## Lenoir CommunityCollege JeffreyJennings Program Chair Aviation 2772 Rouse Road Extension Kinston, North Carolina 27863

jliennings79@lenoircc.edu 252-522-1735

February 10, 2016

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 "I '

Re: Exemption Request Section 333 ofthe FAA Reform Act (Reform Act) and Title 14 Part 11 Code of Federal Regulations (CFR): 14CFR 45.23(b), 14CFR Part 

### 21, 14CFR 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 MayConcern:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and Title 14 CFR Part 11, ( Lenoir Community College (LCC) is a developerand operator ofSmall Unmanned Aircraft Systems ("sUASs") is requesting CFR exemption approval to conduct;

• Education
• CrewTraining
• Remote SensorTraining
• Aerial photographyapplications foropen set filming and photography
LCC is applying foran exemption from the detailed CFR's listed in this letterto allow commercial operation of UASs so long as such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333.1
The requested exemption would permitthe operation of sUAS undercontrolled conditions in airspace that is 1) limited 2) predetermined 3) access controlled and 4) would provide a minimum equivalent level ofsafetyto conventional operations. LCC can provide an infrastructure thatwould therebyfulfill the Secretary ofTransportation's responsibilities to "

...establish requirements forthe safe operation of such aircraft systems in the national airspace 

## system," as stated in Section 333(c) ofthe Reform Act.

### Lenoir Community College Aviation History
LCC Aviation was founded in 1970by aviation professionals in Lenoir County North Carolina. The current program chair Mr.JeffreyJennings is an ATP Pilot, Flight Instructor, Ground Instructor, A&P, lA Mechanic. He has over 25 years ofaviation experience including all areas ofoperations under both Part 61 and 141. Regulations from,which the exemption is requested:
14CFR Part 21
14 C.F.R. 45.23(b)
14CFR 61.113 (a) & (b)
14C.F.R. 91.7 (a)
14CFR 91.9 (b) (2)
14C.F.R. 91.109
14C.F. R. 91.119
14C.F.R. 91.121
14CFR 91.151 (a)
14CFR 91.203 (a) & (b)
14CFR 91.405 (a)
14CFR 407 (a) (1)
14CFR 409 (a) (2)
14CFR 417 (a) & (b)
This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directsthe Secretary ofTransportation to considerwhether certain unmanned aircraftsystems mayoperate safely in the national airspace system (NAS) before completion ofthe rulemaking required underSection 332 ofthe Reform Act. In makingthis determination,the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose athreatto national security in light ofthefollowing:

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

• Operation ofthe UAS in close proximityto airports and populated areas

• Operation ofthe UAS within visual line ofsight ofthe operator

### AIRCRAFT
LCC sUASs are battery powered fixed wing and rotorcraft aircraft weighting less than 55 lbs. (including payload) made oflightweight plastic, foam, composite and limited lightweight metals that meetthe definition ofsUAS. They operate, under normal conditions ata speed of no morethan 50 knots and have the capability to hover, and move in thevertical and horizontal plane simultaneously. They will operate within Line OfSight (LOS) and within a safely controlled environment. Such aircraft and operations will ensure thatsUAS will"notcreate a hazard to users ofthe national airspace system, national security or tothe public."


### EQUIVALENT LEVEL OF SAFETY
The applicant proposes thatthe exemption requested herein applyto civil aircraftthat have the characteristics and thatoperate with the limitations listed herein. These limitations provide forat least
an equivalent oreven higher level ofsafety to operations underthe current regulatory structure.
These limitationsand conditions to which LCC agrees to be bound when conducting commercial operations underan FAA issued exemption include:
1. The sUAS will weigh less than SSibs.
2. Flights will be operated within line ofsight ofa pilot and/orobserver.
3. Flights will be terminated at 25% battery power reserve.
4. Flights will be operated at an altitude400feet AGL and below.
5. Minimum crewfor each operation will consist ofthe sUAS Pilot and theVisual Observer.
6. sUAS will operated by LCC Student'sforeducational purposes.
7. sUAS Pilot will be Pilot in Command (PIC).
8. The UAS will only operate within a controlled area with a secure perimeterforthe flight operations area.
9. A briefing will be conducted in regard to the planned sUAS operations priorto each day's flight activities. Itwill be mandatorythat all personnel who will be performing dutieswithin the boundaries of the safety perimeter be present forthis briefing.
10.The operatorwill obtain the consent ofall persons involved in the operations area.
11. Pilotand observerwill receive LCC training in the mission and operation ofthe specific UAS.
12. Observer and pilotwill atall times be able to communicate byvoice and/ortext.
16. Obtain required permissions and permits priorto operation.17. Ifthe sUAS loses communications the UAS will have capabilityto; return to a pre-determined "home" location or manually flown to a landing.
18.The sUAS will have the capability to abort aflight in case of unpredicted obstacles oremergencies.


### 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 requirementsforthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart 

### Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorizethe FAA to exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstratesthatthe UAS operated withoutan airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed.


### 14C.F.R. §45.23 {b). Marking ofthe Aircraft
The regulation requires:
When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft orexperimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilotstation, 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; howevergiven the size ofthe sUAV, two-inch letteringwill 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 ofsafety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and othersworking 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 pilotor passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiringthe Pilot In Command (PIC) operatingthe aircraftto have a private pilotcertificate ratherthan a commercial pilot certificate to operate this small UAS. Unlike a conventional aircraftthat carries the pilot and passengers, the sUAS is remotely controlled with no livingthing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. Private Pilot certification as the PIC exceeds the present level ofsafety achieved by 14 C.F.R. §61.113 (a) 

### & (b).


### 14C.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 forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftthe use of maintenance procedures and use ofsafety check lists priorto each flight an equivalent level ofsafety 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) Forwhich an Aircraft Flight Manual (AFM) is not required by §21.5 ofthis chapter, unless there is available in the aircraft acurrent approved manual, material, markings, and placards, orany combination thereof.
The sUAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft. Since there is no piloton-board it is more appropriate to have the current approved (AFM) in the carrying case ofthe respective sUAS.
The equivalent level ofsafety will be maintained by keeping the AFM in the carrying case where the pilot flyingthe sUAS will have immediate access to it.


### 14 C.F.R. §91.109: Flight instruction:
Section 91.109 providesthat no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unlessthataircraft has fully functioning dual controls.
sUASs and remotely piloted aircraft, by theirdesign do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions forflight training withoutfully functional dual controlsfora numberofaircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety provided bythe fact that neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. Control underthe provision offlight trainingthe instructorcan assume control ofthe hand controller and associated "abort switch" and/orthrough a dual controllersystem.

### 14C.F.R. §91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudesforoperation ofcivil aircraft. As this exemption is for asUAS DPS request exemption to operate ataltitudes up to 400 AGL, or not more than 200 above an elevated platformfrom which filming is planned, an exemption may be needed to allowsuch operations. Flight operationswill be conducted in a secure perimeterto ensure safety.
The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flightwill be taken withoutthe permission ofthe propertyownerorvia required permits. Because ofthe advance notice to the propertyowner and participants affected individuals will be aware ofthe planned flight operations. Compared to flight operationswith aircraft weightingfar more than the maximum 55lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft missionsthat exist below500 Above Ground Level (AGL). In addition, the low-altitude operations ofthe sUAS will ensure separation between these smaii-UAS operations and the majority ofoperations of conventional aircraftthat must complywith Section 91.119.


### 14 C.F.R. §91.121 Altimeter Settings
This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport oran appropriate altimetersetting 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 ofsafety will be achieved by the operator, pursuantto the operating procedures, confirmingthe altitude ofthe field elevation as read via the GPS to determinethe maximum flight altitude of400' 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 underVFR conditions unless (considering wind and forecast weatherconditions) there is enough fuel to flyto thefirst point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthatforat least 30 minutes; or (2) At night, tofly afterthatfor at least 45 minutes." Since these requirementswere designed for primarilyfossil fuel powered manned aircraftthat are operating outside ofthe 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 mostflights are shorterthan 30 minuteswith current batterytechnology.
An equivalent level ofsafety can be achieved by terminating flights when 25% ofbattery power is reached. This parameterwould be more than adequate to return the sUAS to a safe landing area within its limited operating area.


### 14C.F.R. §91.203 {a) and {b): Carrying Civil Aircraft Certification and RegistrationThe regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section ora special flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew. Since sUAS weigh less than 55 lbs. and is operated without an onboard pilotthere is no ability or place to carry certification and registration documents orto display them on the sUAS.
An equivalent level ofsafety will be achieved by keeping these documents atthe carrying case where the sUAS pilotwill have immediate access to documents specificto the sUAS.

14C.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 orowner "shall have thataircraft inspected as prescribed in subpart Eofthis partand shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43.
Given thatthese section and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will notapplyto the applicant. Maintenance will be accomplished pursuantto the company proceduresforairworthiness (software and hardware) with related maintenance record keeping in additionto the pre-flight duties ofthe sUAS pilot. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry asmall payload and operate only in restricted
areas for limited periods oftime. 

### *********
Pursuantto 14C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determinedthat publication is needed: DronePilotSafety seeks an exemption from thefollowing rules:
"14 CFR §21, subpartH; 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} and91.417(a) 

### & (b) to operate commerciallya small unmanned vehicle (weighing less than 551bs)forresearch anddevelopment, crew training, marketsurvey, aerialphotographyapplications forclosedsetfilming andphotography."Approval ofexemptions allowing commercial operations ofsUASs can enhance safety overconventional 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 agreat portion ofthat risk especially when combined with reduced mass and lack ofcombustible fuel. Since sUAS will carry no passengers orcrew and, therefore, will not expose them to the risks associated with manned aircraft flights.
The operation ofsmall UASs, weighting less than 55 lbs., conducted in the secure conditions outlined in this documentwill provide an equivalent level ofsafetyto support the granting ofexemptionsfor commercial operations. These lightweight aircraft operate atslow speeds, relatively close to the ground in a secure environmentand as a result are far saferthan conventional aircraft operations.Thankyou foryourconsideration.

Sincerely,

Jej:f Jennings

## ~noir Community College jljennings79@lenoircc.edu 

### Ph: 252-522-.1735

### *New CurriculumBeginningAugust2016


### AVIATIONMANAGEMENTAND CAREERPILOT TECHNOLOGYA60180 TheAviationManagement and CareerPilotTechnology curriculumprepares individuals for a variety ofaviation andaviation-relatedcareers includingthe commercial airlines, general aviation, the aerospace industry, the military, unmanned aircraft systems industries, and state and federal aviation organizations. Course workincludes fundamentals offlight, aerodynamics, aircraftperformance, meteorology, navigation, federal regulations, aviationmanagement, unmanned aircraft systems, andinstrument and commercial groundtraining, flight and simulatortraining, and entrepreneurship orbusiness managementtraining. Graduates mayearn a commercialpilot certificate with an instrumentrating, specialize in aviationmanagement orinunmanned air systems, and may find employmentas commercial, corporate, andmilitarypilots, fixed base operators and airportmanagers, as pilots ortechnicians inthe unmanned air systems industry, oras flight instructors, and flight dispatchers.

Title 

### Pilot (Manned) Associate in Applied ScienceA60180 (Revised 2016*03) Course andHourRequirements Hours Class Lab Work Exp. Credits 

### I. GeneralEducationCourses: 15 Hours A. English: 6 Hours ENG 111 Writing andInquiry ENG 112 Writing/Researchin the Disc 

### B. Social/Behavioral Sciences: 3 Hours 3 3 

### 0 0 0 0 3 3
Selected from the listof social/behavioralsciences electives for theAssociate in AppliedScience degree appearing in the currentcatalog. C. Humanities/Fine Arts: 3 Hours Selected from the listof humanities/fine arts electives for theAssociate inApplied Science degree appearing in the currentcatalog. D. Math/Natural Sciences: 3 Hours MAT 121 Algebra/Trigonometry I 2 2 0 3 or MAT 171 PrecalculusAlgebra 3 2 0 4 

### II.MajorCourses: 50 Hours A. Core: 23 Hours 

### 1. Technical Core: 11 Hours AER 110AirNavigation 2 2 0 3 AER 111 AviationMeteorology 3 0 0 3 AER 112 AviationLaws and FARs 2 0 0 2 AER 150PrivatePilotFltTheory 2 2 0 3 2. Required SubjectAreas: 12 Hours AER 151 Flight-PrivatePilot 0 3 0 1 AER 160 InstrumentFlightTheory 2 2 0 3 AER 161 Flight-InstrumentPilot 0 6 0 2 AER 170 CommercialFlightTheory 3 0 0 3 AER 171 Flight-CommercialPilot 0 6 0 3 1"•



### Pilot (Manned) Associate in Applied ScienceA60180 (Continued) Hours Work Title Class Lab Exp. Credits 

### B. OtherMajorCourses: 27 Hours 1. Required Courses: 23 Hours AER 113 History ofAviation 2 0 0 2 AER 114 AviationManagement 3 0 0 3 AER211 AirTraffic Control 2 0 0 2 AER213 Avionics 2 0 0 2 AER215 Flight Safety 3 0 0 3 AER216Engines 

### & Systems 2 2 0 

## 3 AER217AirTransportation 3 0 0 3 AER218 HumanFactors inAviation 2 0 0 2 CIS 110 Introductionto Computers 2 2 0 3 2. Select4 Hours from the following: AER 115 Flight Simulator 0 2 0 1 BUS 152 HumanRelations 3 0 0 3 BUS 153 HumanResource 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 Introto UAS Operations 3 0 0 

## 3 UAS 111 UnmannedAircraft Systems 3 0 0 3 WBL 111-112 Work-BasedLearning I 0 0 10-20 1-2 III. OtherRequired Courses: 1 Hour ACA 111 College Student Success 1 0 0 1 Total Credits 66

2

### Title AVIATIONMANAGEMENT & 

### CAREERPILOTTECHNOLOGY Aviation Management Associate inApplied ScienceA60180M (Revised 2016*03) Course andHourRequirements Hours Class Lab Work Exp. Credits I. GeneralEducationCourses: 15 Hours A. 

### English: 6Hours ENG 111 Writing and Inquiry 3 0 0 3 ENG 112 Writing/Research inthe Disc 3 0 0 3 B. Social/Behavioral Sciences: 3Hours Selected from the listof social/behavioralsciences electives for theAssociate in AppliedScience degree appearing in the currentcatalog. 

### C. Humanities/Fine Arts: 3Hours Selected from the listof humanities/fine arts electives for theAssociate inApplied Science degree appearing in the currentcatalog. 

### D. Math/Natural Sciences: 3Hours MAT 121 Algebra/Trigonometry I 2 2 0 3 or MAT 171 Precalculus Algebra 3 2 0 4 

# ·n. MajorCourses: 53 Hours A. 

### Core: 23 Hours 1. Technical Core: 11 Hours AER 110 AirNavigation 2 2 0 3 AER Ill AviationMeteorology 3 0 0 3 AER 112 Aviation Laws and FARs 2 0 0 2 AER 150 Private PilotFit Theory 2 2 0 3 2. Required SubjectAreas: 12 Hours AER 114 AviationManagement 3 0 0 3 BUS 115 Business Law I 3 0 0 3 BUS 137 Principles ofManagement 3 0 0 3 BUS 152 HumanRelations 3 0 0 3 or BUS 153 HumanResource Management 3 0 0 3 B. 

### OtherMajorCourses: 30 Hours 1. Required Courses: 26 Hours AER 113 History ofAviation AER 160 InstrumentFlightTheory AER 170 Commercial FlightTheory AER 211 AirTraffic Control AER 213 Avionics AER215 Flight Safety AER 216 Engines & 

### Systems AER 217 AirTransportation AER 218 HumanFactors inAviation CIS 110Introductionto Computers 2. Select4 Hours from the following: AER 115 Flight Simulator BUS 230 Small BusinessManagement 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 110Database Concepts 2 3 0 3 PHY 131 Physics-Mechanics 3 2 0 4 UAS 110 Introto UAS Operations 3 0 0 3 UAS Ill UnmannedAircraft Systems 3 0 0 3 WBL 111-112 Work-Based Learning I 0 0 10-20 1-2 

## III. OtherRequired Courses: 1Hour ACA Ill College Student Success 1 0 0 1 

## TotalCredits 

## 69

4

### Title AVIATIONMANAGEMENT & CAREERPILOTTECHNOLOGY Pilot(UnmannedAircraft Systems) Associate in Applied ScienceA60180U (Revised 2016*03) Course andHourRequirements Hours Class Lab Work Exp. Credits I. GeneralEducationCourses: 15Hours A. 

### English: 6 Hours ENG 111 Writing and Inquiry 3 0 0 3 ENG 112 Writing/Research inthe Disc 3 0 0 3 B. 

### Social/Behavioral Sciences: 3 Hours Selected from the listof social/behavioralsciences electives for theAssociate in AppliedScience degree appearing in the currentcatalog. 

### C. Humanities/FineArts: 3 Hours Selected from the list of humanities/fine arts electives for theAssociate inApplied Science degree appearing in the currentcatalog. 

### D. Math/Natural Sciences: 3Hours MAT 121 Algebra/Trigonometry I 2 2 0 3 or MAT 171 PrecalculusAlgebra 3 2 0 4 II.MajorCourses: 51 Hours A. 

### Core: 23 Hours 1. Technical Core: 11 Hours AER 110 AirNavigation 2 2 0 3 AER 111 AviationMeteorology 3 0 0 3 AER 112 Aviation Laws and FARs 2 0 0 2 AER 150 Private PilotFlt Theory 2 2 0 3 2. Required SubjectAreas: 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. OtherMajorCourses: 28 Hours 1. Required Courses: 24 Hours AER 113 History ofAviation 2 0 0 2 AER 160 InstrumentFlightTheory 2 2 0 3 AER 170 CommercialFlightTheory 3 0 0 3 AER211 AirTraffic Control 2 0 0 2 AER217 AirTransportation 3 0 0 3 AER 218 HumanFactors inAviation 2 0 0 2 CIS 110Introductionto Computers 2 2 0 3 UAS 111 UnmannedAircraft Systems 3 0 0 3 UAS 112 UAS Communications/Telemetry 3 0 0 3 2. Select4 Hours from the following: AER 115 Flight Simulator 0 2 0 1 AER213 Avionics 2 0 0 2 AER215 Flight Safety 3 0 0 3

5, 

# . Pilot (Unmanned AircraftSystems)

Title 

### Associate in Applied ScienceA60180U (Continued) Hours Class Lab BUS 153 HumanResource Management CTS 130 Spreadsheet DBA 110 Database Concepts PHY 131 Physics-Mechanics WBL 111-112Work-BasedLearning I 

### III. OtherRequired Courses: 1Hour ACA 111 College Student Success 

### TotalCredits

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 

## 67P.O. Box 26959

Las Vegas, Nevada 89126-0959 February 15, 2016

Docket Operations, M-30 U.S. Department ofTransportation (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 ofthe 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 ofthe 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. ZUFFAwould 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 ofpicture 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 ortexting 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 ofthe flight. The PIC will ensure that VO can perform the duties required ofthe 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. ZUFFAwill alsoP.O. Box26959 Las Vegas, Nevada 89126-0959 present updated and revised documents if it petitions for extension or amendment to this grant of exemption. IfZUFFA 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. Ifthe 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 underspecial visual flight rules (SVFR).P.O. Box26959 Las Vegas, Nevada 89126-0959 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. Ifthe 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 abortthe 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 ofthe attached COA. 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 orvehicle. 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; andP.O. Box 26959 Las Vegas, Nevada 89126-0959 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 underthis 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 awritten Plan ofActivities 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 ofactivities 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 underthis grant ofexemption;
c. Name and phone number of the person responsible for the on-scene operation ofthe sUAS; d. Make, model, and serial or N-Number ofthe 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 ofthose who gave permission will be made available to the inspector upon request; g. Signature ofexemption holder or representative; and h. A description ofthe 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 inP.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, 

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Timothy Bellamy Zuffa LLC d/b/a Ultimate Fighting Champions Senior Vice President and Associate General Counsel