### TRANSITION ROBOTICS, Inc.

340 Woodpecker Rdg. Santa Cruz, CA 95060

T: 831

- 426

- 3733
F: 831

- 426

- 5666 http://transition

- robotics.com

i nfo@transition

- robotics.co m

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	commercial ly	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	inspectio ns,	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

s m all	UAS.	The	flight	team	will	operate	in	accordance	with	FAA	N	8900.227 and	utilize	both	a Pilot	in	Command	and	a	ground

- based	v isual	observer. Transition	Robotics will	also	utilize emergency,	lost	link,	and	lost	communication	procedures previously	approved	for	other	FAA

COA s and	Grants	of	Exemption	Nos.	11062,	11109,	11112	and	11213 .	These	are available	upon request.	All	flights	u nder	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	rang e.
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.

### Page 2 of 6 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	certificati ons	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	imm ediately conclude	the	operation.

14. The	aircraft	will	auto matically	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.	T he	Appendix
contains	details	of the Trans ition	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 1 07 ",	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	us ing	independent

### Page 3 of 6 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 in cluded	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 x 4

E

- mail: psinha @ tri.aero

Transition	Robotics requests	exemption	under	Section	333	to	enable	safe	commercial UAS	operations	for the	activities	st ated.	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

### Page 4 of 6 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	c ertificates 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	unde r	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,	operatio nal	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	lev el	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	oper ations, 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	mention ed	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	c onditions	described	above	have been	satisfied.	The	above

- described

### Page 5 of 6 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	carr y	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	pi loted 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	wil l	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.	Sin ce	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	la nd 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

### Page 6 of 6 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
alt imeter	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	safet y,	th e	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	condit ions. 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	a re	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 obs erver 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	th e 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	Roboti cs plans	to	have	the	PIC perform maintena n ce 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	simplici ty	of	the	aircraft,	the	PIC	ca n

ensure	an equivalent	level	of	safety.