TRANSITION

ROBOTICS, Inc.

340 Woodpecker Rdg.

Santa Cruz, CA 95060

T: 831-426-3733

F: 831-426-5666

http://transition-robotics.com

info@transition-robotics.com

November	1,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC,	20590

RE:	Exemption	Request	Under	Section	333	of	the	FAA	Modernization	and	Reform	Act	of

2012	and	14	C.F.R.	Part	11

Dear	Madam,	Sir,

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

Part	11, Transition	Robotics Inc.	("Transition	Robotics")	seeks	an	exemption	from	the	Federal

Aviation	Regulations detailed	below	for	the	Quadshot and	the	JumpShip UAS.	The	requested	

UAS	all	have	a	maximum	gross	takeoff weight	of	35 lbs	or	less	and	utilize	electric	propulsion.	The	

Quadshot is	a	commercially	available airframe while	the JumpShip is designed	and	

manufactured	by	Transition	Robotics drawing	on	the	significant	experience	of	Transition	

Robotics in	making	production grade	small	unmanned	aircraft	airframes	for	the	past	4.5 years	

along	with other	heritage	in	building	unmanned	aircraft.

The requested	exemption	would	allow	Transition	Robotics to	pursue	commercial	

interests	in	aerial data	collection	using	small	unmanned	aircraft	systems.	The	systems	proposed	

will	be	used	to	conduct data	gathering	for	agricultural	applications,	aerial	inspections,	mapping,	

surveying,	R&D	and	product demonstrations.	The	team	at	Transition	Robotics will	draw	on	

internal	and	external	expertise	in self	certifying	systems	using	MIL-HDBK 516B	and	has	

experience	working	under	FAA	COAs	in	the	past.

1 The	team	at	Transition	Robotics will	continue	

using	this	level	of	experience	and	professionalism	to	conduct safe	commercial operations	of	

small	UAS.	The	flight	team	will	operate	in	accordance	with	FAA	N	8900.227 and	utilize	both	a	

Pilot	in	Command	and	a	ground-based	visual	observer.	Transition	Robotics will	also	utilize

emergency,	lost	link,	and	lost	communication	procedures	previously	approved	for	other	FAA	

COAs and	Grants	of	Exemption	Nos.	11062,	11109,	11112	and	11213.	These	are available	upon	

request.	All	flights	under	these	exemptions	will	be	conducted	with	the	following	restrictions:

1. Flights	will	be	in	Class	G	airspace	at	no	more	than	400'	AGL.

2. The	UAS	will	be	operated	over	private	property	only	with	the	permission	of	the	owner.

3. The	UAS	will	not	be	operated	over	populated	areas.

4. The	UAS	will	not	be	operated	within	5NM	of	an	airport.

5. Operations	will	be	limited	to	daytime	operations	under	visual	meteorological	conditions.

6. The	aircraft	will	remain	within	visual	line	of	sight	of	the	observer	at	no	more	than	

1/2NM	range.

7. A	NOTAM	will	be	issued	prior	to	such	flight	operations as	deemed	necessary	by	the	FAA.

 1 Team members at Transition Robotics were previously employed at Joby Energy, Inc. and conducted 

operations under a COA from October 13, 2010 to October 12, 2011.
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8. The	UAS	will	have	a	maximum	GTOW	of	less	than	55	lbs.

9. The	aircraft	will	be	U.S.	registered	and	display	the	N-number.

10. The	PIC	and	Observer	will	possess	the	certifications	required	under	N	8900.227.

11. No	operator	or	observer	will	engage	in,	nor	may	an	operator	or	observer	permit,	any	

activity	during	a critical	phase	of	flight	which	could	distract	any	operator	or	observer	

from	the	performance	of	his/her duties	or	interfere	in	any	way	with	the	proper	conduct	

of	his/her	duties.

12. The	PIC	will	conduct	a	pre-flight inspection	prior	to	each	flight	so	as	to	ensure	that	the	

UAS	and associated	systems	are	in	a	condition	for	safe	operation.

13. The	PIC	and	observers	will	maintain	two-way	communications	with	each	other	during	all	

operations; if	unable	to	maintain	two-way	communications,	or	if	any	condition	occurs	

that	may	otherwise	cause the	operation	to	be	unsafe,	the	operator	will	immediately	

conclude	the	operation.

14. The	aircraft	will	automatically	return	to	a	specific	location	if	the	communications	link	is	

lost.

15. All	flights	will	be	conducted	below	87	knots	(100	miles	per	hour).

The	regulations	from	which	the	exemption	is	requested	are	as	follows.	The	Appendix	

contains	details	of	the	Transition	Robotics operations	related	to	showing	an	equivalent	level	of	

safety	for	these	exempt	regulations.

• 14	C.F.R.	Part	21,	Subpart	H

• 14	C.F.R.	§91.203(a)	and	(b)

• 14	C.F.R.	§45.23(b)

• 14	C.F.R.§61.23(a)

• 14	C.F.R.	§61.113(a)	and	(b)

• 14	C.F.R.	§61.133(a)

• 14	C.F.R.	§91.7(a)

• 14	C.F.R.	§91.9

• 14	C.F.R.	§91.109(a)

• 14	C.F.R.	§91.119

• 14	C.F.R.	§91.121

• 14	C.F.R.§91.151(a)

• 14	C.F.R.	Subpart	E	(§91.401	- §91.417)

UAS	Overview

Transition	Robotics is	submitting	this	request	for	exemption	for	two	different	UAS;	the	

Quadshot and	the	JumpShip. Transition	Robotics has	completed	an	airworthiness	review	of	the	

Quadshot	and	the	JumpShip.	

Transition	Robotics is	proposing	using	these	two	airframes	to	pursue	further	commercial	

applications. Both	of	these	airframes	utilize	electric	propulsion.	The	Quadshot UAS	is	a	transition

aircraft	that	takes	off	and	lands	vertically,	while	operating	as	a	fixed	wing	aircraft	in	flight,	and	

uses	foam	as	the	primary	construction	material.	It	has	a	span	of	40” and	a	GTOW	less	than	3	lbs.	

The	JumpShip is	a	transition aircraft	that	takes	off	and	lands	vertically,	while	operating	as	a	fixed	

wing	aircraft	in	flight.	It	has	a	span	of 107",	a	maximum	GTOW	of	30 lbs,	and	is	a	composite	

construction.	In	pursuing	these	applications,	Transition	Robotics will	operate	within	the	rules	

with	safety	as	a	top	priority.

Figure	1	below	contains	images	of	both	airframes.	Both	aircraft	allow	for	both	manual	

flight	through an	RC	transmitter	and	fully	autonomous	waypoint	following	using	independent	
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systems.	The	emergency and	lost	link	procedures	have	been	carefully	reviewed	by	Transition	

Robotics to	allow	safe	operations.	These procedures	are	available	upon	request.	Transition	

Robotics proposes	that	small	size	and	weight	of	the	UAS included	in	this	request	for	exemption,	

flown	under	the	guidelines	of	N	8900.227	will	have	an	equivalent level	of	safety	to	manned	

aircraft	performing	similar	missions.

(a)

(b)

Figure	l:	(a)	the	Quadshot UAS	and	(b)	the	JumpShip UAS

The	name	and	contact	information	of	the	applicant	are:

Transition	Robotics Inc.

Attn:	Pranay	Sinha

Phone:	831-426-3733 x4

E-mail:	psinha@tri.aero

Transition	Robotics requests	exemption	under	Section	333	to	enable	safe	commercial	

UAS	operations	for the	activities	stated.	By	approving	these	exemptions	the	FAA	will	create	

benefits	to	the	areas	mentioned	that is	ultimately	in	the	public	interest.	Please	contact	us	if	you	

require	additional	information	or	clarification.

Sincerely,

Pranay	Sinha

Aerodynamics	and	Controls	Engineer

Transition	Robotics Inc.

340	Woodpecker	Ridge,	Santa	Cruz,	CA	95060
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APPENDIX

Specific	Exemption	Requests	and	Equivalent	Level	of	Safety	Showings

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates

14	C.F.R.	§91.203(a)	and	(b)	- Civil	aircraft:	Certifications	required.

Section	91.203	requires	all	civil	aircraft	to	have	a	certificate	of	airworthiness.	Part	21,	

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

issuance	of	airworthiness	certificates as	required	by	FAR	§91.203(a).	Transition	Robotics

requests	an	exemption	from	these	rules	and	will	utilize	an internal	airworthiness	process	based	

on	MIL-HDBK	516B.

Such	an	exemption	meets	the	requirements	of	an	equivalent	level	of	safety	under	Part	

11	and	Section 333	of	the	Reform	Act.	The	Federal	Aviation	Act	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	UAS	involved.

14	C.F.R.	§45.23(b)	- Display	of	marks;	general.

These	regulations	provide	that	each	aircraft	must	display	"N"	and	the	aircraft's	

registration	number	in letters	at	least	3	inches	high.	Additionally,	the	aircraft	must	display	the	

word	"EXPERIMENTAL"	in letters	at	least	2	inches	high	near	the	entrance	to	the	cabin,	cockpit,	

or	pilot	station.	Given	the	size	of	the UAS,	this	requirement	is	impossible	to	match.	The	

equivalent	level	of	safety	will	be	achieved	by	having	the registered	N-number	in	1	inch	lettering	

on	the	side	of	the	fuselage and/or	wing.

14	C.F.R.	§61.23(a)	- Medical	certificates:	Requirement	and	duration.

Regulations	provide	that	a	person	must	hold	at	least	a	second	class	medical	certificate	

when	exercising:

• Second-in-command	privileges	of	an	airline	transport	pilot	certificate	in	part	121	of	this	

chapter	(other than	operations	specified	in	paragraph	(a)(1)(ii)	of	this	section);	or

• Privileges	of	a	commercial	pilot	certificate

Given	the	size	of	the	UAS	in	this	petition	and	the	limited	flight	area	and	the	safety	features	

integrated	in the	autopilot	Transition	Robotics believes	that	an	Equivalent	Level	of	Safety	can	be	

reached	if	the	operator has	a	valid	drivers license.

14	C.F.R.	§61.113(a)	and	(b),	§61.133	- Private	Pilot	Privileges	and	Limitations:	Pilot	in

Command;	Commercial	Pilot	Privileges	and	Limitations

Subsections	(a)	and	(b)	of	§61.113	prohibit	private	pilots	from	operating	aircraft	in	

commercial	operations, and	§61.133(a)	requires	an	individual	operating	an	aircraft	for	

compensation	or	hire	to	hold	a	commercial pilot	certificate.

Transition	Robotics requests	an	exemption	from	14	C.F.R.	§61.113(a)	and	(b)	and	14	

C.F.R.	§61.133(a) so	that	above	mentioned	UAS	may	be	operated	by	individuals	who	have	a	

private	pilot	certificate.	Based upon	the	design	features	of	the	UAS,	its	autopilot	system,	and	

safety	factors,	the	FAA	should	permit operation	of	UAS	by	operators	with	a	private	pilot	

certificate	when	the	conditions	described	above	have been	satisfied.	The	above-described	
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conditions	are	in-line	with	those	set	forth	in	Volume	16,	Chapter	4, Section	1	of	FAA	Order	

8900.1.

Transition	Robotics proposes	to	conduct	operations	in	accordance	with	these	

restrictions.	Given	these conditions	and	restrictions,	an	equivalent	level	of	safety	will	be	

provided	by	allowing	operation	with	a private	pilot	certificate.	The	risks	associated	with	the	

operation	of	the	proposed	UAS	(given	the	size,	speed, operational	capabilities,	and	lack	of	

combustible	fuel)	are	so	much	less	than	the	level	of	risk	associated with	fixed	wing	and	

rotorcraft	operations,	both	private	and	commercial,	as	contemplated	by	Part	61,	that allowing	

operations	of	these	UAS,	as	set	forth	above,	meets	or	exceeds the	present	level	of	safety	

provided under	14	C.F.R.	§61.113(a)	and	(b)	and	§61.133(a).

14	C.F.R.	§91.7(a)	- Civil	aircraft	flight	manual,	marking,	and	placard	requirements

This	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is in	

airworthy	condition.	Transition	Robotics requests	that	an	exemption	be	granted	allowing	

commercial	operation	without	an	airworthiness certificate.	Given	the	size	of	the	aircraft	and	the	

procedure	of	utilizing	MIL-HDBK	516B,	an	equivalent level	of	safety	will	be	achieved.

14	C.F.R.	§91.9(b)- Civil	aircraft	flight	manual,	marking,	and	placard	requirements.

This	regulation	provides	that	no	person	may	operate	an	aircraft	unless	a	current,	

approved	flight	manual	is in	the	aircraft.	Transition	Robotics assumes	that	the	intent	of	this	

requirement	is	to	ensure	that	flight	manual information	is	available	to	the	aircrew	while	

operating	the	aircraft.	Transition	Robotics requests	an	exemption to	this	requirement	since	the	

aircraft	is	not	only	too	small	to	carry	documentation,	but	also	because	the	documentation

would	not	be	available	to	the	crew.

The	equivalent	level	of	safety	will	be	achieved	by	keeping	a	hard	copy	of	the	manual	

with	the	ground crew.

14	C.F.R.	§91.109(a)	- Flight	instruction;	Simulated	instrument	flight	and	certain	flight	tests

Sections	91.109(a)	provides	that	no	person	may	operate	a	civil	aircraft	that	is	being	used	

for	flight	instruction unless	that	aircraft	has	fully	functioning	dual	controls.	The	UAS	in	this	

exemption	are	remotely	piloted aircraft,	and,	by	design,	not	equipped	with	fully	functional	dual	

controls.	Flight	control	is	accomplished through	the	use	of	a	control	box	that	communicates	with	

the	aircraft	via	radio	communications.	Utilizing	a pilot	skilled	in	remote	piloting	will	provide	an	

equivalent	level	of	safety.

14	C.F.R.	§91.119	- Minimum	safe	altitudes:	General.

The	regulation	provides	that	over	sparsely	populated	areas	the	aircraft	cannot	be	

operated	closer	than 500	feet	to	any	person,	vessel,	vehicle,	or	structure.	Since	the	UAS	in	this	

exemption	will	be	operating at	a	maximum	of	400	feet	AGL,	this	requirement	cannot	be	

followed.	To	provide	an	equivalent	level	of safety	Transition	Robotics will	only	fly	over	private	

property	with	the	permission	of	the	land	owner.	The	land owner	will	be	briefed	of	the	expected	

route	of	flight	and	the	associated	risks	to	persons	and	property	on the	ground.	We	maintain	that	

due	to	the	small	size	of	the	Transition	Robotics UAS,	the	hazard	to	persons, vessels,	vehicles,	

and	structures	is	not	comparable	to	manned	aircraft	and	should	be	considered	in	granting the	

exemption.	Furthermore,	Transition	Robotics will	not	operate	over	congested	areas	nor	over	

any	open	air assembly	of	persons.	In	the	event	of	power	unit	failure	and	operating	at	400	feet
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altitude,	the	PIC	will	be able	to	conduct	an	emergency	landing	without	undue	hazard	to	persons	

or	property	on	the	ground.

14	C.F.R.	§91.121	- Altimeter	settings.

The	regulation	states	that	aircraft	shall	maintain	cruising	altitudes	by	reference	to	an	

altimeter	setting available	within	100	nautical	miles	of	the	aircraft.	The	UAS	will	fly	below	400	

feet	AGL	and	will	not	need	to maintain	hemispherical	cruising	altitudes	in	order	to	de-conflict	

with	other	aircraft.	To	provide	an	equivalent level	of	safety,	the	autopilot	calculates	the	

reference	altitude	(ground	level)	with	the	on-board	GPS	during the	pre-flight	tests.	The	GPS	and	

barometer	data	are	then	used	to	calculate	the	altitude	in-flight.

14	C.F.R.	§91.151(a)	- Fuel	requirements	for	flight	in	VFR	conditions.

The	regulation	states	that	no	person	may	begin	a	flight	in	an	airplane	under	day-VFR	

conditions	unless there	is	enough	fuel	to	fly	to	the	first	point	of	intended	landing	and	to	fly	after	

that	for	at	least	30	minutes. As	the	aircraft in	this	request	are	electric-powered,	this	

requirement	is	inapplicable.	An	equivalent	level	of safety	is	achieved	through	a	low	battery	

power	warning	on	the	ground	station	when	there	is	10	minutes	of battery	power	remaining.	

Since	all	operations	are	within	1/2NM	of	the	observer this	will	allow	the	aircraft to	safely	land	if	

this	warning	is	active.

14	C.F.R.	Subpart	E(§91.401	-§91.417)	- Maintenance,	Preventive	Maintenance,	and	

Alterations

The	regulation	provides	that	the	operator	is	primarily	responsible	for	maintaining	the	

aircraft	in	an	airworthy condition,	including	compliance	with	part	39	and	43.	Paragraphs	91.407	

and	91.409	require	that	the	aircraft be	"approved	for	return	to	service	by	a	person	authorized	

under	43.7"	after	maintenance	and	inspection. Transition	Robotics plans	to	have	the	PIC	

perform	maintenance and	inspection	of	the	aircraft	and	"be authorized	to	approve	the	aircraft	

for	return	to	service."	The	PIC	will	ensure	that	the	aircraft	is	in	an airworthy	condition	prior	to	

flight	and	conduct	detailed	inspections	after	every	10	flight	hours.	Additionally, a	checklist	will	

be	utilized	prior	to	each	launch.	The	PIC	will	document	work	performed	in	accordance	with

91.417.	We	feel	that	due	to	the	size,	construction,	and	simplicity	of	the	aircraft,	the	PIC	can	

ensure	an equivalent	level	of	safety.