April 10, 2015

Page 1 of 7 Petition for Exemption concerning opera tion of Physical Sciences Inc. Unmanned Aircraft System in accordance with Section 333 of the FAA Modernization and Reform Act of 2012

Registered Owner Name: Physical Sciences Inc

Registered Owner Address: 20 New England Business Center Andover, MA 01810

- 1077 (978) 689

- 0003

Aircraft Description:

Vertical Take O ff and Landing (VTOL)

s UAS

Aircraft Serial Number : 0030200300648

0030200300649

0030200300652

0030200300653

0030200300654

0030200300655

0030200300656

0030200300657

0030200300658

0030200300659

0030200300660

0030200300661

0030200300662

0030200300663

0030200300664

0030200300665

0030200300666

0030200300667

0030200300668

0030200300669 Aircraft Builder: Physical Sciences Inc.

Year Manufactured:

2015

Aircraft Model Designation: InstantEye Mk

- 2

Engine Model:

Mk

- 2 Brushless Motor

1734

- 311

- 01

Propeller Model:

1812

- 331

- 21 8x3.8 Propeller (2)

1812

- 331

- 22 8x3.8P Propeller (2)

1. **Overview**

. The Instant Eye weighs 1.1 lbs. and will mainly be used to conduct crew training, product development, market research, aerial s urveys, mapping and inspections. The InstantEye is a high

- performance, low

- cost aerial system that can be hand

- launched, flown and hand

recovered by a single person. At approximately one pound, the vehicle can go from a stowed configuration to airborne in under 30 seconds and provide rapid si tuational awareness and tactical sensor operation for up to 30 minutes. InstantEye uses 100% custom control algorithms derived from Physical Sciences Inc. (PSI) biomimetic research of hawk moths in turbulent winds and collisions. InstantEye offers excepti onal stability, position hold, and responsiveness unlike any other UAV in its class. ‘Manual’ mode gives the user total control and speeds up to 60 mph, while ‘Alt’ and ‘GPS’ provide vertical and horizontal position hold and speeds up to 30 mph and vertica l climb rates greater than 2000 ft/min.April 10, 2015

Page 2 of 7 2. Aircraft Configuration. InstantEye’s performance characteristics: Figure 1 shows a complete description of the aircraft.

a. Three

- view drawings or three

- view dimensioned:

Figure 1

- InstantEye Mk

- 2 Components

b. Wing span. 25.0 cm ( 9.84 inches) (frame); 43.0 cm ( 16.92 inches) (frame + props)

c. Length. 25.0 cm ( 9.84 inches) (frame); 43.0 cm ( 16.92 inches) (frame + props)

d. Maximum gross takeoff weight. 730 g ( 1 .6 lb)

e. Fuel capacity. N/A f. Payload capa city. 200 g ( 0.44 ounces)

g. Maximum altitude. 12,000 ft MSL

h. Endurance. 3 0 min of battery life

i. Maximum airspeed. 60 mph
j. Description of ground support equipment. InstantEye Mk

- 2 uses 4 000 mAh Li

- poly batteries and supplied charger.

k. Description of launch and recovery equipment. N/A

3. Ground Control Station System (GCS) Configuration. Description and a diagram (Figure 2), of the GCS.

Ground Control Station (GCS) Control Interface The GCS control interface can be broken into three main groups, 2 joysticks, 8 primary control buttons, and 4 menu buttons, see Figure 2.

1. Joysticks The joysticks are used to reposition the aircraft once it is airborne. Pushing the right joystick up

and do wn causes the aircraft to climb and descend. Pushing it left and right rotates its heading (yaw). Pushing the left joystick up and down moves the aircraft forward and back. Pushing it left and right moves the aircraft left and right.April 10, 2015

Page 3 of 7 2. Primary Control Button s

ALT, NAV, CAM, MOTOR, HOME, UTIL1, and UTIL2 / IR

3. Menu Buttons The menu buttons are just below the screen and are configurable based on context. The context menu can be brought up by pressing the menu button on the left. The other three buttons then

per form the function described just above them on the screen. Pressing the left menu button a second time will bring up a second context menu again defining the function of the other three

buttons.

Figure 2: GCS Button and Joystick Configuration

4. Exemptions requested per 14 C.F.R :

a. § 91.7(a) Civil Aircraft Airworthiness: No person shall operate a civil aircraft unless it is in an airworthy condition. On June 25, 2014, the FAA granted S an
D iego G as &E lectric a Special Airworthiness Certificate in the Experimental category for the InstantEye Mk

- 2. During this process the aircraft was proven to be in an airworthy condition and safe for the public. In addition, the InstantEye has been proven airworthy and received Certification with US Army Special O perations
Command. ( Air Worthiness Releas e

, AWR# IEMK220130521 ; Full AWR has been

submitted in the past and can be submitted with this request.)

b. § 91.109 (a) Flight Instruction: No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The InstantEye does not have dual controls ; instead the InstantEye has a fully functioning Ground Control Station (GCS) . ( See figure 2. ) When flight s are performed

, no pilots will be on the aircraft and the GCS will be a safe distance from the InstantEye and the public, causing no safety hazard.

c. § 91.113 See and Avoid : Method for See

- and

- Avoid (§ 91.113). When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maint ai ned by each person operating an a ircraft so as to see and avoid other aircraft. The sUAS is strictly line of sight and will always be in constant contact with the operator and

visual observer. See and Avoid will be conducted by the operator and vigilance shallApril 10, 2015

Page 4 of 7 be maintained by each operat or so as to “see and avoid” any other aircraft.

All visual observer s will be qualified and understand the rules and responsibilities described in § 91.111 (Operating near other aircraft), § 91.113 (Right

- of

- way rules: Except water operations), and § 91.155 (Basic VFR weather minimums). There will be no adverse impact to the pu blic because each visual observer will be fully qualified.

d. § 91.119 Minimum Safe Altitudes

, n o person may operate an aircraft below the following altitudes: Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. PSI will never operate higher than 400ft AGL and will avo id congested or populated areas and will pose no risk to the public.

e. § 91.121 Altimeter settings: Each person operating an aircraft shall maintain the cruising altitude or fight level of that aircraft, as the case may be, by reference to an altimeter that is set to the appropriate station. The InstantEye s UAS uses barometri c altitude pressure but does not program in an altimeter setting. The altitude is monitored by the Pilot In Command and constantly watched by the visual

observer.

This exemption will benefit the public because the visual observer and operator are

visual l ine of sight at all times, and will not pose any risk to the public.

f. § 91.151 (b) Fuel requirements for flight in VFR conditions: No person may begin a flight in a rotorcraft under VFR conditions unless there is enough fuel to fly to the first point on intended landing and, assuming normal cruising speed, to fly that for at least 20 minutes. The sUAS is battery operated with a max imum flying time of 30 minutes. However, this poses no sa fety risk because the take

- off point is also located at the landing point and will cause no safety hazard to the public. The PIC will ensure that there is enough power to conduct the operations and to operate after that for at least five minutes.

g. § 9 1.2 07 Emergency Locator Transmitters : No person may operate a U.S.

- registered civil airplane unless there is attached to the airplane an approved automatic type emergency locator transmitter. The sUAS does not use an ELT

, all operations are VFR and in line of sight with a visual observer.

This exemption will benefit the public because the visual observer and operator are line of sight at all times with the sUAS

. In addition if the sUAS needed to be located on the ground, the GCS will point to the sUA S to locate it and show range to the

sUAS.

5. Inspection and Maintenance. (14 C.F.R § 91.405, 91.407, 91.409). All operators will follow PSI Unmanned Aircraft Syste m InstantEye training manual and any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristic will undergo a functional test flight prior to conducting further operations. Functional test flights will be conducted by a PIC and VO and will remain at least 500 feet from other people

.

6. Description of past flight history. There are in excess of 15 00 hrs of test and evaluationApril 10, 2015

Page 5 of 7 time on the InstantEye Mk

- 2 systems and more than 36 00 hrs of test and evaluation time on the systems it is derived from. P hysical S cience I nc. has already proven Airworthiness and has an Airworthiness Certification with US Army Special Operations Command. ( AWR#

IEMK220130521

, attached. ) In addition, As of June 25, 2014, after the FAA granted S an
D iego G as &E lectric a Special Airworthiness Certificate in the Experimental category, it has flown numerous sorties in support of operations and has always operate d in a safe manner.

7. Flight Recovery and Lost Link Procedures. Ai rcraft lost link a nd emergency recovery
questi ons /procedures

.

a. How is it determined that the UA is experiencing lost link and how is this displayed to the pilot? Signal strength or quality is determined by error rate or number of lost data packets which are monitored during communications. When a threshold percent of data packets are lost the aircraft

, the aircraft goes into ” lost comms ” mode.

b. O perational procedu res in the event of a lost link : During a lost link event the operator monitors the data and video until communications are restored, then control is regained. If for some reason communications are not restored the operator should wait by the last know location of good communications. The aircraft will

return there and auto land.

c. Describe how the aircraft will react during takeoff, climb, cruise, descent, and landing in the event of a lost link. During startup each InstantEye air vehicle is “tethered” to a ground control station through its command and control communication system. After tetherin g has been achieved the air vehicle will respond to commands from that ground station only. In operation, due to radio interference or flight beyond communication range, the aircraft can lose command and control lock with the ground control station. In t his event the aircraft will enter

into its “lost comm” mode and will e xecute the following procedure:

i. Vehicle will immediately climb/descend to an altitude 300’ Above Ground Level (AGL) above its launch altitude;

ii. Vehicle will home toward last known locatio n of ground control station (GPS position of ground control station is uploaded to air vehicle during flight);

iii. If command and control communication is reestablished, vehicle will stop and hover at current location. If command and control communication is not reestablished, vehicle will hover over last known location of ground co ntrol station (“home position”) and land immediately.

iv. If vehicle is at home position and command and control communication has not been reestablished, vehicle will autonomously descend and land.

d. How is it determined that the lost link functionality of the system is operational? The lost link functionality has been extensively tested and is used operationally, please refer to Airworthiness Release: US Army AWR# IEMK220130521

.

e. How does the UA navigate when in the lost link mode? The InstantEye Mk

- 2 is continuously updated with the GCSs GPS location. When the aircraft goes into “lost comms” mode it then uses the last location of the GCS as its next waypoint.

f. What parameters are used to define the lost link or return home point? How is this point selected? How is this point entered? What happens when the UA reaches thisApril 10, 2015

Page 6 of 7 point? The InstantEye vehicle will enter its lost communication control mode if the

error rate increases abo ve 18.75 failed transmissions per successful transmission or after receiving no data from the ground station for 7.5 seconds. Logic exists to prevent the vehicle from oscillating in and out of lost communication control. When the aircraft enters it “lost c omms mode” the aircraft ascends or descends to 300 ft. AGL and then begins to navigate to the last known home position. If at any point communications are regained the operator can begin controlling again.

g. Unde r what conditions is a return home mode both manually and automatically

activated? The InstantEye Mk

- 2 either enters its return home mode in “ lost comms

mode ” after the aircraft climbs/descends to an altitude 300’ AGL above its launch altitude or when the “Home” button is pressed on the GCS.

h. What do the control station displays indicate during lost link? Is it clear that the data

is stale or invalid? Lost link is known by the operator when the on

- screen data stops updating and the “Home” mode is automatically highlighted on the GCS screen.

i. Lost link emergency procedures :

i. Weak Command and Control (C2) Link

Indicator: “Warning: Weak C2 link” is displayed on

- screen. Aircraft OSD data, such as the heading and altitude graphics, have stopped updating. Often video reception is poor or non

existent as well.

Response action: In ~7 seconds, the vehicle will enter lost communications mode. It will climb to an altitude of approximately 3 00 ft. AGL and then begin to fly back to the home location. If control communications are regained en route to the home location (indicated by the disappearance of the “Weak C2 link” warning and resumption of aircraft OSD data updates) the

operator may res ume controlling the aircraft and redirect it by using the joysticks.

ii. Loss of aircraft GPS fix

Indicator: As GPS quality degrades, the color quality bar will shrink and change color and position hold will become less and less accurate. These effects are amplified when operating in windy conditions, or with very heavy payloads. When the quality bar underneath GPS coordinate is empty (completely gray) for 4 continuous seconds, the vehicle has lost operational GPS and an

indicat or is displayed: “Warning: Vehicle lost GPS; NAV mode disabled” NAV mode is automatically exited without operator action. Aircraft ceases to automatically hold position. The last know GPS is displayed in the GPS Coordinate graphic.

Response action : Ensure that ALT mode is engaged. The aircraft will maintain altitude while the operator can focus on controlling the lateral motion of the vehic le manually. When aircraft position has stabilized, climb to a safe height (above obstructions) and fly the aircraft towards the home location. Use the range/bearing graphic and video feed to assist in this. When over an optimal landing location, slowly de crease the aircraft’s altitude while focusing on maintaining lateral position. At any point, if the GPS quality bar shows a signal quality of medium (yellow) or high (green), it is likely safe to re

- enter NAV mode.

8. Pilot Qualifications (14 CFR 61.3, Requi rement for certificates, ratings, and authorizations, and 14 CFR 61.5, Certificates and ratings issued under this part).April 10, 2015

Page 7 of 7 a. Pilot Qualifications: All PIC will be current rated pilots with current medical. They

will hold either a n airline, transport, commercial, private, recreations, or sport pilot certificate and the PIC will hold a current FAA airman medical certificate.

9. Flight areas

a. Operations will be conducted under VMC of no more than 400 feet AGL. The UA will be operated within visual line of sight at all times. NO night operations wi l l be

conducted.

10. Specif ications and Operations

a. The s UAS weighs

~ 1 7 oz., much less than the weight of a Canada g oose, and will operate under 400 ft. AGL . The aircraft internal software regulates the s UAS s o that it will not fly above 400 AGL and will limit aircraft ground speed to less than 25 mph. Impact to the public will be minimal.

b. sUAS will operate in Class G, C & D airspace.

c. Air Traffic Control Provisions. When operating in areas oth er than Class 'G' Airspace

PSI will obtain a COA first.

11. Granting the exemption would be in the public interest and benefit the public as a whole

.



### In accordance with the statutory criteria provided in Section 333 of Public Law

112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the

Secret ary of Transportation has determined that this aircraft and multiple UA larger then this UA meet the conditions of Section 333. The FAA has found in multiple UA that the requested relief from 14 CFR part 21, and any associated noise certification

and testi ng requirements of part 36, is not necessary. Exemption No. 11217 from Notus Access and Exemption No. 11238 from San Diego Gas & Electric were granted in support of the InstantEye Mk

- 2.

Please direct all questions and concern to Mr. Thomas Vaneck at Physic al Sciences

Inc. vaneck @psicorp.com