1 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 t herefore 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 Pla n?

You can join a Medicare drug plan when you first become eligible for Medicare and each year from October 15 th to December 7 th

. 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), her e by 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 wi th 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 re search.

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 § 91.1212 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 wi thin line

- of

- sigh t of the operator, flown below 2 00 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 po unds 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 a nd 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 automatical ly 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 fro m 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 ABS

reinforced 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 h as 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 retu rning 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 max imum 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 operat es 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, an d a 6S battery. SSCI is also proposin g 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 high3 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 de s cent 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 D JI 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 Visi on 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 als o 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 i ntelligent 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 an d 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 rese arch

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 Pico

ITX GX, AV nano

- LiDAR, Px4Flow, Compass, Airspeed Sensor, P ixHawk 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 lightweig ht 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 sta ff 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 visual4 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 ensu re 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 sta y 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 th e 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, Subpar t 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 in cluding, 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 displa y 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 compensati on 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 compensatio n or hire

Because the sUAS are incapable of carrying a pilot or passengers, and due to the controlled area of operation, the5 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 op erator.

• 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 t ype. 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 combi nation 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 th e 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.

• Secti on 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, w eather 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 dat a 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 runwa y 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 exempt ion 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. The refore 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. All6 Scientific Systems

– Section 333 Petition 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 alti tudes: (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 firs t 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 cert ificate. They will not, therefore, apply to SSCI should its requested exemption be granted. Even so, SSCI conducts an extensive maintenance program that7 Scientific Systems

– Section 333 Petition 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 e xpertise 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

comm ercial 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 SD B) 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 exempt ion, 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 petiti ons 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.)

.