AUSLEY MCMULLEN 

ATTORNEYS AND COUNSELORS AT LAW 

123 SOUTH CALHOUN STREET 

P.O. BOX 391 (ZIP 32302) 

TALLAHASSEE, FLORIDA 32301 

(850) 224-9115 FAX (850) 222-7560 

www.ausley.com 

November 9, 2015 

Via Electronic Submission and Certified U.S. Mail 

Docket Operations 

U.S. Department of Transportation 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Second Supplement to Application for Exemption from Specified Aviation 

Regulations Under Section 333 of the FAA Modernization and Reform Act of 

2012. 

 Applicant: Florida State University 

Attn: David F. Merrick 

Director, Center for Disaster Risk Policy 

113 Collegiate Loop 

637 Bellamy 

Tallahassee, Florida 32306-2250 

Telephone: (850) 644-9961 

Email: dmerrick@cdrp.net 

 rdoran@ausley.com 

shogan@ausley.com 

Dear Sir or Madam: 

 Please accept this letter as a second supplement to the exemption request previously 

submitted by the Center for Disaster Risk Policy at Florida State University (the “Applicant”). 

The Applicant’s exemption request is currently pending under Docket Number FAA-2015-

0621.1

 

 The Applicant requests that the section in the original exemption request entitled 

“Summary of Applicant’s Scope of Operations” be revised to state as follows: 

* * * 

 

1

 The first supplement requested that the FAA grant a “Blanket COA” to the Applicant. The 

FAA’s announcement of the Blanket COA policy on March 24, 2015, occurred after the 

Applicant’s exemption request was initially filed. 
2 

Summary of Applicant’s Scope of Operations 

 The Applicant proposes to conduct applied research in the use and operation of sUAS 

platforms and sensors in the field of disaster management. The Applicant has developed a “UAS 

Standard Operating Guide” (the “Guide”) that sets forth standard operating procedures for its 

UAS operations.2

 These procedures provide a baseline to ensure that all persons operating an 

sUAS in the Applicant’s program possess sufficient knowledge of both airspace and the sUAS 

technology to operate safely in the National Airspace System (“NAS”). 

 

The Applicant proposes to conduct research operations in the Operations Areas defined in 

the granted COA enclosed as Attachment 1 to the Applicant’s original exemption request, and 

the submitted COA applications enclosed with the Applicant’s original exemption request as 

Attachments 2 and 3 (the “Operations Areas”). The Applicant also proposes to conduct applied 

research using sUAS in conjunction with emergency management organizations throughout the 

state of Florida. These operations will be conducted in compliance with the default blanket COA 

or through the standard COA application process. 

 

The Pilot in Command (“PIC”) for each operation will hold, at a minimum, a private pilot 

certificate. The personnel working under the PIC in each operation will meet the standards 

specified in the Guide, as well as any other additional requirement the FAA requires under this 

application. The PIC and crew will be specifically trained to operate the sUAS platforms utilized 

in the Applicant’s operations. 

* * * 

 Thank you for your consideration of these matters. The Applicant looks forward to 

advancing the use of sUAS platforms in the National Airspace System. 

 Respectfully Submitted, 

 /s/ David F. Merrick 

David F. Merrick 

Director, Center for Disaster Risk Policy 

 Florid State University 

 

/s/ Richard E. Doran, Steven M. Hogan 

Richard E. Doran and Steven M. Hogan 

Ausley McMullen 

Attorneys for the Center for Disaster Risk 

Policy, Florida State University. 

 

2

 A copy of the Guide was submitted as Attachment 4 to the Applicant’s original exemption 

request.