the filming production event; the 

list of those who gave permission will be made available to the inspector 

upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which filming will be conducted and 

the altitudes essential to accomplish the operation. 

29. Flight operations may be conducted closer than 500 feet from participating 

persons consenting to be involved and necessary for the filming production. 

Unless otherwise specified, the sUAS operations will comply with all applicable parts of 14 

CFR including, but not limited to, parts 45, 47, 61, and 91. ZUFFA incorporates all arguments in 
P.O. Box 26959 

Las Vegas, Nevada 

89126-0959 

support of the petition made in Advanced Aerial Cinematography's November 24, 2014 

application for exemption. 

Federal Register Notice 

As stated above, publication in the Federal Register is unnecessary because this application 

meets the FAA's criteria for summary approval. To the extent that the FAA determines that 

publication is necessary, the following summary is provided: 

Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 

14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 

91.119; 91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 

(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (551bs or less) in 

videography operations. 

The Exemption is in the Public Interest 

As demonstrated above, the proposed sUAS operations would minimize the risk of harm to 

individual safety or damage to the NAS and property. The operations proposed by ZUFFA 

would provide tremendous public benefits by enabling millions of UFC fans to view footage that 

could not be captured via any other technology. The sUAS operations as described in this 

application will be far safer and more efficient than use of helicopters or other aircraft to capture 

the required footage. 

The conditions outlined in this petition clearly satisfy Section 333's exemption criteria 

regarding "size, weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight," and therefore the proposed operations would not 

"create a hazard to users of the national airspace system or the public or pose a threat to 

national security." As discussed above, ZUFFA agrees to use limitations that are substantially 

identical to those contained in the FAA's recent grant of exemption for Advanced Aerial 

Cinematography. Accordingly, the proposed UAS operations of ZUFFA should not raise safety 

or national security concerns, and should receive summary approval. 

Should you have any questions or concerns, please do not hesitate to contact me 

Best regards, 

7WVJ (\1 

Timothy Bellamy 

Zuffa LLC d/b/a Ultimate Fighting Champions 

Senior Vice President and Associate General Counsel