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Scientific Systems – Section 333 Petition

1. Scientific Systems Co., Inc. has determined that the prescription drug coverage offered by 

Tufts Health Plan is, on average for all plan participants, expected to pay out as much as 

standard Medicare prescription drug coverage pays and is therefore considered Creditable 

Coverage. Because your existing coverage is Creditable Coverage, you can keep this 

coverage and not pay a higher premium (a penalty) if you later decide to join a Medicare 

drug plan. 

When Can You Join A Medicare Drug Plan?

You can join a Medicare drug plan when you first become eligible for Medicare and each year from October 

15th to December 7th. 

Date: October 28, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., 

SE Washington, DC 20590

RE: Request for Issuance of Exemption under Title 14 CFR, Section 333 

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Scientific 

Systems Company, Inc. (SSCI), hereby applies for an exemption from Federal Aviation Regulations (FARs) 

identified below, to allow for the commercial operations of small Unmanned Aerial Systems (sUAS) so long 

as the proposed operations are conducted within the conditions outlined herein or as may be established by 

the FAA as required in accordance with Section 333.

This exemption is in accordance with protocols outlined in this petition, request exemption for the following 

sUAS: DJI multi-copters (Phantom Series 1-3, Inspire, Flamewheel 450, Flamewheel 550), 3DRobotics 

multi-copters (Iris+, X8+, Solo), and the Parrot Bebop quadcopter, all manufactured in standard 

configurations, with additional cameras, sensors, and other components secured using standard third party 

mounts, with additional anchoring as necessary. SSCI is requesting this exemption to utilize the above 

sUAS for data collection, video and photography, combined with other standard UAV sensors (GPS and 

IMU) data. Data collected will be used in the development of new UAV perception and control algorithms 

in support of government funded research. 

The name and address of the Petitioner is: 

Scientific Systems Company, Inc

500 West Cummings Park

Suite 3000

Woburn, MA 01801

Ph: (781) 933-5355

Regulations from which this exemption is requested:

 14 CFR § 21 (H)

 14 CFR § 45.23 (b)

 14 CFR § 61.113 (a, b)

 14 CFR § 91.7 (a)

 14 CFR § 91.9(b)(2)

 14 CFR § 91.103

 14 CFR § 91.109

 14 CFR § 91.119

 14 CFR § 91.121
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Scientific Systems – Section 333 Petition

 14 CFR § 91.151 (a) 

 14 CFR § 91.405 (a)

 14 CFR § 91.407 (a)(1)

 14 CFR § 91.409 (a)(2)

 14 CFR § 91.417 (a, b)

Description of proposed sUAS:

SSCI has a number of small commercial UAS/UAV platforms, primarily quadcopters manufactured by 

3DRobotics, Parrot and DJI. All of the quadcopters are well under 55 pounds (including additional cameras 

and sensors attached), are flown within line-of-sight of the operator, flown below 200 feet and during 

daylight hours only, and are restricted to fly only over areas permitted by the landowners. 

SSCI proposes to utilize the Iris+, manufactured by 3DRobotics. The quadcopter weighs 2.82 pounds with a 

maximum capacity of 0.8 pounds for its payload. It is operated from the ground utilizing a remote 

controller operating at a frequency of 915 MHZ. The Iris+ is equipped with ublox GPS with integrated 

magnetometer, an auto-return home feature and the ability to land itself automatically if it is running out of 

battery. This quadcopter also has “Gofence” technology which would allow the applicant to set boundaries 

for the flight; if the Iris+ runs into one of these boundaries it will automatically return to its launch point. It 

has maximum flight duration of 22 minutes. 

SSCI is proposing to utilize the X8+, manufactured by 3DRobotics. This quadcopter weighs 5.6 pounds 

with a maximum capacity of 1.7 pounds for its payload. It is operated from the ground utilizing a remote 

controller operating at a frequency of 915 MHZ. The X8+ is equipped with 3DR ublox GPS with Compass. 

It has maximum flight duration of 15 minutes. 

SSCI is proposing to utilize the Bebop, manufactured by Parrot. The Bebop's foam body and ABSreinforced structure keep the Bebop light. Its maximum weight is 14.5 ounces. It's compact, too, measuring 

roughly 12 inches square and 1.5 inches tall. A fully charged battery provides maximum flight times of 12 

minutes. The Bebop has MIMO Wi-Fi connection: Parrot Bebop Drone embarks 2 dual-band Wi-Fi 

antennas that allow it to handle both 2.4 GHz and 5 GHz MIMO frequencies. It generates its own Wi-Fi 

802.11 network. Depending on the network interference, you can select the frequency of your choice. When 

“Return Home” is selected the Bebop drone returns directly to its starting position when the altitude is 

greater than 10 meters. If the altitude is less or equal to 10 meters, it will rise and stabilize itself at 10 meters 

before returning to its take-off position in a straight line. Once it has reached its take-off position, it will 

stop and hover 2 meters above the ground. 

SSCI proposes to utilize the 3DR Solo, manufactured by 3DRobotics. The quadcopter weighs 3.9 pounds 

and a maximum capacity of 0.92 pounds for its payload. The 3DR Solo has a maximum speed of 55mph 

with a range of a half-mile for maximum distance. The quadcopter has maximum ascent and descent speeds 

of 10 m/s in stabilization mode; 5 m/s in “fly” mode. It operates on a 2.4GHz frequency through a 3DR 

Link secure Wi-Fi network. It has a maximum altitude of 400ft. The 3DR Solo runs on the PixHawk 2 

autopilot system, as well as two 1GHz computers (one in the controller, one in the copter). 

SSCI is also proposing to utilize the Flamewheel 450 and Flamewheel 550, manufactured by DJI. The 

configuration of the Flamewheel will be configured with standard DJI motors (E4300, E600), 12” 

propellers, using a PixHawk autopilot, 3DR ublox compass, standard RC controller, and a 6S battery. 

SSCI is also proposing to utilize Inspire, manufactured by DJI. The DJI Inspire weighs 2935 grams 

including built in battery and dimensions of 438x451x301 mm. The DJI standard battery is a LiPo 6S high 
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Scientific Systems – Section 333 Petition

voltage battery, with a capacity of 4500 mAh and voltage of 22.2V. The DJI Inspire has a max ascent speed 

of 5 m/s and a max descent speed of 4 m/s. Maximum flight time is 18 minutes, and max speed of 10 m/s. 

The remote control for the DJI Inspire operates on 5.725~5.825 GHz and 2.400~2.483 GHz. It can also be 

controlled by a mobile phone or tablet that is iOS 8.0 or later and Android 4.1.2 or later. 

SSCI proposes to utilize the DJI Phantom series. The DJI Phantom 1 has a diagonal distance of 350.0mm, 

and weighs less than 1200g. The DJI Phantom 1 requires 4 AA batteries for the controller that works on a 

2.4GHz ISM frequency at a communication distance of 1000m. The DJI Phantom 1 battery is a 20W LiPo 

battery, it has a max speed of 10 m/s and a max ascend and descend speed of 6 m/s. 

The DJI Phantom 2 weighs 1000g, which includes the battery and propellers. It has a max speed capability 

of 15 m/s and a maximum flight time of 25 minutes. The supported smart battery is a 3S LiPo with a 

capacity of 5200mAh. The remote control operates on a 2.4GHz ISM frequency with a communication 

distance of 1000m. The DJI Phantom 2 also features an auto Return-to-Home and landing. The Phantom 2 

Vision weighs 1160g, and has a max ascent speed of 6 m/s and descent speed of 2 m/s. The Phantom 2 

Vision has a max speed of 15 m/s. The controller operates on 4 AA batteries, and utilizes a frequency of 

5.728GHz – 5.8GHz. The range extender increases Wi-Fi distance up to 300m. 

The DJI Phantom 2 Vision+ weighs 1242g, with a 5200mAh LiPo battery. It also has a max speed of 15 

m/s and the same max ascent and descent speeds as the Phantom 2 and Phantom 2 Vision. The Phantom 2 

Vision+ remote control operates on the same frequency as the Phantom 2 Vision, but the controller has a 

built in 3.7V battery. The range extender has an operating frequency of 2412-2462MHz and in an open area 

can extend to 700m. 

The DJI Phantom 3 Pro/Adv weighs 1280g with a max speed of 16 m/s. The DJI Phantom Pro/Adv has a 

max ascent of 5 m/s and max descent of 3 m/s. It has an intelligent flight battery with a capacity of 4480 

mAh, 15.2 V, and is a LiPo 4S, weighing 365g. It has a max flight time of 23 minutes. The remote 

controller operates on 2.400 GHz-2.48 GHz with a maximum distance of 2000 when outdoors and 

unobstructed. The remote controller operates on a 6000 mAh LiPo 2S. The DJI Phantom 3 Pro/Adv can 

also be controlled by a phone or tablet with iOS 8.0 or later and Android 4.1.2 or later. The standard 

Phantom 3 weighs 1216g with a maximum flight time of 25 minutes and the same remaining specs of the 

DJI Phantom 3 Pro/Adv. 

Each sUAS will be modified with additional sensors and cameras for the purpose of data collection in 

support of various research and development efforts, funded by SSCI and through Government research 

contracts. Additional sensors and cameras include, but are not limited to: PointGrey Flea3, Leopard 

Imaging M021M, Leopard Imaging OV3640, Leopard Imaging M021C, Nvidia Jetson TK1, SECO PicoITX GX, AV nano-LiDAR, Px4Flow, Compass, Airspeed Sensor, PixHawk IMU Block, Forward failsafe 

sensor, fixed mount, anti-vibration mount, and/or rotation stabilization mount. Each sUAS that is modified 

may have one or more of the sensors and cameras listed, or similar. Additional sensors and cameras are 

lightweight and fall within the payload that each sUAS is capable of handling. These sensors and cameras 

will help collect the necessary data needed to record and will support SSCI research objectives. 

Safety / operating procedures:

SSCI employs numerous staff with private pilot certificates, in addition to graduate school and/or 

commercial experience in building, maintaining, and flying small unmanned air vehicles during flight 

testing in military airspace. All flights will take place under the supervision of at least one experienced pilot 

or operator. SSCI will ensure that an experienced pilot or operator will sign off on flight plans for every 

flight, ensuring that the plan is safe and within the guidelines and requirements of the exemption. For an 

SSCI staff member to become a person in control of the sUAS, they will be trained by one of SSCI’s 

existing licensed pilots and/or an experienced UAV operator. The person in control will maintain visual 
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Scientific Systems – Section 333 Petition

contact with the UAV at all times. At least 3 persons will be present at each flight; any of the PIC, VO, or 

the SO can command an end to the flight at any time. A Safety Officer will maintain awareness of the 

surroundings to ensure that operations stay within the planned safety parameters. The SO will also ensure 

no bystanders accidentally come within a pre-defined safety range. All flights will take place with 

permission of the land owner, will not take place by airports, and will remain below 200ft. The air vehicles 

will not fly over any people, and will stay outside the pre-defined safety range of people (GPS fence 

limited). SSCI will not fly the air vehicles over any building or vehicles unless there is explicit permission 

from the owners of those vehicles or buildings. SSCI staff will also be aware of the flight manuals and 

safety regulations of the air vehicles they are flying, as outlined in their user manuals. 

Extent of Relief Sought and Reasons for request:

• Section Part 21 Subpart H, Airworthiness Certificates: Certification Procedures for Products and Parts 

prescribes in pertinent part, the procedural requirements for issuing and changing design approvals, 

production approvals, airworthiness certificates, and airworthiness approvals. 

The applicant requests and exemption from 14 CFR Part 21, Subpart H and the requirement for airworthiness 

certificate in general. SSCI will be flying lightweight, small UAV’s for the purpose of data collect for research 

into new sensor processing and flight control technologies; SSCI will ensure all safety measures including, but not 

limited to signing off on flight plans for every flight, ensuring that the plan is safe and within the guidelines and 

requirements of the exemption. 

• Section 45.23(b) Display of marks; general

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman 

capital letter “N” (denoting United States registration) followed by the registration number of the 

aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. 

 (b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

“limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

Due to the small size of the sUAS, the applicant requests an exemption from 14 CFR 45.23(b) that would 

allow the sUAS to display the registration number in letters and numbers as large as practical on its 

fuselage.

• Section 61.113(a) and (b) prescribes that –

 (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that 

is carrying passengers or property for compensation or hire; nor may that person, for compensation or 

hire act as PIC of an aircraft

 (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if -

 (1) The flight is only incidental to that business or employment: and

 (2) The aircraft does not carry passengers or property for compensation or hire

Because the sUAS are incapable of carrying a pilot or passengers, and due to the controlled area of operation, the 
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Scientific Systems – Section 333 Petition

applicant seeks an exemption from this regulation. The applicant has employees that are holders of private pilot 

certificates, in addition to graduate school and/or commercial experience in building, maintaining, and flying 

small unmanned air vehicles during flight testing in military airspace. All flights will take place under the 

supervision of at least one experienced pilot or operator. 

• Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition.

Given that if this exemption is granted, there will be no airworthiness certificate, and no standard exists for an 

aircraft of this type. We propose to utilize each manufacturer’s operating and maintenance manuals. The PIC, VO 

and/or SO will inspect the sUAS prior to the flight to determine if it meets safety requirements as outlined by their 

individual user manuals.

• Section 91.9(b) (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

Due to the size and configuration of the sUAS, there is no room or capacity to carry such an item on the aircraft. 

We propose maintaining and equivalent level of safety by keeping the manual of the aircraft that is currently in 

use, at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 

10167, 10167A, 10602, 10700 and 32827.

• Section 91.103 prescribes that each PIC shall, before beginning a flight, become familiar with all available 

information concerning that flight, to include –

(a) For a flight under instrument flight rules (IFR) or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, 

and any known traffic delays of which the PIC has been advised by air traffic control (ATC) 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff 

and landing distance data is required, the takeoff and landing distance data contained therein; and 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and temperature.

We request an exemption from 14 CFR 91.103 as FAA approved flight manuals will not be used. In the absence 

of flight manuals, the PIC will take all pre-flight actions including but not limited to: reviewing the weather, flight 

battery requirements, launch and landing area assessments and aircraft performance data before commencing a 

flight.

• Section 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

We request an exemption from 14 CFR 91.109 as evidence is inconclusive that a person with a private pilot 

certificate can successfully maneuver or train someone in the safe operation and maneuvering of a sUAS without 

first hand flight experience with the particular sUAS. Therefore the training we will offer will provide an 

equivalent level of safety; as well as following all safety guidelines as stated in the sUAS user manuals. All 
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PICs, SO and VO’s attending the flight test will have experience flying the sUAS being used, and the user manual 

will be on-site and within reach of the operator at all times. 

• Section 91.119 Minimum safe altitudes: General – prescribes that, except when necessary for takeoff or 

landing, no person may operate an aircraft below the following altitudes:

 (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without

 undue hazard to persons or property on the surface.

 (b) Over congested areas. Over any congested area of a city, town , or settlement, or over any

 open-air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a

 horizontal radius of 2,000 feet of the aircraft. 

We request an exemption from 14 CFR 91.119 as we believe an equivalent level of safety will be achieved given 

the size, weight and speed of the small UAVs. No flights will be taken without proper notices given, and 

permission being received from the property owners, therefore adequate notice will be provided for any 

individuals that may be affected by this operation. Additionally, since there is no flammable fuel load, any 

potential risk associated with these operations is far less than those presently presented utilizing conventional 

aircrafts operating below 500 ft. AGL. Finally, the low-altitude restriction of the sUAS operations will ensure 

separation between the sUAS and conventional aircrafts that must comply with these sections. 

• Section 91.121 Altimeter settings – prescribes in pertinent part, that each person operating an aircraft shall 

maintain the cruising altitude by reference to al altimeter that is set when operating below 18,000 feet mean 

sea level (MSL) to the elevation of the departure airport or an appropriate altimeter setting available 

before the departure. 

We request an exemption from 14 CFR 91.121 as the sUAS are not always equipped with a barometric altimeter, 

but instead uses GPS altitude data. An equivalent level of safety will be achieved by the PIC verifying the 

altitude at the launch site prior to, and during the flight. 

• Section 91.151 Fuel requirements for flight in VFR conditions:

 (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming 

normal cruising speed—

 (1) During the day, to fly after that for at least 30 minutes; or

 (2) At night, to fly after that for at least 45 minutes.

We seek and exemption from 14 CFR 151 as we believe we can achieve an equivalent level of safety by requiring 

an operation to be terminated when the indicated battery power reaches 20%. This would provide more than 

sufficient time for the sUAS to return to its planned landing zone from anywhere in the limited VSOL operating 

area.

• Section 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above-cited 

Regulations require, amongst other things, aircraft owners and operators to "have [the] aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph C of this section, have discrepancies repaired as prescribed in part 43 of this chapter."

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to SSCI 

should its requested exemption be granted. Even so, SSCI conducts an extensive maintenance program that 
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involves regular software updates and constant inspection for assessment and replacement/repair of any damaged 

hardware. Therefore, an equivalent level of safety will be achieved. SSCI is using currently manufactured UAS’s 

for its research which have been produced in significant numbers, which also allows SSCI to avail itself of the 

higher reliability and expertise of the vehicle manufacturers which will further help in keeping all vehicles safe.

Reasons why granting the request would be in the public interest

SSCI develops cutting edge algorithms for small unmanned air vehicles for both government and 

commercial customers. It is in the public’s interest for the United States of America to build and maintain 

technical superiority in this area, which requires the ability to flight test outdoors in non-military airspace. 

Conclusion

SSCI (a minority-owned SDB) is among the Top 20 companies (out of 10,000) in the Small Business 

Innovation Research (SBIR) program. SSCI is a responsible company that understands the safety required to 

flight test, obtaining permission from landowners, and flying away from people. We have a unique focus on 

transitioning our technology to operational platforms to increase the effectiveness and decrease the 

operating cost of Unmanned Vehicles through major improvements in automation and ‘Intelligent 

Autonomy’. If granted the exemption, we are proposing use of platforms that are widely used by hobbyists. 

The work we do is in the national interest, and the products we plan to create are in the public interest. 

Additional consideration:

The FAA has set precedence in granting petitions to other entities that propose to engage in the same or 

similar types of activities under essentially the same operating parameters. Grant exemption numbers 11062 

(Astraeus Aerial), 11109 (Clayco Inc.), 11112 (VDOS Global) and 11213 (Aeryon Labs, Inc.).